A. OVERVIEW:

A Code of Practice to protect the uniqueness and integrity of Sable Island has been developed as an integral part of ExxonMobil Canada's environmental protection planning. The intent is to provide a guide for the design, development and implementation of the Sable Project so that the sensitive and valued environment of Sable Island is protected. Personnel are NOT to disembark on Sable Island, fly over Sable Island, or approach within 1 kilometre of Sable Island unless required to do so in a life-threatening emergency or with written approval from the appropriate government agencies and written approval from ExxonMobil Canada. In all cases, personnel are to follow this Code of Practice.

Sable Island, about 41 kilometre in length, is located approximately 290 kilometres southeast of Halifax; composed of sand, the island is the only emergent portion of Sable Island Bank. The island as a diverse flora and fauna; over time its vegetation cover and oceanic currents have stabilized it. The best known component of its fauna is a population of feral horses, which were introduced sometime shortly after 1738; their numbers range between 150 and 400 individuals.

The island also supports numerous migrants, and small numbers of breeding bird species. Sable is, for example, the only breeding ground of the rare Ipswich Sparrow, and is also home from mid-May to mid-July to small breeding numbers of the threatened Roseate Tern, as well as Arctic Terns, gulls, sandpipers, plovers, black ducks and mergansers. It is a federal Migratory Bird Sanctuary administered by Environment Canada's Canadian Wildlife Service. Gray seals pup from late December to early February on Sable; with in the order of 18,000-19,000 pups produced, with births peaking in early January. Adults will swim in the surrounding waters and may feed if prey is easily available. A small breeding population of harbour seals also inhabits Sable, hauling out on the island throughout the year and pupping in late May-early June. They live in the Scotian Shelf area year-round, breeding on isolated islands along the Nova Scotian coast.

At present access to, and activities on, Sable Island are regulated under the legislative mandate of the Canadian Coast Guard, Department of Fisheries and Oceans (DFO), through the Canada Shipping Act, Sable Island Regulations. The island is also protected by the Migratory Bird Sanctuary (MBS) Regulations under the Migratory Birds Convention Act. Although these provide a relatively high degree of protection for the island, the conservation value of the MBS designation is primarily for migratory birds and their nests; the MBS regulations are effective as a conservation tool when migratory birds are nesting.

The federal Fisheries Act administered by the DFO extends protection and management jurisdiction to marine mammals. Of particular relevance to Sable Island is the protection this legislation provides to seal populations.

A Conservation Strategy for Sable Island has been prepared by Environment Canada and approved by DFO and the Province of Nova Scotia. The strategy was prepared for Environment Canada's Canadian Wildlife Service by the Sable Island Conservation Strategy Advisory Committee; the latter is composed of representatives of Dalhousie University, government and non-government organizations with interests in, and knowledge of, Sable Island. The strategy defines the environmental limits within which future activities should proceed and the various conservation priorities both biological and physical. It provides a basis for the establishment of long-term development principles. The strategy specifies the following "priority requirement":

"On Sable Island the priority conservation focus must be habitat, everything else devolves from this. The Island owes its very existence to the stabilizing effect of its vegetative cover and no activity can be permitted which would endanger it".

The intent of ExxonMobil Canada's Code of Practice is to provide clarity to all personnel working with ExxonMobil Canada on aspects of the project concerning interactions between project activities and Sable Island. The Code of Practice addresses the following:

• Project activities on the Island;
• Vessel routing in the vicinity of the Island;
• Aircraft flights near and over Sable Island; and,
• Waste Management.

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• Do not disturb, feed, harm or handle any wildlife on the island or in waters surrounding the island.

• Do not damage any beach or dune vegetation by vehicle traffic, or by excavation or construction.

• Do not destabilize areas of unvegetated sand by vehicle or foot traffic, or by excavation or construction.

• Do not dump or bury garbage, and do not burn it in open-air fires.

• Follow all Sable regulations and guidelines (including the 1992 Canadian Coast Guard Visitors Guidelines), and read carefully the following details of ExxonMobil Canada's Code of Practice.

• Receive an Orientation to the island and act in accordance with this Code of Practice; review the map provided in the orientation, indicating the locations of buildings, and designated roads and driveways. While the map also shows ponds and vegetated terrain, areas of newly developing vegetation may occur almost anywhere on the island. The map should be used only as a general reference, and personnel must be watchful for areas of vegetation not indicated on the map.

• ExxonMobil Canada's environmental representative will be available to "introduce" newcomers to Sable Island habitat, flora and fauna.

• If in doubt, consult with the Atmospheric Environment Branch (AEB) Officer-in-charge or with ExxonMobil Canada's environmental representative on the island.

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1. Travel:

1a ) Vehicle Traffic

Dune and beach vegetation is very vulnerable to disturbance. While a single passage of a vehicle over vegetated terrain may not cause serious long-term damage, driving on dunes and beach vegetation is NOT permitted. In general, all vehicle traffic is restricted to the north and south beaches and to the designated inland roads. These roads are:

• From north beach into the AEB area.
• From south beach into the AEB area.
• From north beach into the West Light complex.
• Inland between AEB and West Light (running along the north side of the fresh water pond system).
• The "driveways" into the NSNR camp and into the DFO camp near East Light.

Do not drive vehicles through or over any terrain management sites. Such sites can be recognized by the presence of snow fencing or tree fencing, and plots of transplanted beach grass. If personnel are unsure about the locations of such sites they can consult with the AEB Office-in-charge or with ExxonMobil Canada's environmental representative.

Recreational (off-duty) vehicle traffic is not only restricted to the beaches and designated roads, but should not be driven into the extensive blowout and washover areas, or on to the "bald dunes". Off-duty personnel wishing to explore inland of the beaches must walk.

1b) Foot Traffic

Recreational travel on foot through vegetated terrain in permitted:

• Walkers should avoid climbing steep slopes to reach dune tops.
• Walkers should avoid the sharp-edged seaward margins of dunes.
• When walking off the established roads (1a.), use "traditional paths" (made by people and/or horses) whenever possible as long as such paths are not in conflict with the two preceding points. By following well-used paths personnel have less chance of stepping on birds' nests or flushing ducks, and can avoid trampling plants of particular vulnerability or restricted distribution. Also any localized damage caused by foot traffic along particular well-used paths can be monitored and remedied, if necessary.

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2a) Horses

Do not feed, chase or attempt to handle the horses. Mares with very young foals should not be approached at all. If you encounter a "lost" foal or injured horse, it would be appreciated if you would report the observation to Ms. Zoe Lucas (an environmental scientist normally on the island, who can be contacted through AEB station personnel). The horses are protected by federal law from all interference.

Since long-term studies of the horses are underway, do not remove any horse skulls or bones from the island. Also, report finds of walrus skulls and bones to the AEB Officer-in-charge or to Ms. Zoe Lucas. The walrus were hunted to extinction early in the 18th century. Their remains, however, are under study by researchers with the Canadian Museum of Nature, and all walrus bones must be photographed and/or measured before they are taken off the island.

2b) Birds

During spring and summer, avoid walking through the gull and tern nesting colonies found on both the beaches and the vegetated dunes. The most critical period for terns is late May to late July and persons should stay at least 100 meters from all nesting colonies. Terns and gulls make the presence of their colonies known by taking to the air and calling noisily. When inadvertently encountering a colony, pay attention to the agitated birds and retreat. Do not proceed in their direction.

In some cases, terns nest in small groups (10 to 20 birds) and their nests may not be obvious. Terns'nests are little more than scrapes-depressions in sandy areas or amongst drift debris (eg. shells, and fragments of wood, peat and litter). The small size and sandy mottled colour pattern of terns' eggs make them equally difficult to see. When driving on the beach it is possible to run over such nests and eggs before noticing the disturbed terns taking to the air. Drivers must be particularly watchful for such inconspicuous "beach" nests in the following areas:

• The outer portions of the Sandy Plain (the wide section of the south beach).
• The north and south beaches along the eastern-most and western-most highly vegetated dunes.
• On the east and west spits.

2c) Seals

Seals on the beach should not be approached or frightened into the water. Harbour seals are particularly vulnerable during their pupping season in early May to mid-June.

2d) Vegetation

Some plants found on Sable Island are very restricted in distribution and should not be disturbed. Since such plants generally occur in areas of lusher and wetter vegetation, it is advisable to avoid such areas. Under no circumstances should any species of a plant or animal be deliberately introduced to Sable Island.

2e) Miscellaneous

While it is the intention of ExxonMobil Canada to ensure that no one associated with its Sable Island operations are in any way responsible for damage or disturbance to the island's environment, personnel should also be aware that Sable Island flora and fauna have legal protection:

• The Sable Island Regulations promulgated in 1961 under the Canadian Shipping Act control disturbance of terrain and give protection to the horses.
• Birds have been protected by federal Migratory Bird Sanctuary regulations since 1977. Sanctuary designation provides additional protection for the breeding populations of Ipswich Sparrows, and Common Arctic and Roseate terns.
• Seals are protected by regulations of the Canadian Fisheries Act.

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3a) Camping

Camping is NOT permitted.

3b) Recreational Fishing

Recreational fishing (from boat or from beach) or in the fresh water ponds is NOT permitted.

3c) Garbage

Garbage is the responsibility of the visiting individual or group. It can be handled in two ways:

• The first option is to save all garbage and take it off the island when leaving at the end of the trip.
• The second option is to arrange for disposal at the weather station. In the latter case, the garbage must be separated into: metal (foil, aluminum and food cans) which must be washed and flattened; toxic (batteries, aerosol cans, used oil and filters); glass (washed); clean, dry and bundled cardboard box material; and burnable (plastics, papers, food scrapes, etc.). Burial or open-air burning of garbage is NOT permitted.
• Composting of food scraps (excluding meat) is permitted, however the scraps must not be accessible to the horses (i.e. the composting must be done in a composting bin or within a fenced enclosure).

Fuel and oil use or storage must have adequate containment. All fuel, oil, oily material or lubricants are collected in a closed system that is designed for that purpose. Any accidental spills of fuel and oil must be reported immediately to the AEB Office-in-charge and ExxonMobil Canada.

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The preceding guidelines have been prepared in order to ensure optimum protection of the Sable Island habitat, flora and fauna. In some cases the rationale for these guidelines may not be immediately obvious to newcomers. Personnel interested in the rationale for these guidelines, and/or in a better appreciation of Sable Island can refer to a number of books and papers covering the subject. A collection of literature on various aspects of Sable Island natural and social history has been prepared for use by ExxonMobil Canada personnel and contractors working on the island, and is available on short-term loan from the AEB office on Sable Island. Included in this collection are:

"The Fauna of Sable Island" by Barry Wright, Nova Scotia Museum Curatorial Report Number 68, October 1989, pp.1-93.

"The Birds of Sable Island, Nova Scotia" by Ian A. McLaren, Proc. N.S. Inst. Sci.(1981) Vol.31, pp 1-8

"The Ipswich Sparrow" by W.T.Stobo amd I.A. McLaren, Nova Scotia Institute of Science, 1975, pp, 1-105.

"The Horses of Sable Island" by Barbara J. Christie (with postscript by Zoe Lucas), Pottersfield Press (1995) 2nd Edition, pp.1-111.

"The Vegetation and Phytogeography of Sable Island, Nova Scotia" by P.M. Catling, B. Freedman and Z. Lucas, Proc. N.S. Inst. Sci. (1984) Vol.34,pp.181-247.

"Report on Experimental Transplanting and Terrain Management on Sable Island, Nova Scotia, 1995", prepared for Mobil Oil Canada, Ltd. and PanCanadian Nova Scotia Limited, by Zoe Lucas March 1996.

"Sable Island, Fatal and Fertile Crescent" by Lyrall Campbell, Lancelot Press, 1974, pp.1-104.