First Information Request Package from the Technical Review of the April 2015 Goliath Gold Environmental Impact Statement

• Cover Letter
  • IR-1 Annex A1
  • IR-1 Annex A2
  • IR-1 Annex A3
    • IR-1 Addendum to Annex A3 September 11, 2015
  • IR-1 Annex A4
  • IR-1 Annex B

Cover Letter

Canadian Environmental Assessment Agency
Ontario Region
55 St. Clair Avenue East, Suite 907
Toronto, Ontario
M4T 1M2

Agence canadienne d'évaluation environnementale
Région de l'Ontario
55, avenue St-Clair Est, Bureau 907
Toronto (Ontario)
M4T 1M2

June 30, 2015

ELECTRONIC MAIL

Mr. Norm Bush
Vice President, Goliath Gold Project
Treasury Metals Inc.
PO Box 783

Dryden, ON P8N 2Z4

Dear Mr. Bush:

SUBJECT: First Information Request Package from the Technical Review of the April 2015 Goliath Gold Project Environmental Impact Statement

The Canadian Environmental Assessment Agency (the Agency) has completed the technical review of the April 2015 Goliath Gold Project (the Project) Environmental Impact Statement (EIS) documentation from Treasury Metals Inc. (TMI).

The technical review is intended to ensure sufficient information is available for the Agency to conclude on whether the Project is likely to cause significant adverse environmental effects and to prepare the environmental assessment (EA) report. The Agency, along with federal authorities (Environment Canada, Fisheries and Oceans Canada, Health Canada, Natural Resources Canada, and Transport Canada) and provincial ministries (Ministry of Natural Resources and Forestry, Ministry of the Environment and Climate Change, and Ministry of Tourism, Culture and Sport), generated comments on the EIS documentation. Also, the Agency received comments and questions from Eagle Lake, Grassy Narrows and Naotkamegwanning First Nations, Wabigoon Lake Ojibway Nation, the Métis Nation of Ontario, Aboriginal People of Wabigoon, Grand Council of Treaty #3, and members of the public on the EIS and the Project.

Following its technical review, the Agency has drafted comments on matters related to a number of topics, including, but no limited to: fish and fish habitat; wildlife and wildlife habitat, including migratory birds and species at risk; human environment, including impacts on Aboriginal peoples; mine waste management, including geochemistry and geology; the atmospheric environment, including air quality, light and noise; groundwater quality and quantity; surface water quality and quantity; Aboriginal and public engagement; environmental assessment methodology; project description; alternatives assessment; accidents and malfunctions; cumulative effects assessment; and, the effects of the environment on the Project.

The Agency submits the following information request and comments in Annex A of this letter. Annex A is subdivided into four parts:

• Annex A1 contains requests from the Agency and other government reviewers, provided in accordance with s.23(2) of the Canadian Environmental Assessment Act, 2012 (CEAA 2012). These information requests relate to the EA and must be satisfactorily addressed in order for the Agency to continue the EA process and prepare the EA report.
• Annex A2 contains regulatory comments from government reviewers that must be addressed during the federal and provincial regulatory processes, as appropriate, but not necessarily during the EA process. Comments considered supplementary actions for consideration are also included in Annex A2.
• Annex A3 contains comments from Aboriginal communities and groups. These comments are provided in accordance with s.23(2) of CEAA 2012 and must be satisfactorily addressed for the purposes of the EA process and the Agency's preparation of the EA report. TMI is expected to respond to these directly to the Agency and directly to the Aboriginal communities and groups. Also note that some comments in Annex A3 are linked to information requests in Annex A1.
• Annex A4 contains comments from members of the public and responses to these comments should be made publicly available and submitted directly to the Agency.
• Annex B consists of a companion sheet, which outlines the deliverables the Agency must receive from TMI and the instructions TMI must follow. The procedural direction provided in the companion sheet is being proposed in part due to the size, scale and scope of the First Information Request Package. Further, the Agency expects to receive a draft response package for review to provide feedback to TMI prior to finalization of the response package. In addition, the Agency will complete another conformity review of the formal submission to ensure the response package is complete.

This letter and all annexes collectively form the first Information Request (IR-1). In accordance with s.23(2) of CEAA 2012, the Agency requests, at a minimum, that TMI submit complete responses to the requests and comments appearing in Annexes A1, A3 and A4.

The timeline is stopped as of June 30, 2015 and will not recommence until the Agency completes the conformity review of the formal submission of responses to the IR-1 and is satisfied that robust responses to the comments and questions have been received.

In accordance with section 78(3) of CEAA 2012, IR-1 will be made available to Aboriginal groups and the public upon request.

The Agency is willing to meet with TMI to discuss the path forward and schedule meetings on specific EA thematic areas with all government reviewers, TMI and TMI's consultants to clarify expectations for the IR responses.

Please feel free to contact me directly at 416-952-1574 or loraine.cox@ceaa-acee.gc.ca.

Sincerely,

<Original signed by>

Loraine Cox
Project Manager

Attachments:

Annex A – First Information Requests and Comments on the April 2015 Environmental Impact Statement

• Annex A1: First Information Requests on the April 2015 Environmental Impact Statement for the Goliath Gold Project Submitted by the Canadian Environmental Assessment Agency
• Annex A2: Other Government Comments on the April 2015 Environmental Impact Statement for the Goliath Gold Project
• Annex A3: Comments on the April 2015 Environmental Impact Statement for the Goliath Gold Project from Aboriginal Communities and Groups
• Annex A4: Comments on the April 2015 Environmental Impact Statement for the Goliath Gold Project from Members of the Public

Annex B – Goliath Gold Project IR-1 Companion Sheet

cc:

Rob Read, Environment Canada
Natalie Webster, Fisheries and Oceans Canada
Kitty Ma, Health Canada
Regent Dickey, Major Projects Management Office
Kate Cavallaro, Natural Resources Canada
David Zeit, Transport Canada
Shawn Burr, Ministry of the Environment and Climate Change
Dave Lyle, Ministry of Natural Resources and Forestry
Patrick Barnes, Ministry of Northern Development and Mines
Joe Muller, Ministry of Tourism, Culture and Sport

IR-1 Annex A1

ANNEX A1 - Information Requests on the April 2015 Environmental Impact Statement for the Goliath Gold Project Submitted by the Canadian Environmental Assessment Agency

The Canadian Environmental Assessment Agency (the Agency) provides the following information requests.

Treasury Metals Inc. (the proponent) needs to duly address these requests in order for the Agency to make a conclusion on the likelihood for significant adverse environmental effects.

ENVIRONMENTAL ASSESSMENT METHODOLOGY

IR-1 Reference #: EA(1)-01
Links to Annexes A3 and A4: AC(1)-151; AC(1)-10; AC(1)-41; AC(1)-42; AC(1)-61; AC(1)-63; AC(1)-64; AC(1)-68; AC(1)-70; AC(1)-71; AC(1)-138; AC(1)-141; AC(1)-145; AC(1)-150; AC(1)-152; AC(1)-153; AC(1)-154; AC(1)-155; AC(1)-158; AC(1)-168; AC(1)-185; AC(1)-187; AC(1)-191; AC(1)-195; AC(1)-196; AC(1)-213; AC(1)-233; AC(1)-276; AC(1)-278; AC(1)-280; AC(1)-289; AC(1)-290; AC(1)-291; AC(1)-292; AC(1)-293; AC(1)-314; AC(1)-331; AC(1)-347; AC(1)-198; AC(1)-282; AC(1)-343; AC(1)-143; AC(1)-146; AC(1)-360; AC(1)-367; AC(1)-368; AC(1)-369; AC(1)-381; AC(1)-406; AC(1)-410; AC(1)-427
s.5 Effect/Valued Component/EA Item: Effects Assessment Methodology; Community and Aboriginal Traditional Knowledge
Reference to EIS Guidelines: Sections 2.3, 3.4.2, 7.2.1, 7.2.2, 9.1.1, 10.2, 11.2
Reference to EIS: EIS sections 5, 6; Appendix DD
Summary of Comment/Rationale: Section 2.3 of the EIS Guidelines states: "The proponent will make reasonable efforts to integrate "traditional Aboriginal knowledge" that will contribute to the assessment of environmental impacts." Potentially affected Aboriginal groups, including Wabigoon Lake Ojibway Nation, Eagle Lake First Nation, Wabauskang First Nation, Grassy Narrows First Nation, Naotkamegwanning First Nation, and Métis Nation of Ontario, as well as the Grand Council of Treaty 3 have expressed concerns that traditional knowledge in the project area has not been collected; therefore, potential effects to the environment have not been adequately characterized in the EIS and further understanding of both land and resource use and traditional knowledge in the project area is needed. All groups have expressed willingness to participate in traditional knowledge and traditional land use studies in the project area.

Aboriginal traditional knowledge is held by the Aboriginal people who live in the area of a proposed project, and who have a long relationship with the lands and resources likely to be affected. As such, the integration of Aboriginal traditional knowledge into the environmental assessment (EA) process can serve to strengthen the EA. The proponent should review the Agency's reference guidance document "Considering Aboriginal Traditional Knowledge in Environmental Assessments Conducted under the Canadian Environmental Assessment Act, 2012" (https://www.canada.ca/en/environmental-assessment-agency/services/policy-guidance/considering-aboriginal-traditional-knowledge-environmental-assessments-conducted-under-canadian-environmental-assessment-act-2012.html). This document provides 1) principles that should be taken into consideration when collecting Aboriginal traditional knowledge from groups and 2) guidance on integrating traditional knowledge into an EA. In accordance with this guidance document, the proponent should follow existing consultation protocols. Currently, community and Aboriginal traditional knowledge has not been integrated into the effects assessment presented in section 6 (EIS). Information shared by Aboriginal groups with the Agency and the proponent prior to EIS submission is discussed in Appendix DD. In most cases, Aboriginal traditional knowledge has not been integrated into the assessment, and concerns identified in Appendix DD have not been adequately considered or addressed by the proponent. Aboriginal groups have identified that some responses provided by the proponent are not demonstrative of a respectful understanding of the cultures, views and concerns of Aboriginal groups. The guidance document includes guidance as to how the proponent should integrate Aboriginal traditional knowledge and Western knowledge. The guide states that in cases where Aboriginal traditional knowledge and Western knowledge cannot be reconciled "EA practitioners should juxtapose what is suggested by each knowledge system in their EA report and demonstrate how each type of knowledge has been considered in the EA."

Information Request:

1. Engage Aboriginal groups to collect Aboriginal traditional knowledge, including but not limited to information related to traditional land and resource use.
2. Integrate Aboriginal traditional knowledge into the baseline assessment and assessment of environmental effects, including documentation of information provided for each valued component.
3. Ensure Aboriginal traditional knowledge is discussed and considered in a respectful manner which acknowledges its inherent value. As directed by potentially affected Aboriginal groups, consider engaging in cultural awareness training and seek to follow existing consultation protocols.
4. If/where differences between Aboriginal and Western knowledge arise, include both information sources in the assessment.

IR-1 Reference #: EA(1)-02
Links to Annexes A3 and A4: AC(1)-63; AC(1)-198; AC(1)-212; AC(1)-213; AC(1)-216; AC(1)-218; AC(1)-219; AC(1)-220; AC(1)-221; AC(1)-222; AC(1)-223; AC(1)-225; AC(1)-233; AC(1)-241; AC(1)-33; AC(1)-361
s.5 Effect/Valued Component/EA Item: Effects Assessment Methodology; Potential Environmental Effects Characterization
Reference to EIS Guidelines: Section 10.1
Reference to EIS: EIS Section 6.4.1.11
Summary of Comment/Rationale: The potential effects for the valued components in section 6 (EIS) are not characterized adequately to inform the effects assessment. For example, potential effects to wildlife and wildlife habitat are described as "The primary potential effect to wildlife and wildlife habitat will result from the physical alteration or removal of existing habitat. Constructing access roads, mine infrastructure, tailing storage, pit excavation and waste rock storage areas will require disturbance or alteration of terrestrial and wetland/riparian habitats. In total, it is expected that 242 ha of wildlife habitat will be lost due to Project activities for the duration of the Project life. Habitats are expected to recover over time following Project closure." The potential effects need to be described adequately for species at risk listed in section 6.4.1.11 (EIS), ungulates, furbearers, upland birds, and wetland birds. A more adequate characterization needs to take into consideration quantitative data and include a description of the species and habitat, what types of habitat are proposed to be impacted by which project component, and any applicable references to federal or provincial regulations or guidelines. Section 10.1 (EIS Guidelines) states that "in predicting and assessing project's effects, the proponent will indicate important details and clearly state elements and functions of the environment that may be affected, specifying the location, extent and duration of these effects and their overall impact." Descriptions, including figures and maps to provide this information are important for the Agency to analyze the effects assessment.

Information Request:

1. Provide adequate characterizations of potential effects, for all valued components listed in section 6 (EIS), taking into consideration the responses to all relevant information requests from the Agency.
2. Provide detailed figures with base maps to indicate the elements and functions of the environment potentially impacted, including receptors, and to delineate the areas, locations, extent and durations of the various potential environmental effects for each project phase.

IR-1 Reference #: EA(1)-03
Links to Annexes A3 and A4: AC(1)-63; AC(1)-181; AC(1)-198; AC(1)-199; AC(1)-207; AC(1)-208; AC(1)-213; AC(1)-218; AC(1)-219; AC(1)-220; AC(1)-221; AC(1)-222; AC(1)-223; AC(1)-225; AC(1)-233; AC(1)-267; AC(1)-329; AC(1)-343; AC(1)-206
s.5 Effect/Valued Component/EA Item: Effects Assessment Methodology; Residual Effects Characterization
Reference to EIS Guidelines: Sections 7.2.1, 7.2.2, 13.1.1
Reference to EIS: EIS Section 6
Summary of Comment/Rationale: Section 6.1.3 (EIS) provides a characterization of residual effects for the Project. Publications of the Governments of Canada (http://www.ceaa-acee.gc.ca/Content/D/2/1/D213D286-2512-47F4-B9C3-08B5C01E5005/Determining_Whether_a_Project_is_Likely_to_Cause_Significant_Adverse_Environmental_Effects.pdf) and British Columbia (http://www.eao.gov.bc.ca/pdf/EAO_Valued_Components_Guideline_2013_09_09.pdf) are cited as the primary references used in developing the characterization. It is unclear how the proponent followed the methods outlined in these reference documents. Section 13.1.1 (EIS Guidelines) states: "The following elements should be used in determining the significance of residual effects: magnitude, geographic extent, timing, duration, frequency, reversibility, ecological and social context, and existence of environmental standards, guidelines or objectives for assessing the impact. In assessing significance against these criteria the EIS will, where possible, employ relevant existing regulatory documents, environmental standards, guidelines, or objectives such as prescribed maximum levels of emissions or discharges of specific hazardous agents into the environment. The EIS will contain a section which explains the assumptions, definitions and limits to the criteria mentioned above in order to maintain consistency between the effects on each VC." Section 6.1.3 (EIS) outlines magnitude as Level I (no measurable residual effect), Level II (Residual effect is measurable but within range of natural variation) and Level III (Residual effect is outside range of natural variation). Applying an across-the-board approach to defining levels of magnitude in the residual effects characterization does not allow the reader/reviewer to adequately understand the nature of the effect such that different readers/reviewers will reach the same conclusions. The definitions of magnitude will vary by VC and as such should be clearly defined on a per-VC basis. Definitions should be thorough and unambiguous to ensure that little room is left for interpretation on the part reader/reviewer. A table should be provided outlining magnitude definitions for each VC. Section 7.2.1 of the EIS Guidelines states: "The EIS will clearly indicate the spatial boundaries to be used in assessing the potential adverse environmental effects of the proposed project and provide a rationale for each boundary. It is recognized that the spatial boundaries for each VC may not be the same. Spatial boundaries will be defined taking into account as applicable the appropriate scale and spatial extent of potential environmental effects, community and Aboriginal traditional knowledge, current land and resource use by Aboriginal groups, ecological, technical and social and cultural considerations. The description of the project setting will be presented in sufficient detail to address the relevant environmental effects of the project.' Valued component (VC)-specific spatial scales are not defined or justified in the EIS. Therefore the spatial scale over which the residual effect is expected to occur is unclear for the VCs. Section 7.2.2 (EIS Guidelines) states: "The temporal boundaries of the EA will span all phases of the project: construction, operation, maintenance, foreseeable modifications, and where relevant, closure, decommissioning and restoration of the sites affected by the project. Temporal boundaries will also consider seasonal and annual variations related to VCs for all phases of the project, where appropriate. Community and Aboriginal traditional knowledge should factor into decisions around appropriate temporal boundaries. If the temporal boundaries do not span all phases of the project, the EIS will identify the boundaries used and provide a rationale." It is unclear in the EIS what the basis or reasoning is for the selection of "10-years after project initiation" as a benchmark value for the characterization of temporal scale (duration). It is also unclear how this benchmark relates to the project considering that Figure 3.2.1 (EIS, page 3-6) shows the operations phase to be 11 years and the total project length to be 18 years from construction to the end of the abandonment (post-closure) phase. A clear definition for duration levels that will provide consistency across VCs is required. For example, Level 1: Effect Not measurable beyond current project phase, Level 2: Effect could persist up to project decommissioning (closure), Level 3: Effect could persist beyond project decommissioning. In addition, for many biological VCs, the most relevant duration may be relative to the organism's lifespan. Frequency has been defined in general terms for the residual effects characterization. If terms such as infrequently, intermittently, or continuously are used then relevant temporal scales should be defined for each VC. For example, "occasionally" could be defined further as: fewer than X number of occurrences per unit time. Furthermore, in the case of recurrent disturbances, the proponent should discuss the ability of the VC to recover, whether it is partially or fully, between disturbances and how the extent of the recovery effects the level assigned in the residual effects characterization and final significance determination. Relevant temporal scales for each VC have not been defined by the proponent and the capacity of the VC to fully recover between recurrent causal disturbances has not been discussed. For reversibility, Level I is defined as "residual effect is readily reversible over a relatively short time period". A definition of relatively short should be provided. The definition should be based on a temporal scale that is relevant to the VC being assessed. In addition, Level II is defined as "Residual effect is partially reversible". The definition of partially reversible is unclear and should be quantified and discussed on a per-VC basis. Section 13.1.1 (EIS Guidelines) states "Where significant adverse effects are identified, the EIS will set out the probability (likelihood) that they will occur, and describe the degree of scientific uncertainty related to the data and methods used within the framework of its environmental analysis." The basis of how likelihood of occurrence was determined is unclear. No descriptions, definitions or data was provided. Qualitative terms such as "unlikely" or "reasonably" should be clearly defined, and probabilities should be assigned, leaving little room for interpretation by the reader/reviewer. More information is needed to understand the basis of the likelihood conclusions.

Information Request:

1. Provide definitions of each level of magnitude on a VC by VC basis. Arrange definitions in a table and include in chapter 6 of the EIS.
2. Define and justify the spatial scale (aka. geographic extent, LSA/RSA) for each VC, taking into account as applicable the appropriate scale and spatial extent of potential environmental effects, community and Aboriginal traditional knowledge, current land and resource use by Aboriginal groups, ecological, technical and social and cultural considerations.
3. Define and justify the indicators and measures of ecosystem health and integrity used for the analysis of each VC.
4. Provide a clear definition for duration levels that will provide consistency across VCs. Provide definitions on a per-VC basis where appropriate.
5. Define relevant temporal scales for each VC where frequency has been described in general terms. Assess the capacity of VCs to fully recover between recurrent causal disturbances.
6. Clearly define and quantify "relatively short period" and "partially reversible" as they relate to reversibility. Complete this on a per-VC basis where necessary.
7. Provide a clear and comprehensive basis for the determination of likelihood of occurrence. Clearly define any qualitative terms used in describing likelihood of occurrence.
8. Revise the environmental effects assessment based on the newly defined magnitude, geographic extent, duration, frequency, reversibility, and likelihood levels.

IR-1 Reference #: EA(1)-04
Links to Annexes A3 and A4: AC(1)-63; AC(1)-213; AC(1)-233
s.5 Effect/Valued Component/EA Item: Effects Assessment Methodology; Significance Determination
Reference to EIS Guidelines: Section 3.2
Reference to EIS: EIS Section 6.4, Figure 6.1.1, Tables 6.4.1 – 6.4.8
Summary of Comment/Rationale: Section 3.2 (EIS Guidelines) states: "In describing methods, the proponent will document how it used scientific, engineering, traditional and local knowledge to reach its conclusions. Assumptions will be clearly identified and justified. All data, models and studies will be documented such that the analyses are transparent and reproducible. All data collection methods will be specified. The uncertainty, reliability and sensitivity of models used to reach conclusions must be indicated." Very little information is given in the EIS regarding the methodology followed to create the decision tree presented in Figure 6.1.1 (EIS, page 6-4) or the scientific or technical suitability of the tree for use in determining the significance of residual effects. There are numerous inconsistencies in how the decision tree was applied and how effects/impact levels were described in section 6.4 (EIS), for example: Table 6.4.1 (EIS, page 6-54), under the VC Ungulates, lists magnitude level 2, geographic extent level 3, duration level 1, frequency level 3, reversibility level 2 and goes on to list significance as "not significant". Following the decision tree listed in Figure 6.4.1 (EIS) this should be considered a significant effect. Other examples include but may not be limited to: Table 6.4.1 Furbearers, Table 6.4.2, Groundwater, Fish. The effects assessment of air quality presented in section 6.4.1.5 (EIS) does not align with Table 6.4.2 (EIS, page 6-61). The table shows magnitude and geographic extent at Level 2, and frequency at Level 3 while section 6.4.1.5 (EIS) deems these all to be Level 1 in determining an overall magnitude Level 1.

Information Request:

1. Provide the procedures and rationale used to create the decision tree presented in Figure 6.1.1 (EIS, page 6-4). Provide clear explanation and justification of how different paths through the decision tree were determined to result in significant or non-significant outcomes.
2. Using the revised residual effects characterization (see EA(1)- 03), and any revisions made to the decision tree, repeat the residual effects significance determination for all VCs. Based on the revised significance determination, revise mitigation and follow-up programs as required for all VCs. Revise EIS section 6 and correct any inconsistencies between the section 6 tables and the text in the section.

IR-1 Reference #: EA(1)-05
Links to Annexes A3 and A4: AC(1)-63; AC(1)-188; AC(1)-198; AC(1)-213; AC(1)-233
s.5 Effect/Valued Component/EA Item: Effects Assessment Methodology; Mitigation
Reference to EIS Guidelines: Section 11.1.1
Reference to EIS: EIS Section 6
Summary of Comment/Rationale: Section 11.1.1 of the EIS Guidelines state: "The [environmental] impact statement will also present an assessment of the effectiveness of the proposed technically and economically feasible mitigation measures. The reasons for determining if the mitigation measure reduces the significance of an adverse effect will be made explicit." The mitigation measures identified in section 6 (EIS) are not assessed for their effectiveness, nor are reasons presented for determining if the measures reduce the significance of the potential effects.

Information Request:

1. For each proposed mitigation measure: assess and describe the effectiveness of the measure; explain the criteria used to evaluate effectiveness with respect to the implementation of the measure to address potential effects caused by the Project; and provide the rationale for determining the measure will reduce the significance of the potential effects caused by the Project.

IR-1 Reference #: EA(1)-06
Links to Annexes A3 and A4: AC(1)-20; AC(1)-63; AC(1)-213; AC(1)-233; AC(1)-390; AC(1)-431; AC(1)-432; AC(1)-437; AC(1)-439
s.5 Effect/Valued Component/EA Item: Effects Assessment Methodology; Follow-up Program
Reference to EIS Guidelines: Section 11.4
Reference to EIS: EIS Sections 12, 13, Tables 6.4.1 – 6.4.8
Summary of Comment/Rationale: Section 11.4 of the EIS Guidelines includes the following statements: "A Follow-up Program is designed to verify the accuracy of the effects assessment and to determine the effectiveness of the measures implemented to mitigate the adverse effects of the project"; "The EIS will describe the proposed Follow-up Program in sufficient detail to allow independent judgment as to the likelihood that it will deliver the type, quantity and quality of information required to reliably verify predicted effects (or absence of them), and to confirm both the assumptions and the effectiveness of mitigation"; "The Follow-up Program will include specific commitments that clearly describe how the proponent intends to implement them"; "The description of the Follow-up Program will include any contingency procedures/plans or other adaptive management provisions as a means of addressing unforeseen effects or for correcting exceedances as required to comply or to conform to benchmarks, regulatory standards or guidelines"; "The Follow-up Program will also be designed to monitor the implementation of mitigation measures resulting from Aboriginal consultation."; Tables 6.4.1 to 6.4.8 identify follow-up monitoring for certain valued components; however, the EIS does not provide sufficient detail to evaluate whether the proposed monitoring is appropriate. The objectives outlined in sections 12 and 13 of the EIS do not reflect the intent of the EIS Guidelines. These sections describe an environmental management plan and monitoring program, respectively, developed to meet anticipated regulatory permit requirements only. Neither the plan nor the program indicates the main purpose of the follow-up program, which is to verify the predictions of the environmental effects and determine the effectiveness of the mitigation measures.

Information Request:

1. Develop and describe a follow-up program to verify the accuracy of the effects assessment and to determine the effectiveness of the measures implemented to mitigate the adverse effects of the Project on all relevant valued components (VCs). For any identified VC excluded from the follow-up program, provide a rationale for the exclusion.
2. Describe the follow-up program which includes, in accordance with the EIS Guidelines: specific, achievable, measurable and verifiable commitments that clearly describe how they will be implemented; baseline data, compliance data (e.g. established benchmarks, regulatory documents, standards or guidelines), and real time data (e.g. observed data gathered in the field) incorporated in the program design and implementation; reporting methods to be used, including frequency, methods, and format; field-testable monitoring objectives that reflect the effects predictions, assumptions, and mitigation actions; a schedule indicating the frequency and duration of effects monitoring; and program elements designed to monitor the implementation of mitigation measures resulting from Aboriginal engagement and where appropriate, public concerns.

IR-1 Reference #: EA(1)-07
Links to Annexes A3 and A4: AC(1)-63; AC(1)-213; AC(1)-233; AC(1)-361; AC(1)-377; AC(1)-397; AC(1)-398; AC(1)-399; AC(1)-413; AC(1)-417
s.5 Effect/Valued Component/EA Item: Monitoring Program and Environmental Management Plans
Reference to EIS Guidelines: Section 11.1, 16;
Reference to EIS: EIS Sections 6.4.1.4, 6.4.1.7, 6.4.1.11, 6.4.1.12, 12, 13
Summary of Comment/Rationale: An Environmental Management Plan (EMP) is referred to throughout the EIS as a mitigation measure for impacts to several valued components. The EIS also refers to section 12 for the EMP; however, section 12 describes the monitoring plan for the valued components. Details of measures contained in an EMP will assist the Agency in better understanding how the environmental effects are proposed to be mitigated.

Information Request:

1. Describe the general content of an EMP to ensure that proper measures and controls will be in place in order to decrease the potential for effects on air quality, surface water quality, Aboriginal peoples, wildlife and wildlife habitat, and fish and fish habitat.

IR-1 Reference #: EA(1)-08
Links to Annexes A3 and A4: AC(1)-33; AC(1)-63; AC(1)-213; AC(1)-233
s.5 Effect/Valued Component/EA Item: Section 5(2) Effects
Reference to EIS Guidelines: Section 10.1.2, 10.1.3
Reference to EIS: EIS Section 6.4.3.3
Summary of Comment/Rationale: Section 6.4.3.3 (EIS) does not describe the changes to the environment linked or necessarily incidental to the provision of an authorization for the serious harm to fish by Fisheries and Oceans Canada, an approval for the deposit of deleterious substance in a fish frequented waterbody by Environment Canada and a licence for the explosives manufacturing and storage facilities by Natural Resources Canada. Based on section 10.1.2 of the EIS Guidelines, "the proponent shall describe any; change that may be caused by the project on the environment, which is defined as; the components of the Earth, including: − Land, water and air, including all layers of the atmosphere; − All organic and inorganic matter and living organisms; and − The interacting natural systems that include the components described above. These descriptions will be integrated into the effects assessment sections of each VC included in the EIS". Section 10.1.3 of the EIS Guidelines also state that the proponent shall describe the effects of these changes on health and socio-economic conditions, physical and cultural heritage, or any structure, site or thing that is of historical, archaeological, paleontological or architectural significance, other than as they pertain to Aboriginal peoples.

Information Request:

1. Where matters may fall within the scope of subsection 5(2) of CEAA 2012, i.e. effects in relation to a federal authority's exercise of a power or performance of a duty or function, describe in a stand-alone section the effects to additional receptors, not just air quality, surface water quality, Aboriginal peoples, wildlife and wildlife habitat, and fish and fish habitat, and identify mitigation measures, the significance of residual effects, and any follow-up monitoring that may be required. Additional receptors can include, but is not limited to: a. Furbearers and their habitat, b. Amphibians and their habitat, c. Reptiles and their habitat, d. Ungulates and their habitat, e. Species at risk and their habitat, f. Water quality and quantity, g. Non-migratory birds and their habitat, h. Riparian vegetation, i. Non-Aboriginal people; j. Air quality;
2. Provide a map that shows the ecosystem habitats (e.g. riparian zones, waterbodies, wetlands) within the geographic areas that may fall within the scope of subsection 5(2) of CEAA 2012.
3. Provide the sizes of the geographic areas and habitats that may fall within the scope of subsection 5(2) of CEAA 2012 in hectares.

IR-1 Reference #: EA(1)-09
Links to Annexes A3 and A4: AC(1)-63; AC(1)-213; AC(1)-233; AC(1)-265
s.5 Effect/Valued Component/EA Item: Proponent Commitments
Reference to EIS Guidelines: Section 11.5
Reference to EIS: EIS Section 9; Table 9.0.1
Summary of Comment/Rationale: Section 11.5 of the EIS Guidelines states: "Proponent commitments identified in the EIS should include environmental mitigation measures to address public and Aboriginal people's concerns and Follow-up Program elements". The guidelines also state: "Each commitment will be specific, achievable, measurable and verifiable, and described in a manner that avoids ambiguity in intent, interpretation, and implementation." The commitments listed in Table 9.0.1 (EIS, pages 9-1 to 9-7) do not have sufficient detail to comply with the EIS Guidelines and to permit the Agency to evaluate the effectiveness of mitigation measures and the follow-up program in addressing environmental effects or uncertainty. Details for each commitment should include, but not be limited to, description of the mitigation measure or follow-up program element, where the measure or element will be applied, what phase(s) of the project life the measure or element will be applied, and which organizations will be involved. The proponent should consider SMART (specific, measurable, attainable, relevant, time-bound) measures to guide the development of the commitments. Also, the commitments should indicate to whom the commitments are made. Also, section 9.0 (EIS) states: "Treasury has made a series of the key commitments as identified in the EIS report in accordance to the Federal EIS Guidelines (Table 9.0.1). Reference numbers have been attached to commitments as they appear in the report. Regulatory and legislative requirements have been identified where applicable." Table 9.0.1 (EIS, pages 9-1 to 9-7) does not include reference numbers.

Information Request:

1. Update Table 9.0.1 of the EIS with descriptions of the mitigation measures and follow-up program elements, where the measures and elements will be applied, what phase(s) of the project life the measures and elements will be applied, and which organizations will be involved. Provide details on these commitments that reflect the SMART approach, avoid ambiguity, and indicate to whom the commitments are made.
2. Update Table 9.0.1 with additional mitigation measures and follow-up program measures or elements in response to comments from government, public and Aboriginal peoples. Provide details on these commitments that reflect the SMART approach, avoid ambiguity, and indicate to whom the commitments are made.
3. For each commitment in Table 9.0.1, provide the reference numbers.

ABORIGINAL AND PUBLIC ENGAGEMENT

IR-1 Reference #: AC(1)-01
Links to Annexes A3 and A4: AC(1)-151; AC(1)-194; AC(1)-266; PC(1)-23; PC(1)-79; AC(1)-40; AC(1)-41; AC(1)-61; AC(1)-63; AC(1)-66; AC(1)-67; AC(1)-68; AC(1)-69; AC(1)-71; AC(1)-82 ; AC(1)-88; AC(1)-89; AC(1)-91; AC(1)-97; AC(1)-100; AC(1)-101; AC(1)-102; AC(1)-103; AC(1)-106; AC(1)-108; AC(1)-117b; AC(1)-119; AC(1)-122; AC(1)-125; AC(1)-138; AC(1)-141; AC(1)-143; AC(1)-146; AC(1)-146; AC(1)-150; AC(1)-152; AC(1)-153; AC(1)-154; AC(1)-155; AC(1)-158; AC(1)-159; AC(1)-162; AC(1)-170; AC(1)-176; AC(1)-179; AC(1)-180; AC(1)-182; AC(1)-183; AC(1)-184; AC(1)-186; AC(1)-196; AC(1)-199; AC(1)-232; AC(1)-235; AC(1)-236; AC(1)-238; AC(1)-245; AC(1)-246; AC(1)-247; AC(1)-249; AC(1)-250; AC(1)-252; AC(1)-253; AC(1)-275; AC(1)-279; AC(1)-280; AC(1)-282; AC(1)-290; AC(1)-291; AC(1)-292; AC(1)-293; AC(1)-315; AC(1)-316; AC(1)-329; AC(1)-330; AC(1)-334; AC(1)-335; AC(1)-339; AC(1)-343; AC(1)-346; AC(1)-347; AC(1)-356; AC(1)-357; AC(1)-62; AC(1)-172; AC(1)-289; AC(1)-359; AC(1)-360; AC(1)-381
s.5 Effect/Valued Component/EA Item: Aboriginal Engagement
Reference to EIS Guidelines: Sections 2.3, 3.3, 7.1.1, 7.2.19.2, 10.2, 11.2
Reference to EIS: EIS Section 8; Appendix DD
Summary of Comment/Rationale: The EIS guidelines detail Aboriginal engagement requirements for the proponent in relation to specific components of the EIS, including the identification of valued components, impacts from the Project on Aboriginal and Treaty rights, and proposed mitigation or accommodation measures. The EIS does not clearly identify or document how the Aboriginal engagement requirements described in the EIS Guidelines are met. Further, while a detailed log of proponent efforts is provided in Appendix DD, it is not clear how the efforts align with the environmental assessment (EA) milestones, what information related to the EA was shared for engagement, and when the information was shared. In Appendix DD, the responses to specific concerns are not substantiated by information in the EIS, nor is it clear how comments have been incorporated into EIS or the project design. For example, a key concern from Eagle Lake First Nation was the effect of the project on Lola Lake Nature Reserve (table in section DD.7.9, Appendix DD, page 119). The proponent response states: "Lola Lake Nature Reserve is located 2 km. to the northeast of the project site and upstream from the project site. The area between the project site and Lola Lake Nature Reserve will not be developed as part of the Project. As such, the project is expected to have no impact on the Lola Lake reserve area." This conclusion is not substantiated by any scientific or technical information. Further, the response includes a reference to Appendix J, which is the air quality study, without rationale for the reference.

Information Request:

1. Provide a summary of the information presented, including a reference list and sample of the materials used and distributed at Aboriginal engagement events, as well as meeting notes, and written comments provided by participants, to demonstrate how each potentially affected group was engaged on each of the following topics: baseline conditions, including potential or established Aboriginal and Treaty rights that may be affected by the Project; alternatives assessment; project components and related activities; effects assessment, including valued components, spatial and temporal boundaries for the assessment, and adverse impacts to potential or established Aboriginal and Treaty rights; mitigation measures, including Aboriginal accommodation measures to address impacts on Aboriginal and Treaty rights; residual effects, including identification of outstanding Aboriginal issues; and the follow-up monitoring program.
2. Provide a table with a summary of Aboriginal concerns by valued component, the proponent responses (including the extent to which this information was incorporated in the design of the Project as well as in the EIS, and the resultant changes), references to specific sections of the EIS and/or appendices that detail how the concerns has been addressed, and the proponent's commitments to address concerns.
3. Demonstrate how Aboriginal groups were provided access to timely and relevant information required to identify impacts to Aboriginal and Treaty rights.
4. Align engagement activities with each of the EA milestones, and provide a record of information presented. Information provided need to demonstrate that the proponent held and facilitated meetings by making key EA summary documents (baseline studies, EIS and key findings) available, including plain language summaries.
5. Demonstrate that the engagement requirements were met during the development of the EIS. Where requirements were not met, conduct additional Aboriginal engagement activities in consultation with the Agency. Any concerns or information gathered from additional engagement activities will need to be documented and included in the table requested in item B above. The proponent must also describe how the additional information was incorporated into the effects assessment.

IR-1 Reference #: AC(1)-02
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Aboriginal and Public Participation
Reference to EIS Guidelines: Sections 12.2, 12.3
Reference to EIS: EIS Section 8.9.3
Summary of Comment/Rationale: Outstanding public and Aboriginal concerns are discussed in section 8.9.3 (EIS). This text is limited to concerns related to water quality and impacts to an individual home owner nearby the site. Comments received during Agency consultation on the EIS indicate that this discussion is not complete. There is no discussion of outstanding potential adverse impacts to Aboriginal and Treaty rights that may result from residual and cumulative environmental effects in section 8.9.3 (EIS). This information is needed by the Crown for consideration as it assesses the adequacy of consultation and accommodation.

Information Request:

1. Describe the potential adverse impacts on potential or established Aboriginal and treaty rights and related interests that have not been fully mitigated as part of the environmental assessment and associated engagement with Aboriginal groups;
2. Describe outstanding public concerns related to potential environmental effects as described in section 5 of CEAA 2012 that have not been resolved as a result of changes to the project, mitigation measures, or public participation activities.

IR-1 Reference #: AC(1)-03
Links to Annexes A3 and A4: AC(1)-148; AC(1)-157; AC(1)-158
s.5 Effect/Valued Component/EA Item: Aboriginal and Public Participation
Reference to EIS Guidelines: Sections 5, 9, 11
Reference to EIS: Appendix C of Appendix S
Summary of Comment/Rationale: Aboriginal engagement activities to identify species at risk (SAR) in the project area or define the spatial boundaries for SAR have not been conducted. The proponent received no responses from any of the First Nations contacted through information requests in regard to wetland evaluations (Appendix C of Appendix S). As such, the proponent should consider devising an alternative approach to engaging Aboriginal communities and groups. Section 9.1.2 of the EIS Guidelines states the proponent should seek advice from Aboriginal groups and First Nations on SAR and species of conservation concern.

Information Request:

1. Engage Aboriginal groups and First Nations to define the spatial boundaries for SAR and acquire information needed to discern SAR location and prevalence in the local and regional study areas.
2. Provide documentation of engagement results by Aboriginal group.
3. Revise the baseline and effects assessment based on engagement results, including the identification of additional mitigation measures where needed.

IR-1 Reference #: PC(1)- 01
Links to Annexes A3 and A4: PC(1)-82; PC(1)-83; PC(1)-85; PC(1)-87; AC(1)-251
s.5 Effect/Valued Component/EA Item: Public Participation
Reference to EIS Guidelines: Sections 2.2, 3.3, 4, 5.7, 7.1.1, 7.2.1, 10.3, 11.3, 11.4, 11.5, 12.3, 14, 16, Figure 1
Reference to EIS: EIS Sections 8, 8.6, 8.8, 8.8.1; Appendix V
Summary of Comment/Rationale: Section 8.6 (EIS) and Appendix V note the locations, persons, and organizations engaged in relation to public participation. Appendix V shows that the proponent presented and provided information on the project description and economic opportunities; however, it is not apparent whether the proponent engaged the public on the effects assessment, including the valued components and the spatial boundaries. The methods of public engagement and their relevance are also not clear. For greater clarity, the proponent needs to provide the materials used and distributed at the public meetings. Section 8.8.1 (EIS) states: "the detail as to how public concerns are to be addressed is included throughout the EIS". With only a short summary of the measures to address key issues presented in section 8.8.1, it is difficult to know if the public concerns have been fully addressed in the EIS. Some of the responses to the public concerns also contradict the information presented in the EIS. For example, the proponent states that no adverse impacts to fish habitat or fishing opportunities are anticipated but Appendix II indicates that the project infrastructure will overprint fish habitat in Blackwater Creek. Section 11.3 of the EIS Guidelines states: "the EIS will provide a summary of discussions; indicate the methods used and their relevance, locations, the persons and organizations consulted, the concerns raised, the extent to which this information was incorporated in the design of the project as well as in the EIS, and the resultant changes. The proponent will also provide a description of efforts made to distribute project information and provide a description of information and materials that were distributed during the consultation process."

Information Request:

1. Provide a summary of the information presented, including a reference list and sample of the materials used and distributed at the public meetings held by the proponent, to demonstrate that the public was engaged on each of the following topics: 1. Baseline conditions; 2. Effects assessment, including: a. Valued components; and; b. Spatial and temporal boundaries for the assessment; 3. Mitigation measures; 4.Residual effects.
2. Provide a table with a summary of public concerns by valued component, the proponent responses (including the extent to which this information was incorporated in the design of the Project as well as in the EIS, and the resultant changes), references to specific sections of the EIS and/or appendices that detail how the concerns has been addressed, and the proponent's commitments to address concerns.
3. Where the proponent cannot demonstrate that the above engagement occurred during the development of the EIS, additional engagement activities need to be implemented by the proponent in consultation with the Agency, prior to providing a response to this IR. Any concerns or information gathered from additional engagement activities will need to be documented and included in the table requested in request B above. The proponent also must describe how the additional information was incorporated into the effects assessment.

PROJECT DESCRIPTION

IR-1 Reference #: PD(1)-01
Links to Annexes A3 and A4: AC(1)-375; AC(1)-386; AC(1)-396; AC(1)-420; AC(1)-426
s.5 Effect/Valued Component/EA Item: Project Description
Reference to EIS Guidelines: Section 5.7
Reference to EIS: EIS Sections 1.4.1, 3.2.1, 3.3.2; EIS Summary ; Section 5.2
Summary of Comment/Rationale: Section 1.4.1 (EIS) does not list dewatering ponds and wetlands as a project activity for the site preparation phase while sections 5.2 (EIS Summary) and 3.2.1 (EIS) indicate that site preparations include dewatering ponds and wetlands within footprint of the proposed mine infrastructure and constructing water realignment channels and ditches. In addition, section 3.3.2 (EIS) notes that there are no permanent ponds or lakes that require dewatering. It is not clear whether dewatering of ponds and wetlands will take place during site preparation and if this activity will take place, which ponds and wetlands will be dewatered. Site preparation should be scheduled to minimize potential disturbance of wildlife. This should also include aquatic life (spawning periods for dewatering activities).

Information Request:

1. Clarify whether or not the site preparations activities include dewatering of ponds and wetlands. If so, identify and describe the wetlands and ponds to be dewatered.
2. Clarify whether or not site preparation will be scheduled to minimize potential effects to fish and fish habitat.
3. In relation to subsection 5(2) of CEAA 2012, should any of the ponds or wetlands be subject to the federal authority's exercise of a power or performance of a duty or function, name and map the location of the water-bodies in question, describe any other potential environmental effects of dewatering activities to ponds and wetlands, identify mitigation measures, the significance of residual effects, and any follow-up monitoring that maybe required.

IR-1 Reference #: PD(1)-02
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Project Description
Reference to EIS Guidelines: Sections 4, 5.6, 5.7
Reference to EIS: EIS, Section 3.1, Figure 3.1.2
Summary of Comment/Rationale: Section 3.1 (EIS) describes the proposed use of the existing facilities, including the tree nursery ponds and the existing structures at the former tree nursery. However, there is no description of the infrastructure required to take water from the tree nursery ponds for mine operations. It is also not clear whether additional work on the tree nursery pond dams, irrigation ponds, or at the former tree nursery is proposed.

Information Request:

1. Describe the use of the existing facilities/infrastructure required to pump water from the irrigation ponds along the tributary of Thunder Creek. Include a map with its location.
2. Clarify whether additional infrastructure or works are planned at the Tree Nursery site. If so, describe the environmental effects, mitigation measures, and follow-up measures that are linked to these activities.

IR-1 Reference #: PD(1)-03
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Project Description
Reference to EIS Guidelines: Section 5.5
Reference to EIS: Appendix II, Section 3.0
Summary of Comment/Rationale: Section 3.0 (Appendix II) indicates that habitat modifications will result from channel realignment and culvert replacement. However, it is not clear where the culvert replacement will take place.

Information Request:

1. Provide a map of all water crossings and culvert replacements associated with the Project.
2. Describe the culvert replacement and how it will be designed to avoid impacts to fish and fish habitat including fish passage. If the proponent believes that it is not necessary to ensure fish passage, provide a justification.

IR-1 Reference #: PD(1)-04
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Project Description
Reference to EIS Guidelines: Sections 5.7, 7.1.1
Reference to EIS: EIS Section 3.6.1; Appendix D
Summary of Comment/Rationale: Appendix D does not address the proposal to redirect the Tree Nursery Road (a public local roads board road). Section 3.6.1 states that "The process plant site will be located to the east of the mining pits, and just east of the Tree Nursery Road (Figure 3.6.3). The road will be diverted to the east side of the process plant. The plant security gate and car park access will be from this new section of Tree Nursery Road. The process plant and ancillary buildings will be located outside a 500 m radius blast zone from the edge of the open pit and on property owned by Treasury. The crushing facility will have a tentative clearance of 300 m from the edge of the pit. Aerial view of proposed processing plant can be seen in Figure 3.6.1".

Information Request:

1. Clarify and provide the plans for realignment/redirecting of Tree Nursery Road. Include a map of the realigned corridor.
2. Describe the environmental effects (including impacts to Aboriginal peoples), mitigation measures, and follow-up measures for the activities related to redirecting the Tree Nursery Road.

IR-1 Reference #: PD(1)-05
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Project Description
Reference to EIS Guidelines: Section 5.6
Reference to EIS: EIS Figures 3.5.1, 3.5.2
Summary of Comment/Rationale: Figures 3.5.1 and 3.5.2 (EIS, pages 3-14 and 3-15) show the property boundary immediately adjacent to the overburden stockpile, the waste rock stockpile, and the pit. It appears that the property boundary has been extended in these areas, but it cannot be confirmed.

Information Request:

1. Confirm whether the property boundary has been extended away from the main mine facilities and is not as depicted in Figures 3.5.1 and 3.5.2. If the figures are inaccurate, provide revised figures that accurately reflect the layout, locations, and scale of the project components.

IR-1 Reference #: PD(1)-06
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Project Description; Surface Water Quality
Reference to EIS Guidelines: Section 5.6
Reference to EIS: Appendix F, Section 2.1.4
Summary of Comment/Rationale: Section 2.1.4 of Appendix F states: "When the tailings storage facility reaches the design overflow point, it will overflow and discharge effluent." It is unclear whether this means the overflow effluent will be discharged to the water treatment facility and NOT directly to the environment.

Information Request:

1. Explain to where the overflow effluent from the tailings storage facility (TSF) will discharge. Include a figure to depict the flow path, water management system, effluent transfer locations into and out of the TSF, and the receiving environment of the overflow effluent.
2. If the effluent overflow does not go to the water treatment facility, describe the contingency measures that will be put in place to ensure there are no impacts to the environment from the effluent overflow discharge.

ALTERNATIVES ASSESSMENT

IR-1 Reference #: AA(1)-01
Links to Annexes A3 and A4: PC(1)-68; AC(1)-51; AC(1)-296
s.5 Effect/Valued Component/EA Item: Alternatives Assessment; Mine Waste Management
Reference to EIS Guidelines: Section 8.1
Reference to EIS: EIS Section 2; Appendix D Section 4.6.1; Appendix O Figure 2-2
Summary of Comment/Rationale: Section 4.6.1 (Appendix D, page 24) states that the proponent assumes a natural clay basin will contain the tailings storage facility in the long term. However, it is noted that much of the onsite clays are interlayered with silt layers. Figure 2-2 (Appendix O) also shows that the surficial geology of the proposed footprint of the tailings storage facility consists of clay and sandy loam. Due to the uncertainty of its technical feasibility, the proponent needs to provide evidence and a clear rationale that the underlying clay basin is present and suitable for use in long term tailings storage. It is not clear whether the clay material found on the project site will be segregated from other overburden during stripping and stockpiling for capping the tailings in the tailings storage facility. The environmental effects of obtaining suitable clays from other parts of the project site or offsite locations need to be considered. The proponent also needs to provide a clear rationale that it is economically feasible, and that supply exists, to source any additional required clay from outside vendors. An alternative tailings storage facility that does not depend on clay as an underlying layer and for building a cap should also be provided.

Information Request:

1. Provide evidence and a clear rationale to support the current assumption that the natural clay basin underlying the tailings storage facility (TSF) is sufficient for long term storage purposes.
2. Discuss how onsite clays will be segregated from other materials, if applicable.
3. Explain the environmental effects of obtaining the required quantities of suitable clay material from the project footprint and offsite locations to build the TSF embankments; cap the TSF tailings, the backfilled west and central pits; and cap the waste rock stockpile area.
4. Discuss the economic feasibility and supply options for sourcing sufficient amounts of suitable clay material from offsite locations.
5. As part of the alternatives assessment, describe at least one long term tailings storage facility alternative that is not reliant on clay. Evaluate the feasibility of using a synthetic liner.

IR-1 Reference #: AA(1)-02
Links to Annexes A3 and A4: AC(1)-104; AC(1)-122; AC(1)-123; AC(1)-128; AC(1)-131
s.5 Effect/Valued Component/EA Item: Alternatives Assessment; Aboriginal and Treaty Rights and Related Interests
Reference to EIS Guidelines: Section 8
Reference to EIS: EIS Section 2
Summary of Comment/Rationale: Section 2 (EIS) does not assess the potential adverse impacts on potential or established Aboriginal and Treaty rights and related interests from each alternative means in a manner that incorporates input from Aboriginal groups. Section 8 of the EIS Guidelines state that the EIS will identify and consider the effects of each alternative means, including "both environmental effects and potential adverse impacts on potential or established Aboriginal and Treaty rights and related interests".

Information Request:

1. Assess the potential adverse impacts on potential or established Aboriginal and Treaty rights and related interests from each alternative means.
2. Revise the quantitative analysis to include a weighting factor based on input from Aboriginal groups.

IR-1 Reference #: AA(1)-03
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Alternatives Assessment; Human Environment; Project Description
Reference to EIS Guidelines: Section 8
Reference to EIS: EIS Table 1.5.1, Section 2
Summary of Comment/Rationale: Table 1.5.1 (EIS, page 1-20) shows that the proponent has applied for a Notice of Camp Opening permit with the Regional Health Unit while Section 2 (EIS) suggests that employees will be responsible for their own housing off-site. The proponent must clarify if they will be constructing and owning employee accommodations either on or off the project site for the purposes of the Project.

Information Request:

1. Clearly indicate whether on and/or off-site employee accommodations will be constructed or provided.
2. Describe the alternatives means for on and/or off-site employee accommodations, the preferred alternative and assess the environmental effects and potential impacts on potential or established Aboriginal and Treaty rights and related interests from each alternative means.
3. Provide a map showing the locations of on and/or off-site employee accommodations alternatives.

IR-1 Reference #: AA(1)-04
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Alternatives Assessment; Mine Waste Management
Reference to EIS Guidelines: Section 8
Reference to EIS: EIS Section 2; Appendix D Section 4.4, Figure 4.1
Summary of Comment/Rationale: The co-disposal option (tailings in the tailings storage facility and open pit) was only considered for tailings storage facility location #1 because it was determined that its location was optimal due to "proximity to open pit and underground operations while minimizing travel distance and environmental harm" (Appendix D, Section 4.4). It appears that potential locations 4 and 6 are as close or closer to the open pit (Appendix D, Figure 4.1).

Information Request:

1. Explain why tailings storage facility optional locations 4 and 6 were not considered for co-disposal.

IR-1 Reference #: AA(1)-05
Links to Annexes A3 and A4: AC(1)-129
s.5 Effect/Valued Component/EA Item: Alternatives Assessment; Project Description
Reference to EIS Guidelines: Sections 5.6, 8
Reference to EIS: EIS Sections 2, 3.1.2
Summary of Comment/Rationale: Section 2 (EIS) does not assess alternative energy sources for the Project. Section 3.1.2 (EIS) does not describe the energy infrastructure, including power supply and scheduling details. The EIS Guidelines (Section 5.6) require this information.

Information Request:

1. Identify and assess alternative energy sources for the project.
2. Describe the anticipated power demand, routing and location of related infrastructure.
3. Identify the power supplier and the builder, owner, controller, and operator of the energy infrastructure.

IR-1 Reference #: AA(1)-06
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Alternatives Assessment; Mine Waste Management
Reference to EIS Guidelines: Section 8
Reference to EIS: EIS Sections 2.3.2.1, 2.4.4, Figure 3.8.4
Summary of Comment/Rationale: A number of water management ponds/facilities are referred to in Sections 2 and 3 (EIS) that are not clearly labelled on site maps. Some examples include: Figure 3.8.4 (EIS, page 3-54) does not show minewater collections sumps directing water to the waste rock pond. There is no "water management pond" or "mine rock pond" shown in any figure despite a reference to it in Section 2.3.2.1 (EIS): "Under an integrated approach, minewater will be pumped from the minewater collection sump(s) in the open pit and underground mine to the mine rock pond. Water from the mine rock including the integrated minewater will be used for processing. Excess water in the mine rock pond not needed for processing will be transferred to either the water management pond or tailings management area pond." The following statement, from Section 2.3.2.1 (EIS), is quite vague: "The integrated site water management system requires a number of large ponds to ensure adequate water availability for processing at all times and does not require any modification to contain and treat minewater." Section 2.4.4 (EIS) lists a tailings storage facility reclaim pond in addition to a tailings storage facility seepage collection pond. The reclaim pond is not shown/ labelled on related maps, e.g. Figure 3.8.4 (EIS, page 3-54). Section 3.6.2.1 (EIS Report, pg. 3-19) indicates that during the start-up of the plant, and initial first fill a quantity of water will be taken from the "contact water sediment ponds". These ponds are not identified in any of the figures. Figure 3.8.3 (EIS Report, pg. 3-49) shows a "Raw Water Reservoir" which is not shown in other figures. Figure 3.8.4 (EIS Report, pg. 3-54) shows a "Polishing Pond" and a "Collection Pond" south of the Tailings Storage Facility. However, Figure 3.0.1 (EIS Report, pg. 3-2) shows only one pond, that is, "Polishing Pond/Seepage Collection". Figure 3.11.1 (EIS Report, pg. 3-57) shows a created water structure which is on the Blackwater Creek and no description is provided regarding this structure. Section 7.1 (Appendix F, pg. 30) mentions secondary waste rock contact water collection ponds and ditches, but these ponds and ditches are not shown on any figure.

Information Request:

1. Provide a figure that clearly shows all proposed ponds and water management areas.
2. Revise all figures showing ponds/water management areas in the EIS, as outlined in part A of this IR.
3. Provide references to relevant figures (maps) in the EIS when discussing ponds/water management.
4. Provide a description of the function of each pond, along with their capacity and retention time.

IR-1 Reference #: AA(1)-07
Links to Annexes A3 and A4: AC(1)-133; AC(1)-50
s.5 Effect/Valued Component/EA Item: Alternatives Assessment;
Reference to EIS Guidelines: Section 8
Reference to EIS: EIS Section 2.3.3
Summary of Comment/Rationale: Section 2.3.3 (EIS, pp. 2-13, 2-14) discusses alternative locations for the waste rock storage area. Alternative locations are not discussed for overburden or the low grade ore stockpile.

Information Request:

1. Provide an assessment of alternative locations for the overburden and low grade ore stockpiles.

IR-1 Reference #: AA(1)-08
Links to Annexes A3 and A4: AC(1)-303; AC(1)-24
s.5 Effect/Valued Component/EA Item: Alternatives Assessment; Mine Water Management; Surface Water; Wetlands
Reference to EIS Guidelines: Section 8
Reference to EIS: EIS Section 2.3.7.1, Figure 2.3.10; Appendix M
Summary of Comment/Rationale: Section 2.3.7.1 (EIS, p. 2-31) discusses creeks near the project site and their ability to supply needed fresh water for mine processing: "The results of the flow gauging studies conducted are presented in Table 2.3.10 (p. 31) along with the maximum allowable water take, which is calculated as 10% of the flow of the creek.There are two ponds on the proposed project site, referred to as the tree nursery ponds. These dug ponds were used for irrigation during the historical operation of a tree nursery and are situated on the creek referred to as Thunder Lake Tributary 3 in the hydrogeology report (Appendix M). This creek was gauged and the results reported for measurements taken during 2013 indicate sufficient flow to meet the process plant requirements. To meet the processing plant requirements, taking 26% of the flow of Thunder Lake Tributary #3 would be required"; Given that the maximum allowable take is set at 10%, and 26% of the flow of Thunder Lake Tributary #3 would be required for mine processing operations, it is not clear whether the proponent intends to source the extra water from additional sources or whether a 26% take is viewed as sustainable.

Information Request:

1. Clarify the amount of water that will be required during construction, operation, decommissioning and abandonment phases in cubic meters/day for each water source, including the irrigation ponds (Thunder Lake Tributary #3) and any additional sources.

IR-1 Reference #: AA(1)-09
Links to Annexes A3 and A4: AC(1)-125
s.5 Effect/Valued Component/EA Item: Alternatives Assessment; Human Environment
Reference to EIS Guidelines: Section 8
Reference to EIS: EIS Section 2.3.8.6
Summary of Comment/Rationale: While discussing alternative locations for water (effluent) discharge in Section 2.3.8 (EIS) the proponent does not identify potential spawning locations as a factor in selecting the preferred alternative (Blackwater Creek). The proponent also states in Section 2.3.8.6 (EIS, p. 2-33): "The potential risk to permitting is reduced due to no residents living directly along the creek" in reference to Blackwater Creek. The risk to permitting is not a valid consideration in assessing alternatives from an environmental impact perspective. In addition, the Agency visited the project site during the week of May 4-8, 2015 and noted that there are residents living in very close proximity to Blackwater Creek (e.g. The property on the west side of Tree Nursery Rd. just north of Anderson Road). Under Section 2.3.8.6 (EIS) the proponent states that locating the water discharge along Blackwater creek provides ".the ability for Treasury to quantify its impact on the environment." This statement is unclear because it implies that quantification is not possible at other locations.

Information Request:

1. Revise the evaluation of the preferred alternative for water discharge location to consider fish spawning habitat.
2. Identify and assess impacts to residents living in close proximity to Blackwater Creek and add these residents to related maps.
3. Clarify the reasoning behind the selection of the preferred alternative for water discharge.

IR-1 Reference #: AA(1)-10
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Alternatives Assessment
Reference to EIS Guidelines: Sections 5.2, 8
Reference to EIS: EIS Summary Figure 4.2; EIS Sections 2.3.15.1, 3.13.1; Table 1.5.1
Summary of Comment/Rationale: Figure 4.2 (EIS Summary) indicates that the explosive storage facility is currently located on provincial Crown lands. This location overlaps with forest research value–breeding and genetic tree orchards that have been established since the 1980's along the Nursery Road, have significant value to Dryden's local forest industry, and have also been used by Lakehead University. Section 5.2 of the EIS Guidelines requires the proponent to identify all environmental and other specific regulatory approvals and legislation that are applicable to the Project at the federal, provincial, regional and municipal levels. (Note: If the intent is to locate the explosives storage facility on Crown land, then a provincial permit will be required.) Sections 2.3.15.1 and 3.13.1 (EIS) state that, in addition to the preferred location, one alternative location has been identified. Descriptions of the two locations in the EIS are brief and no reference(s) to appendices containing descriptions of the locations or reasoning behind the selection of the preferred alternative are provided.

Information Request:

1. Evaluate and describe alternative locations and the associated environmental effects of each for the explosives storage facility. Provide a reference to this discussion in the EIS.
2. Provide a map and update existing maps, as required, to show alternative locations for the explosives storage facility.

IR-1 Reference #: AA(1)-11
Links to Annexes A3 and A4: AC(1)-133; AC(1)-373
s.5 Effect/Valued Component/EA Item: Alternatives Assessment; Mine Waste
Reference to EIS Guidelines: Sections 8.1, 10.1
Reference to EIS: Appendix D; EIS Section 2
Summary of Comment/Rationale: Mine waste disposal alternatives have not been thoroughly characterized from a technical, environmental and socio-economic perspective in the Alternatives Assessment Report (Appendix D). Following the pre-screening step, all mine waste disposal alternatives need to be thoroughly characterized. Complete characterization of each alternative ensures that every aspect and nuance of the alternative is properly considered. Furthermore, the provision of a thorough characterization in a clear and concise format that directly compares alternatives ensures complete transparency of the alternatives assessment process. Some examples of additional characterization criteria, which could be provided for each alternative following pre-screening, are provided below for the consideration by the proponent: Technical Characterization; Number of starter dams; Tailings Impoundment Area (TIA) volume; TIA footprint; Closure design; Water management system design (including water treatment system, seepage and run-off collection, etc.); Design and construction of impermeable covers over wastes; Technical risks; Environmental Characterization; Downstream water quality; Impacts to groundwater; Size of watersheds affected; Number of fish species affected within a TIA footprint; Loss of wetlands; Presence of fish species at risk; Presence of non-fish aquatic species at risk; Presence of terrestrial species at risk; Presence of plant species at risk; Impacts of changes to freshets; Socio-economic Characterization; Local Aboriginal community response; Regional community response; Aboriginal values and traditional use effects. These and other relevant characterization criteria can be used to introduce additional sub-accounts and indicators into the alternatives assessment. The proponent is referred to section 2.4 and Tables 3 to 6 of Environment Canada's guidelines for additional information on characterization of alternatives: http://ec.gc.ca/pollution/default.asp?lang=En&n=125349F7-1

Information Request:

1. Document the assessment of alternatives for mine waste disposal. Rationalize the preferred alternative and document the alternatives assessment process, including engagement of Aboriginal communities as applicable, (e.g., the inclusion of additional characterization criteria in the Alternatives Assessment (AA) Report, or the provision of a rationale as to why certain characterization criteria have not been included in the AA report).

IR-1 Reference #: AA(1)-12
Links to Annexes A3 and A4: PC(1)-72
s.5 Effect/Valued Component/EA Item: Alternatives Assessment; Mine Waste
Reference to EIS Guidelines: Section 8.1
Reference to EIS: Appendix D; EIS Section
Summary of Comment/Rationale: According to the Alternatives Assessment (AA) Report (Appendix D), alternative 1D (co-disposal of waste rock and tailings in a single facility) has been selected as the preferred disposal alternative. It is not clear in the AA Report where waste rock would be disposed of should an alternative other than 1D be the preferred alternative.

Information Request:

1. Clarify additional options for waste rock disposal if alternative 1D cannot be pursued.

IR-1 Reference #: AA(1)-13
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Alternatives Assessment
Reference to EIS Guidelines: Section 8.1
Reference to EIS: Appendix D, Tables 4.4, 4.5; EIS Section 2
Summary of Comment/Rationale: Table 4.4 (Appendix D) lists the quantity for each candidate alternative, either numeric or descriptive, associated with each indicator under the four accounts of the Alternatives Assessment Report. Then indicators are scored based on the quantity listed in Table 4.4 and in accordance with the designed scale described in Table 4.5 (Appendix D). However, the source of information provided in Table 4.4 for each indicator is not provided. Without the information source, it is not possible to verify the accuracy of the evaluation and understand its inherent uncertainty. The proponent should provide the source of the information used in Table 4.4 so that the necessary evaluation of the proposed amendments to Schedule 2 of the Metal Mining Effluent Regulations can be undertaken. These sources include but are not limited to personal communication with an expert, literature review and field study.

Information Request:

1. Provide the source of the information used in Table 4.4.

IR-1 Reference #: AA(1)-14
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Alternatives Assessment
Reference to EIS Guidelines: Sections 8.1, 10.1
Reference to EIS: Appendix D, Table 4.3; EIS Section 2
Summary of Comment/Rationale: The proponent has considered relevant sub-accounts and indicators under the alternatives characterization section in Table 4.3 (Appendix D). For a number of qualitative indicators, there is no description of why the indicator parameters are varying between each alternative. An example of this is for the indicator Sensitivity to Climate Variability, where Alternatives are ranked as having from low to moderate, to moderate to high sensitivities, respectively, but each alternative is characterized as having the same reclaim requirements (i.e. reclaim from pond during winter with ice buildup in pond, Table 4.3). According to current guidance (https://www.canada.ca/en/environmental-assessment-agency/news/policy-guidance/addressing-purpose-alternative-means-under-canadian-environmental-assessment-act-2012.html), it should be clear to an independent reviewer what the basis is for the characterization criteria stipulated for any alternative.

Information Request:

1. Describe why and how indicator parameters are varying between each alternative. Repeat this process for all qualitative indicators.

IR-1 Reference #: AA(1)-15
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Alternatives Assessment
Reference to EIS Guidelines: Sections 8.1, 10.1
Reference to EIS: Appendix D, Table 4.5; EIS Section 2
Summary of Comment/Rationale: The proponent has considered relevant sub-accounts and indicators under the alternatives characterization section. For a number of qualitative indicators, there is no description of how and why indicator scores, shown in Table 4.5 (Appendix D), are defined. An example of this is for the indicator "Noise", where alternatives are either characterized as having Low noise generation or High noise generation due to truck traffic (Table 4.3). However, Table 4.5 does not define what constitutes "High", "High to Medium", "Medium", "Medium to Low", "Low" or "<Low" noise. Without information such as this, it is difficult to understand the work completed by the proponent in developing the Alternatives Assessment. With respect to the qualitative indicators used throughout the multiple accounts analysis, the proponent needs to define the indicator scale in a systematic and transparent manner. Without this information the impacts of the proposed mine waste disposal alternative cannot be fully understood and therefore it cannot be determined if the preferred option is the one that best mitigates effects on Valued Components. Examples of qualitative value scales are provided in Tables 9 and 11 of Environment Canada's guidelines: http://ec.gc.ca/pollution/default.asp?lang=En&n=125349F7-1.

Information Request:

1. Define the range of sensitivities used to score qualitative indicators (e.g. for the indicator "Noise", what the difference is between "High", "High to Medium", "Medium", "Medium to Low", "Low" or "<Low" noise). Repeat this process for all qualitative indicators.

IR-1 Reference #: AA(1)-16
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Alternatives Assessment
Reference to EIS Guidelines: Section 8.1
Reference to EIS: Appendix, Tables 4.4-4.6; EIS Section 2
Summary of Comment/Rationale: The Alternatives Assessment (Appendix D) seeks to differentiate between each alternative. The selection of value scales for assessing some quantitative indicators to compare alternatives in terms of how these value scales differentiate each alternative is in question. For example, for the indicator "Preliminary Estimate of Total Embankment Height" in Table 4.6, the scale of values presented therein ensures that the scores for each alternative are concentrated in a narrow range, i.e. the scores range from 3 to 5. The proposed value scale does not sufficiently differentiate each alternative in accordance with the objectives of the EIS Guidelines. Since the values of this indicator range from 18 to 34 m (see Table 4.4), it would have been more appropriate to establish a scale of values more representative such as: < 19 m ("best") – score of 6; 19 - 22.5 m – score of 5; 22.5 - 26 m – score of 4; 26 - 29.5 m – score of 3; 29.5 - 33 m – score of 2; > 33 m ("worst") – score of 1. This is also the case for the following indicators in the Alternatives Assessment: Potential Loss to flura[sic] and Fana[sic] with construction and operations, Length of Access Roads, Distance from Plant Site to Far End of Facility for pipeline or haul road, Elevation Difference From Plant Site at Final Embankment Elevation, for tailings pumping, Estimate of Slope Angle during operations, Distance From Plant Site to Far End of Facility, Estimate of Water Treatment Volume per year, Capitol[sic] Costs, $M, Life of Mine (differentiating), Operational Cost Estimate, $M, Life of Mine, Closure Cost Estimate, $M, Life of Mine (differentiating), and Extent of structure above topography and sight lines. Current guidance (http://www.ceaa-acee.gc.ca/default.asp?lang=En&n=1B095C22-1 and http://ec.gc.ca/pollution/default.asp?lang=En&n=125349F7-1) state that the Alternatives Assessment seeks to differentiate alternatives. Providing value scales that are more representative of these indicator ranges would better differentiate the alternatives.

Information Request:

1. Provide and implement value scales that are more representative of the discussed indicator ranges in order to better differentiate the alternatives.

IR-1 Reference #: AA(1)-17
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Alternatives Assessment
Reference to EIS Guidelines: Section 8.1
Reference to EIS: Appendix D, Table 4.5; EIS Section 2
Summary of Comment/Rationale: Further to the objective of differentiating between alternatives, the value scale ranges used to score quantitative indicators in Table 4.5 (Appendix D) should be constant to ensure that scoring is proportional for each value in the scale. The selection of value scales for assessing some indicators to compare alternatives in terms of how these value scales differentiate each alternative is in question. For example, the value scale ranges for the indicator Direct Distance from Plant Site to Structure are not constant: The score of "4" is assigned a range of approximately 300 m (1,200 to 900 m) while the remaining scores encompass a range of approximately 400 m (score of "2" ranges from 2,000 to 1,600 m; score of "3" ranges from 1,600 to 1,200 m; score of "5" ranges from 900 to 500 m). Assigning ranges which are not constant within a value scale could favour alternatives with scores that encompass a greater range, or against alternatives with scores that encompass a lesser range. This also applies to the following indicators: Length of Additional Infrastructure Required, Length of Access Roads, Capitol[sic] Costs, $M, Life of Mine (differentiating), and Closure Cost Estimate, $M, Life of Mine (differentiating).

Information Request:

1. Assign and apply value scale ranges used to score quantitative indicators that are constant to ensure that scoring is proportional for each value in the scale.

IR-1 Reference #: AA(1)-18
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Alternatives Assessment
Reference to EIS Guidelines: Section 8.1
Reference to EIS: Appendix D, Tables 4.4 to 4.6; EIS Section 2
Summary of Comment/Rationale: According to current guidance (http://ec.gc.ca/pollution/default.asp?lang=En&n=125349F7-1), sub-accounts need to be sufficiently decomposed to allow measurability. However, sub-accounts should also be non-redundant. The multiple inclusions of indicators whose metrics are measured identically effectively favours those candidate alternatives having a high score for those indicators. The following indicators have metrics which are measured identically in the Alternatives Assessment (Appendix D): Potential for Greenhouse Gas Emission (number of truck hours) and Noise; Number of Main Watersheds Affected and Number of Watersheds; Distance from Plant Site and Operation Distance; Storage Facility and Associated Infrastructure Footprint and Existing Vegetation, ecosystems will be lose[sic]; Slope Stability and Visual Impact; Risk to Human Health and Risk to Worker Safety; Economic Benefits to Regional Communities and Regional Job Creation and Diversity; Aboriginal Rights and Extent of Traditional Land Use

Information Request:

1. Remove those indicators from the Alternatives Assessment (Appendix D) that effectively result in "double-counting" and reassess data accordingly for further clarity.

IR-1 Reference #: AA(1)-19
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Alternatives Assessment
Reference to EIS Guidelines: Section 8.1
Reference to EIS: Appendix D, Tables 4.3, 4.4; EIS Section 2
Summary of Comment/Rationale: Current guidance (http://ec.gc.ca/pollution/default.asp?lang=En&n=125349F7-1) states that when selecting indicators thought should be given to the parameter that will be used to define measurability. Assigning measurability is relatively simple for sub-accounts that readily lend themselves to parametric terms. The following indicators have been defined qualitatively: Potential Impacts to Water Quality, Construction material availability and Tailings Storage Expansion Capacity. It is unclear why the Alternatives Assessment (Appendix D) provides qualitative indicator scales to evaluate indicators which could readily lend themselves to parametric terms. Examples of this include: Potential Impacts to Water Quality: instead of being ranked, could be defined in terms of water quality predicted parameters (e.g. concentrations of metals, pH, DO, etc.); Construction material availability: instead of being ranked, could be defined in terms of amount of construction material available or required; Tailings Storage Expansion Capacity: instead of being ranked, could be defined in terms of volume of capacity to which the TIA could be expanded.

Information Request:

1. Define indicators which readily lend themselves to parametric terms, otherwise provide further justification as to why these indicators have been defined qualitatively.

MINE WASTE MANAGEMENT (including GEOCHEMISTRY AND GEOLOGY)

IR-1 Reference #: MW(1)-01
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Mine Waste
Reference to EIS Guidelines: Section 5.6
Reference to EIS: EIS Summary Section 4.4.1; EIS Section 2.4; Appendix K; Appendix L
Summary of Comment/Rationale: The EIS executive summary and the EIS project description sections state that approximately 23 million tonnes of waste rock will be produced during the open pit mine life with an additional 2 million tonnes being generated and stored on surface from underground mining. Approximately 40% (12 million tonnes) of total open pit waste rock will be used to backfill the pits to minimize the volume and footprint of the waste rock stockpile. The waste rock stockpile will have a footprint of 37 ha, a height of 30 m above grade, and side slopes of 3H: 1V. In Appendices K and L, the amount of total waste rock to be produced at the site is described as approximately 46 million tonnes waste rock. About 20 million tonnes of mine rock will be relocated to the mined out open pits and the remaining 26 million tonnes will be stored in the waste rock storage area (WRSA). The WRSA will have a footprint of 625 000 m² (62.5 ha) and a height of 20 m. The information presented does not match and it is unknown which of the information presented is factually correct.

Information Request:

1. Clarify the following: 1. The total mass and volume of waste rock that would be produced from the integrated open and underground mining operations; 2. The total mass and volume of waste rock to be deposited in the mined out pit,; 3. The total mass and volume of waste rock to be deposited in the WRSA; 4. The final footprint and dimension of the WRSA and the open pit; 5. The total volume of the integrated mined out pit; 6. The stripping ratio of waste rock to ore; and 7. The mass and volume of overburden mined and stored in the overburden stock pile.
2. Revise relevant studies and appropriate sections of the EIS and appendices using the correct information. If the revised information alters significance determinations, describe the changes and provide mitigation, monitoring, and follow-up plans as appropriate.

IR-1 Reference #: MW(1)-02
Links to Annexes A3 and A4: AC(1)-372
s.5 Effect/Valued Component/EA Item: Mine Waste
Reference to EIS Guidelines: Section 8
Reference to EIS: EIS Sections 2.3, 2.3.6; Appendix X
Summary of Comment/Rationale: Project preferred options for both waste rock and tailings management and options at decommissioning (closure) consisted of various locations of the waste rock storage area (WRSA) and tailings storage facility (TSF) sites. At decommissioning (closure) the waste rock will be covered first with a layer of pioneer or base stabilization layer to fill rock voids followed by a low permeability clay layer and a granular shedding on top of the clay layer. At decommissioning (closure) the tailings beach will be graded and covered, similar to the waste rock pile, first with a layer of pioneer or base stabilization layer followed by a low permeability clay layer, a granular shedding on top of the clay layer, and a final top soil layer for re-vegetation purposes. The abandonment (post-closure) performance of simple and composite clay covers on waste rock pile at the Equity Silver Mine, Barrick Gold Corporation, Houston, B.C. and pyritic shale rock pile at the Halifax International Airport, N.S. has not been successful. At both of these sites, the covers did not perform as designed, requiring collection and chemical treatment of the drainage effluents.

Information Request:

1. Provide information on the type of pioneer layer to be placed on the various waste management sites and the estimated thickness and long-term performance of these layers.
2. In light of the poor performance track record of simple clay covers provide additional conceptual design features that could be incorporated in the proposed clay covers at the project site to prevent long-term acid rock drainage (ARD) and metal leaching (ML).
3. Provide and describe monitoring and follow-up programs to reliably verify predicted effects (or absence of them), and to confirm both the assumptions and the effectiveness of the proposed clay covers. Provide contingency measures as a means of addressing unforeseen effects related to the proposed clay cover.
4. Provide information on the expected longevity of the designed clay covers.

IR-1 Reference #: MW(1)-03
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Mine Waste
Reference to EIS Guidelines: Section 5
Reference to EIS: Appendix D, Section 3.2.1; EIS Section 1.4.3
Summary of Comment/Rationale: Section 3.2.1 (Appendix D) states: "This concept assumes that disposal of tailings solids into underground mine workings can occur after Year 5 of operations and that an assumed 40% can be removed from the tailings stream (directed to the on land tailings facility after Year 5) and directed to the underground mine workings." While no explicit schedule is provided, there does not appear to be evidence that the goal of diverting 40% of the tailings stream to underground mine workings after year 5 is reasonable. The requested information will also be required in complete detail during the provincial permitting phase when submitting the required closure plan.

Information Request:

1. Describe how the tailings and exhausted underground mine workings volumes were estimated to provide evidence that the 40% goal is feasible.
2. Provide contingency measures as a means of addressing unforeseen effects should the 40% goal not be feasible.

IR-1 Reference #: MW(1)-04
Links to Annexes A3 and A4: AC(1)-416
s.5 Effect/Valued Component/EA Item: Mine Waste
Reference to EIS Guidelines: Sections 8.1, 10.1
Reference to EIS: Appendix D
Summary of Comment/Rationale: The analysis in Appendix D is incomplete and does not account for the disposal of all mine waste. It only covers the tailings storage location and deposition technology. There is no mention of the disposal of other mine waste such as waste rock, low-grade ore (LGO) and overburden. The Metal Mining Effluent Regulations (MMER), as per paragraph 5(1)(a), stipulate that for mine waste to be deposited in a natural water body frequented by fish, the water body must be listed in Schedule 2 of the MMER, designating it as a tailings impoundment area (TIA). In this context, a TIA is a natural water body frequented by fish into which deleterious substances (e.g. tailings, waste rock, low grade ore, overburden, and any effluent that contains any concentration of the deleterious substances specified in the MMER and is of any pH) are disposed. Information pertaining to which water bodies will be impacted by mine waste is essential to the determination of effects to these water bodies.

Information Request:

1. Describe the disposal of all types of mine wastes including tailings, waste rock, low grade ore, overburden and mine effluent, and indicate whether or not any water bodies frequented by fish will be impacted by the disposal of these mine wastes.
2. Provide maps that overlay the proposed mine waste options with the local water bodies and specify which water bodies are deemed to be fish frequented.
3. If any of the mine wastes listed in responses to questions A and B of this IR are not required to be subject to the MMER Schedule 2 amendment requirements, provide appropriate explanation and rationale.

IR-1 Reference #: MW(1)-05
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Mine Waste
Reference to EIS Guidelines: 9.1.2
Reference to EIS: EIS Section 5.4.1; EIS Appendix Figure 1.1
Summary of Comment/Rationale: No contour information appears on Figure 1.1 (Appendix D) which is referenced in section 5.4.1 (EIS) as evidence that the project area is one of relatively low relief and that the landslides, slope erosion and potential for instability is limited in the project area. This has implication on the proposed tailings storage facility.

Information Request:

1. Provide contour information on Figure 1.1 (Appendix D) or change the reference in section 5.4.1 (EIS) to the appropriate figure containing topographic information.

IR-1 Reference #: MW(1)-06
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Acid Rock Drainage
Reference to EIS Guidelines: Sections 7.2.1, 9.1.2
Reference to EIS: EIS Sections 2, 3, 6, 13
Summary of Comment/Rationale: Local study areas and regional study areas (LSA/RSA) in relation to acid rock drainage/ metal leaching (ARD/ML) is not clearly defined, justified, or referenced in the EIS. Section 7.2.1 of the EIS Guidelines requires the EIS to clearly indicate the spatial boundaries to be used in assessing the potential adverse environmental effects and provide a rationale for each boundary.

Information Request:

1. Define the LSA/RSA as it relates to ARD and provide a rationale for the defined LSA/RSA.
2. Provide and reference a map that clearly indicates creeks, lakes etc. that could act as receptors for ARD/ML.

IR-1 Reference #: MW(1)-07
Links to Annexes A3 and A4: AC(1)-98
s.5 Effect/Valued Component/EA Item: Acid Rock Drainage
Reference to EIS Guidelines: Section 9.1.2
Reference to EIS: EIS Sections 6, 11, 13
Summary of Comment/Rationale: Section 9.1.2 of the EIS Guidelines requires the EIS to include "ARD/ML prevention/management strategies under a temporary or early decommissioning scenario, including low grade ore." This information is not provided under sections 6, 11, or 13 of the EIS.

Information Request:

1. Provide an ARD/ML prevention management strategy under a temporary or early decommissioning scenario.

IR-1 Reference #: MW(1)-08
Links to Annexes A3 and A4: PC(1)-08; AC(1)-295; AC(1)-304
s.5 Effect/Valued Component/EA Item: Acid Rock Drainage
Reference to EIS Guidelines: Section 5.7
Reference to EIS: EIS Sections 2.3.11, 3.5.1, 3.7.2
Summary of Comment/Rationale: It is unclear whether the proponent will use mine waste rock as a source of aggregate on the project site. Section 3.5.1 (EIS) indicates potentially acid generating waste rock will be separated. Section 2.3.11.2 (EIS) states: "No site has been identified to date that contains non-acid generating (NAG) rock suitable for aggregate construction." While section 3.7.2 (EIS) states: "Subsequent raising of the embankments will utilize NAG mine waste rock with downstream slopes of 1.5H:1V while maintaining the upstream slope at 2.5H:1V." It is unclear whether NAG rock can be obtained from the waste rock to use for construction of the tailings storage facility (TSF) embankments. If there is no NAG rock available on site, as suggested in 2.3.11.2 (EIS), clarify from where the rock will be obtained for construction of the TSF embankments.

Information Request:

1. Clarify where NAG rock will be obtained for the construction of the TSF embankments and use as aggregate.
2. Confirm whether or not onsite potentially acid generating/metal leaching waste rock will be separated and provide justification for the choice.
3. If potentially acid generating/metal leaching rock will be separated, provide detailed methods to be used in this segregation process.
4. If aggregate must be sourced offsite, describe the potential impacts associated with obtaining and delivering this material to the project site.
5. Revise the EIS document to provide consistency across sections when discussing the use of waste rock as aggregate or material for decommissioning activities.

IR-1 Reference #: MW(1)-09
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Acid Rock Drainage
Reference to EIS Guidelines: Section 5
Reference to EIS: EIS Sections 3.3.1, 3.5.2, 11.3.3
Summary of Comment/Rationale: Based on statements in sections 3.3.1, 3.5.2, and 11.3.3 (EIS), it is assumed the overburden material is chemically stable, but no evidence has been provided. The geochemistry of the overburden material is a fundamental piece of information missing from the effects prediction. Note that the requested information will also be required in complete detail during the provincial permitting phase when submitting the required closure plan.

Information Request:

1. Analyze and describe the chemical stability of the overburden material and any potential environmental effects associated with the overburden stockpile, including feasible mitigation methods and conceptual decommissioning (closure) options.

IR-1 Reference #: MW(1)-10
Links to Annexes A3 and A4: PC(1)-17; PC(1)-18; PC(1)-26; AC(1)-304
s.5 Effect/Valued Component/EA Item: Acid Rock Drainage
Reference to EIS Guidelines: Section 10
Reference to EIS: EIS Section 11.2.1; Appendix L Section 5.1
Summary of Comment/Rationale: The description of the cover to be used for the waste rock storage area (WRSA) is not comprehensive. While it is not expected that the final cover design be provided, the proponent must show the capacity to develop adequate cover onsite, from both a conceptual design and materials availability perspective. It is expected that similar cover would be used for the low-grade ore (LGO) stockpile in the event that this pile remains upon decommissioning (closure) and abandonment (post-closure) phases. It was noted in section 5.1.1 (Appendix L) that "the location of the waste rock storage area (WRSA) has not been finalized at this time." However, it was determined through the alternatives assessment, section 2.3.3.4 (EIS), that "the preferred location for the storage of waste rock material is to the north of the open pit combined with a co-disposal within the completed open pit to the extent possible."

Information Request:

1. Provide a conceptual design for the waste rock storage area (WRSA) cover, including approximate layer type, configuration and thickness, and identify whether the materials required are available for the project. Also provide the conceptual design for the low-grade ore stockpile in the event that this pile remains upon decommissioning (closure) and abandonment (post-closure) phases.
2. List and describe environmental factors that could result in reduced efficacy or failure of the covers over time.
3. Describe monitoring and follow-up plans to confirm both the assumptions and the effectiveness of the WRSA and the low-grade ore stockpile covers, as applicable, to limit acid rock drainage.
4. Provide a map of the confirmed location of the WRSA.

IR-1 Reference #: MW(1)-11
Links to Annexes A3 and A4: AC(1)-376; AC(1)-389
s.5 Effect/Valued Component/EA Item: Acid Rock Drainage
Reference to EIS Guidelines: Sections 5.6, 9.1.2
Reference to EIS: Appendix F Section 6
Summary of Comment/Rationale: During the decommissioning (closure) phase, as water is deliberately drained off the tailings to allow for tailings consolidation and the capping materials are emplaced, acid generation will occur and contaminants will seep into the tailings mass. This pulse of contamination eventually will seep out from the tailings storage facility. No information is provided to explain how contaminated this pulse will be and how long it will take to appear in downstream monitoring wells and ultimately receiving waters. This type of information is important for determining the duration of seepage interception and treatment after decommissioning (closure). Additional information should be provided on the estimated amount of acid rock drainage (ARD) and metal leaching (ML) that will occur during the decommissioning (closure) phase. This additional information should include and consider: (1) how long the tailings storage facility (TSF) dewatering capping will take to complete, and use this to estimate the amount and extent of ARD/ML that may take place; (2) the concentrations of contaminants of concern and estimated volumes of this pulse of ARD seepage that will escape the TSF; (3) the estimated length of time for the seepage to be detected in the monitoring wells; and (4) the potential impact of this seepage on the receiving waters.

Information Request:

1. Provide additional information on the ARD/ML that will occur during the decommissioning (closure) phase, specifically:
   1. the length of time it will take for the tailings storage facility (TSF) dewatering and capping to be complete;
   2. the estimated amount and extent of ARD/ML that may take place, calculated by using the results of 1);
   3. concentrations of contaminants of concern and estimated volumes of the pulse of ARD seepage that will escape the TSF;
   4. estimated length of time for the seepage to be detected in the monitoring wells;
   5. the length of time it will take for the pulse to appear in receiving waters; and
   6. the potential impact of the seepage on the receiving waters.

IR-1 Reference #: MW(1)-12
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Acid Rock Drainage
Reference to EIS Guidelines: Section 9.1.2
Reference to EIS: EIS Sections 11, 13.5
Summary of Comment/Rationale: Section 9.1.2 of the EIS Guidelines requires the EIS to include pit water quality geochemical modeling in the abandonment (post-closure) period. This information is not provided in sections 11 or 13.5 of the EIS.

Information Request:

1. Provide pit water quality geochemical modeling for the abandonment period.

IR-1 Reference #: MW(1)-13
Links to Annexes A3 and A4: PC(1)-74; AC(1)-387; AC(1)-395
s.5 Effect/Valued Component/EA Item: Acid Rock Drainage
Reference to EIS Guidelines: Sections 10, 11
Reference to EIS: EIS Section 11.2.2
Summary of Comment/Rationale: In describing the flooded pit, section 11.2.2 (EIS) states: "the elevation of the spillway will be set to ensure the lake level is maintained within the overburden above the bedrock." No specific detail is provided as to the depth of water cover that is possible over the overburden-bedrock interface or the mine waste rock that will be used to backfill some of the pit. For this design to be successful, it will be necessary to ensure that adequate water cover is maintained in perpetuity (including abandonment) to mitigate acid rock drainage/metal leaching conditions. The requested information will also be required in complete detail during the provincial permitting phase when submitting the required closure plan.

Information Request:

1. Describe how water cover can be maintained in the pit, including details of the extent of water cover over both the overburden-bedrock interface and the stockpiled mine waste rock.

IR-1 Reference #: MW(1)-14
Links to Annexes A3 and A4: AC(1)-98; AC(1)-376
s.5 Effect/Valued Component/EA Item: Acid Rock Drainage
Reference to EIS Guidelines: Section 9
Reference to EIS: EIS Sections 2, 3, 6, 13; Appendix F; Appendix C Section 4.0; Appendix K Sections 2.2, 4.3
Summary of Comment/Rationale: While preliminary geochemical baseline studies have been completed, the EIS indicates that additional testing will be required to confirm geochemical modelling predictions and effectiveness of proposed mitigation strategies. Section 13 (EIS) does not identify the appropriate enforceable duration for monitoring of acid rock drainage (ARD)/metal leaching (ML). Given that preliminary testing indicates that ARD onset will take decades to occur, monitoring or the lack thereof should reflect this. This information is important as it must be shown that the tailings storage facility effluent can be treated to meet PWQO.

Information Request:

1. Outline what additional testing is needed and the plans to complete the testing to confirm geochemical modelling predictions and effectiveness of the proposed mitigation strategies. Refer to Prediction Manual for Drainage Chemistry from Sulphidic Geological Materials, MEND Report 1.20.1 (MEND, 2009) for sampling information.
2. Outline a monitoring program for ARD/ML and provide justification for the duration.

IR-1 Reference #: MW(1)-15
Links to Annexes A3 and A4: AC(1)-312
s.5 Effect/Valued Component/EA Item: Acid Rock Drainage
Reference to EIS Guidelines: Section 9.1.2
Reference to EIS: EIS Section 5.4.3.4; Appendix K
Summary of Comment/Rationale: Section 5.4.3.4 (EIS) indicates it was conservatively estimated that the time to onset of acid rock drainage (ARD) for the waste rock, which is all classified as potentially acid generating (PAG), would be between a few tens of years to many tens of years. For exposed tailings beaches in the tailings storage facility (TSF) the ARD onset time was estimated to be only a few years. The waste rock is classified as PAG and the waste rock stockpile is estimated to contain approximately 5% of fine broken material of size fraction similar to that of the humidity cell test (HCT) material. This suggests the ARD onset in the waste rock pile should be the earliest humidity cell ARD onset time adjusted for temperature effect, irrespective of other particle size fractions of the waste rock; however Appendix K does not seem to accept this and assumes acidic drainage in the waste rock stockpile will be delayed to a greater extent than observed in the HCTs.

Information Request:

1. Provide additional information on the methodology followed for estimating the ARD onset time including: times of neutralization potential and acid potential depletions, reaction rate kinetics and drainage effluent (Ca + Mg)/SO4 based neutralization potential ratio as a function of time.
2. For waste rock, provide a more definitive ARD onset time rather than the broader estimated time of a few tens to many tens of years.
3. Explain whether or not the ARD onset in the waste rock stockpile should be the earliest humidity cell ARD onset time adjusted for temperature effect, irrespective of other particle size fractions of the waste rock.

IR-1 Reference #: MW(1)-16
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Acid Rock Drainage
Reference to EIS Guidelines: Section 9.1.2
Reference to EIS: EIS Sections 5.4.3, 5.4.3.1
Summary of Comment/Rationale: For estimating the ARD onset time and total loading rates of various contaminants of potential concern (COPCs), it was assumed that the waste rock pile at the project mine site would contain approximately 5% by weight of fine broken material in the particle size fraction of <6 mm (0.25") used in the humidity cell tests. Materials larger than the above size fraction would also oxidize and contribute to the total COPCs load but at a lower rate due to decreasing specific surface area with increasing particle size. The estimated 5% wt. percentage for <6 mm size fractions appears to be on the low side for the altered felsic metavolcanic rocks (sericite schist, biotite-muscovite schist) and metasedimentary rocks. Actual field data for a granitic waste rock pile in northern Saskatchewan had a wt. percentage of about 8-10% of < 6mm size fractions. It is expected that biotite-muscovite schist type rock at the Goliath site would contain similar or higher weight percentage. The proponent should use a more realistic weight fraction number for rock lithologies that would be mined at the project site. The proponent should provide supporting information on how the expected weight percentage of 5% for COPCs load estimation for the waste rock pile was obtained. Was it based on blast hole rock fragment calculations/measurements or actual field data from other mine sites containing similar rock lithologies?

Information Request:

1. Provide supporting information on how the expected weight percentage of 5% for the contaminants of potential concern (COPCs) load estimation for the waste rock pile was obtained.
2. Justify the use of the current weight fraction number or revise accordingly.

IR-1 Reference #: MW(1)-17
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Acid Rock Drainage
Reference to EIS Guidelines: Section 9.1.2
Reference to EIS: EIS Section 5.4.3 ; Appendix K; Table 3.11
Summary of Comment/Rationale: In Table 3.11 (Appendix K) some COPCs loading rates functions are expressed as: y = 6E-8 + 6E-7 (for iron, Fe); y = 3E-7 + 1E-6 (for lead, Pb); y = 5E-6 + 3E-7 (for uranium, U) ; y = 5E-6 + 1E-5 (for zinc, Zn); Clarification on these functions is needed for the review.

Information Request:

1. Clarify Table 3.11 (Appendix K) by providing detail on: 1. What the loading rate function equations for Fe, Pb, U and Zn represent; and, 2. How the average loading rates given in the last column of Table 3.11 (Appendix K) were obtained by such loading rate functions.

IR-1 Reference #: MW(1)-18
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Acid Rock Drainage
Reference to EIS Guidelines: Sections 10, 11
Reference to EIS: Appendix C of Appendix F Section 4.0
Summary of Comment/Rationale: One assumption of the model presented in section 4 (Appendix C of Appendix F) is that: "backfilled pits are effectively isolated from water and oxygen, thus prevented from undergoing further ARD reactions or generating leachate." It is not clear how the proponent expects to isolate the waste rock that is used to backfill the pits from water. It is anticipated that the pits will flood, thus saturating the waste rock, with the intention of limiting the oxidation of this material.

Information Request:

1. Clarify and justify the assumption described in section 4, revise as necessary.

IR-1 Reference #: MW(1)-19
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Acid Rock Drainage
Reference to EIS Guidelines: Section 9
Reference to EIS: Appendix K, Section 2.3.3
Summary of Comment/Rationale: Section 2.3.3 (Appendix K) requires clarification for interpreting the geochemical evaluation results. It was described in this section that "the samples were constantly agitated for approximately 24 hours prior to sampling the leachate," and that "all flasks were intermittently agitated over a 24 hour period."

Information Request:

1. Clarify which technique was used for the shake flask extractions.

IR-1 Reference #: MW(1)-20
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Acid Rock Drainage
Reference to EIS Guidelines: Section 9.1.2
Reference to EIS: EIS Section 5.4.3; Appendix K Section 2.3.3
Summary of Comment/Rationale: The soluble masses of constituents in the tailings and mine rock were assessed by shake flask extraction (SFE) tests. The tests involved leaching of the test materials with DI water using water to solid ratio of 3:1. Although no regulatory criteria exist for constituent concentrations in SFE, values were compared with Provincial Water Quality Objectives (PWQO). For screening purposes, results of the SFE were compared to 100 times (100X) the PWQO in order to identify aqueous constituents that may require additional investigation. The 100X screening level was chosen to represent the "natural dilution contact water would undergo as it enters the surface water." It is understood that the 7Q20 of Blackwater Creek, the proposed discharge receiver, is essentially zero. Therefore, it cannot be expected that 100 times dilution will be achieved. The proponent should provide the rationale for using the dilution factor of 100 for comparing the SFE results to PWQO as the SFE leachates (liquid to solid wt. factor of 3) are already about 30 times dilute in comparison to actual drainages from waste rock pile where the contact liquid to solid weight ratio is about 0.1:1 (wt. factor 0.1) or less. In addition, the SFE leachate results provide the total concentrations of soluble constituents present in the test materials and have no relationship to the actual leachates that will be produced from tailings or waste rock management sites. The proponent should provide the purpose of their comparisons with appropriate regulatory water quality objectives.

Information Request:

1. Provide a revised comparison datum to represent more realistic dilution rates and comment on any additional aqueous constituents that may require further investigation.
2. Provide the purpose of comparisons with appropriate regulatory water quality objectives.

IR-1 Reference #: MW(1)-21
Links to Annexes A3 and A4: AC(1)-312
s.5 Effect/Valued Component/EA Item: Acid Rock Drainage
Reference to EIS Guidelines: Section 9.1.2
Reference to EIS: Appendix K, Section 2.4.3; EIS Section 5.4.3.1
Summary of Comment/Rationale: The following equation, the Arrhenius equation, was used in section 2.4.3 (Appendix K) to translate laboratory humidity cell test (HCT) results for mine rock and tailings reaction rates, k1, to more appropriate field reaction rates, k₂: ??(?1?2)=??(?1−?2)??1?2

by assuming that laboratory temperatures, T1, were 20 °C, "while temperatures under field conditions for the stockpile [T2] will be approximately equal to the average air temperature at the site," 2°C. A temperature adjustment factor of 0.12 was estimated and used for reaction rates of metal loading from the stockpile in the EIS. While this transformation is necessary, it was hypothesized that using the average annual air temperature may not be accurate since near surface ground temperature is known to fluctuate with air temperature and the Arrhenius equation is not a linear function. This theory was tested by calculating the average monthly field reaction rate, k2, using average monthly air temperatures for the site taken to be -16.8, -12.7, -5.8, 3, 10.8, 16.2, 18.9, 17.8, 11.7, 4.2, -5.2, and -13.5 for January through December (1981 to 2010 Canadian Climate Normals for Dryden Airport, Environment Canada). The average of these 12 monthly reaction rates was 0.29, approximately 240% of that estimated using the average annual air temperature. The calculated contaminants of potential concern loadings are unnecessarily biased on the low side due to inclusion of winter temperatures when the waste rock pile is mostly frozen and there is no subsurface flow or drainage. In some cases the waste pile may remain warm or hot depending upon the rate of sulphide oxidation within the pile. Therefore, the low temperature adjustment factor of 0.12 is unjustified and should be revised. Given the exponential nature of the Arrhenius equation, it may be more appropriate to use more detailed temperature data when transforming laboratory reaction rates to field condition reaction rates. The requested information will also be required in complete detail during the provincial permitting phase when the updated geochemical model is provided.

Information Request:

1. Recalculate the temperature adjustment factor for reaction rates and provide details on any changes this alteration has on the geochemistry evaluation of the site.
2. Recalculate and provide the contaminants of potential concern (COPCs) loadings rates on a monthly basis for ice free period using the temperature adjustment factors corresponding to the monthly average daily temperatures as shown in figure 5.1.1. (EIS, page 5-3) for the Dryden area. Add together the individual monthly COPCs loadings to obtain the total annual load and provide this sum.
3. Revise and provide the predicted effluent concentrations accordingly on a monthly basis and use these values for developing the monitoring program.

IR-1 Reference #: MW(1)-22
Links to Annexes A3 and A4: AC(1)-312
s.5 Effect/Valued Component/EA Item: Acid Rock Drainage
Reference to EIS Guidelines: Section 9
Reference to EIS: Appendix K, Section 3.3.1
Summary of Comment/Rationale: Section 3.3.1 (Appendix K) states: "one or more of the BS [biotite schist], BMS [biotite muscovite schist], and MSS [muscovite sericite schist] HCTs [humidity cell tests] did not reach steady-state for one or more COPCs [constituents of potential concern] prior to concluding the experiments." It is not clear whether or not those HCTs that did not reach a steady-state would be continued through to completion. Please note the Prediction Manual for Drainage Chemistry from Sulphidic Geologic Materials (MEND, 2009) suggests that "the humidity cell test ends when the rates of sulphate generation and metal leaching have stabilized at relatively constant rates for at least five weeks." Having a complete understanding of the anticipated drainage chemistry is an integral part of the effects assessment and must be adequately addressed in order for impacts to be evaluated appropriately.

Information Request:

1. Confirm that HCTs were allowed to progress through to completion, or adequately justify how the results collected are sufficient for the purposes of the effects assessment for the Project.

IR-1 Reference #: MW(1)-23
Links to Annexes A3 and A4: AC(1)-298; AC(1)-372
s.5 Effect/Valued Component/EA Item: Acid Rock Drainage
Reference to EIS Guidelines: Section 5, 11, 12
Reference to EIS: EIS Section 11.5.1
Summary of Comment/Rationale: The period length of five years for dam stability monitoring during decommissioning (closure) and abandonment (post-closure) does not appear adequate to ensure the physical integrity of the dam in perpetuity. There was no mention of waste rock storage area or tailings storage facility slope stability monitoring. Monitoring the integrity of the slopes and dams is required to ensure they are functioning as intended. It is expected that such monitoring will be conducted during decommissioning (closure) and abandonment (post-closure) phases.

Information Request:

1. Revise the dam stability monitoring program to include monitoring of the integrity of the waste rock storage area or tailings storage facility slopes and provide details regarding the justification of the monitoring program.
2. Describe physical stability monitoring for the waste rock storage area and tailings storage facility, including covers, slopes, feasible mitigation measures that will be initiated in the event that deficiencies are observed, and assigned responsibilities to identify and implement the mitigation measures.

IR-1 Reference #: MW(1)-24
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Mine Waste; Geology
Reference to EIS Guidelines: Section 9.2.1
Reference to EIS: EIS Section 5.4.1, Figure 5.4.1; Appendix D; Figure 2.2
Summary of Comment/Rationale: The Wabigoon Fault is a regional structure that transects the southern edge of the Goliath project property. Information provided in the EIS related to the fault is that, north of the Wabigoon Fault, rock units dip steeply (70-80°) south whereas south of the fault, rocks face steeply north. No information regarding the fault itself is provided in the EIS. Impacts related to the proximity of the Wabigoon Fault to the proposed development cannot be assessed without information on the fault. This has implications on mine waste management, seepage and the tailings storage facility.

Information Request:

1. Describe the character, width, age and movement history of the Wabigoon Fault, specifically addressing: 1. Whether it is a structure along which movement will take place over the course of the project; and 2. Whether it is a structure that will localize/mobilize/affect drainage and water (contaminated or fresh groundwater).
2. Describe any potential environment impacts that could reasonably be expected to occur in connection with the Wabigoon Fault and how the impacts will be mitigated.

IR-1 Reference #: MW(1)-25
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Acid Rock Drainage
Reference to EIS Guidelines: Sections 5, 11
Reference to EIS: Appendix F, Section 4.2
Summary of Comment/Rationale: Beached tailings are a likely possibility. Mitigation measures or a contingency plan to address the effects of this possibility are not discussed in the EIS. With the significant positive water balance in the tailings storage facility (TSF), it should be possible for the proponent to maintain adequate water cover to mitigate the possibility "that tailings are deposited above the intended water cover, or the water level in the tailings storage facility drops to the point that tailings solids become exposed to air." It is planned that "water cover of 1.2 m will be maintained" on the TSF. This amount of cover does not appear sufficient. When determining the water cover required, the proponent must consider undulations in the tailings (e.g., plan that 1.2 m is the minimum amount of water cover at any point within the TSF), extreme drought events, and wave erosion.

Information Request:

1. Provide adequate justification for the water cover on the TSF and include mitigation measures and contingencies that will ensure adequate water cover is maintained until the dry cover is to be administered.

GROUNDWATER QUALITY AND QUANTITY

IR-1 Reference #: GW(1)-01
Links to Annexes A3 and A4: AC(1)-366; AC(1)-401
s.5 Effect/Valued Component/EA Item: Groundwater Quality
Reference to EIS Guidelines: Section 9.1.2
Reference to EIS: Appendix M, Section 4.3; EIS Section 5.6.3.4
Summary of Comment/Rationale: Groundwater quality in bedrock has not been assessed. This is necessary for baseline purposes and is most important for the shallow bedrock as it is most likely to be affected by seepage.

Information Request:

1. Provide groundwater quality monitoring data for the shallow bedrock.

IR-1 Reference #: GW(1)-02
Links to Annexes A3 and A4: PC(1)-10; AC(1)-305; AC(1)-408; AC(1)-418
s.5 Effect/Valued Component/EA Item: Groundwater Quality
Reference to EIS Guidelines: Sections 7.1.2, 11.4, 16
Reference to EIS: EIS Section 3.7.6
Summary of Comment/Rationale: Seepage monitoring should be able to detect changes in groundwater quality both in the early stages of operations and in the abandonment phase. Seepage can take many years, even decades, to travel to a monitoring well depending on its distance from the seepage source and hydrogeological conditions. If the seepage does lead to groundwater quality impacts it could manifest in impacts to fish and fish habitat when it discharges into surface water.

Information Request:

1. Identify proposed groundwater monitoring locations that are intended to detect and measure seepage. Justify their locations based on seepage flow directions, volumes, travel times, and the location of environmentally sensitive areas.

IR-1 Reference #: GW(1)-03
Links to Annexes A3 and A4: PC(1)-06; PC(1)-34; AC(1)-14; AC(1)-322; AC(1)-324; AC(1)-372; AC(1)-389; AC(1)-408
s.5 Effect/Valued Component/EA Item: Groundwater Quality
Reference to EIS Guidelines: Section 10
Reference to EIS: EIS Section 6.2.1.8; Appendix K
Summary of Comment/Rationale: Some potential effects to groundwater are not discussed in the EIS. These include seepage from the pit, contamination related to explosive residuals, and estimated loadings to receivers resulting from seepage from the mine facilities including the waste rock storage area (WRSA), low grade ore stockpile (LGO), tailings storage facility (TSF, TMA), and the pit. While information regarding seepage quantity is provided in Appendix M, and loading rates for the tailings storage facility (TSF) and waste rock storage area (WRSA) are estimated in Appendix K, the estimated quality of the seepage from the mine facilities, including receiver loading estimations, does not appear to be discussed. Effects associated with seepage, including seepage quantity and surface water loading estimates should be considered in the hydrogeological model sensitivity analysis.

Information Request:

1. Describe seepage water quality during operations, decommissioning and abandonment from the major mine features, including the pit, WRSA, TSF, and LGO stockpile, groundwater impacts associated with explosives, and seepage loadings to receivers. Include conservative estimates of loadings to surface water, predicted effects to offsite groundwater and feasible mitigation measures.

IR-1 Reference #: GW(1)-04
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Groundwater Quality
Reference to EIS Guidelines: Section 9.1.2
Reference to EIS: Appendix D, Section 4.7.1
Summary of Comment/Rationale: Section 4.7 (Appendix D) states: "The summaries for each of the accounts (from Environment Canada, Guidelines for the Assessment of Alternatives for Mine Waste, September 2015) are as follows: Environmental Account – Characterizing the local and regional environment surrounding the proposed TIA. These include elements such as climate, geology, hydrology, hydrogeology, water quality and potential impacts on aquatic, terrestrial and bird life." However, in section 4.7.1 (Appendix D), under the subaccount, "Water Impacts", groundwater quality and quantity are not listed as indicators. Groundwater quality and quantity, which are valued components (see section 9.1.2 of the EIS Guidelines), must be included in the environmental account to predict the direct and indirect effects caused by the development, construction, operation, and decommissioning of a given location and tailings disposal technology.

Information Request:

1. Incorporate groundwater quality and quantity in the environmental account, as defined in current guidance, and include groundwater quality and quantity under the subaccount, "Water Impacts".

IR-1 Reference #: GW(1)-05
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Groundwater Quality
Reference to EIS Guidelines: Section 9
Reference to EIS: Appendix C of Appendix F Section 3.0; Appendix K Sections 2.4.2, 2.4.3, 3.3.2
Summary of Comment/Rationale: Scaling factors were used to adjust laboratory results for source term calculation in the groundwater quality model. The proponent states: "The scaling factors were selected based on applicability to site conditions at the Project and were calibrated against the data collected from field cells in operation since November 2012. The details of the scaling factors applied to each source term are presented in Table 1." It was assumed that Table 1 was referring to the table of assumptions at the end of Appendix C (of Appendix F) as no Table 1 could be found. The values used as scaling factors are not discussed in detail. Further information is required to assess the validity of these values. Some scaling factors used were in the range of 0.03, suggesting that some laboratory tests over estimate loading rates by a factor of 3,333%. Such a significant discrepancy between laboratory and field conditions warrants additional justification. Section 2.4.2 (Appendix K) states that: "the barrel tests results are assessed in parallel with the laboratory humidity cell results to verify the appropriateness of the scaling factors used to scale laboratory conditions to field conditions." However, it appeared as though the results of this assessment were not provided. Additionally, section 3.3.2 (Appendix K) states that "loading rates were not calculated for the barrel tests as equilibrium values had not yet been reached for each of the four mine rock types, at the time of this report." There was no discussion of when these results would be provided. These results are needed to verify the appropriateness of the scaling factors used. Section 2.4.3 (Appendix K) states: "it was assumed that approximately 5% of the material comprising the expected Goliath mine rock material will be of similar size to the material tested in the humidity cells (less than 1 inch to silt/clay size). As such, a scaling factor of 0.05 was applied to the calculated laboratory loading rates." This logic is unreasonable, as the remaining 95% of the mine rock material will not have zero surface area and cannot be excluded from the effects assessment. No water quality model sensitivity analysis results were provided for these scaling factors. The requested information will also be required in complete detail during the provincial permitting phase.

Information Request:

1. Provide the results of the barrel tests and discuss the assessment of the appropriateness of these scaling factors as they relate to barrel test results.
2. Provide additional details and discussion regarding the development and use of these scaling factors. Include water quality model sensitivity analysis results for these adjustment factors to provide a range of potential, including worst case scenario, effects.
3. Justify the use of the particle size scaling factor of 0.05 to adjust loading rates instead of a particle size scaling factor that represents 95% of the mine rock material. Revise the water quality model as appropriate and describe any change in anticipated effects.

IR-1 Reference #: GW(1)-06
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Groundwater Quality
Reference to EIS Guidelines: Section 9
Reference to EIS: Appendix C of Appendix F Section 3.0, Table 1
Summary of Comment/Rationale: Assumptions are made throughout Table 1 (Appendix C of Appendix F) for various ‘active depths'. No justification for the selection of these depths is given. The requested information will also be required in complete detail during the provincial permitting phase when submitting the required Closure Plan.

Information Request:

1. Provide details on how the active depths were considered and whether the assumptions made are conservative.

IR-1 Reference #: GW(1)-07
Links to Annexes A3 and A4: PC(1)-06; AC(1)-372; AC(1)-389
s.5 Effect/Valued Component/EA Item: Groundwater Quantity
Reference to EIS Guidelines: Sections 5.6, 10.1.2
Reference to EIS: EIS Sections 3.7.4, 3.8.5.4; Appendix F Sections 2.1.4, 4.2, Appendix C; Appendix K Section 4.3; Appendix M Section 5.3.5
Summary of Comment/Rationale: The embankments for the tailings storage facility (TSF) are proposed to be constructed upon overburden, rather than upon bedrock that has been exposed by excavation of the overburden. Seepage will therefore occur which has the potential to impact both surface and groundwater quality. Some inconsistency exists within the EIS, where Section 2.1.4 (Appendix F) suggests that all seepage from the TSF will be captured: "seepage from the dam will be collected and returned to the tailings storage facility." This claim is also made in Section 4.2 (Appendix F): ".any dam seepage being returned to the impoundment." Again in Appendix C (of Appendix F): "for the purposes of this preliminary water quality model, all run?off and seepage waters are considered to be collected and diverted to the TSF." And further in Section 4.3 (Appendix K): "All drainage from the temporary stockpiles will report to one of three collection ponds and treated at the processing plant before being discharged to the environment." Note the reference to ­"all drainage" in Section 4.3 (Appendix K). This concept is also discussed in Section 6.5 (Appendix L). It is not reasonable to suggest that all seepage will be collected. This idea is supported in Appendix M where it is stated that some seepage from the waste rock storage area (WRSA) and the tailings management area (TMA) is expected to eventually discharge to Blackwater Creek, Hoffstrom's Bay Creek, Thunder Lake Tributary #3 and Thunder Lake.

Information Request:

1. Revise the seepage assessment to include and account for the amount of seepage that will flow beneath the embankments and assess the potential ground and surface water quality impacts associated with its release.
2. Update the wording to remove any suggestion that all seepage from any of the mine facilities will be captured.

IR-1 Reference #: GW(1)-08
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Groundwater Quantity
Reference to EIS Guidelines: Section 9.1.2
Reference to EIS: Appendix M, Section 3.1.1, Figure 4
Summary of Comment/Rationale: A good understanding of the surficial geology of the area around the proposed pit is essential for both hydrogeological modelling and site layout purposes. The surficial geology map shown in Figure 4 (Appendix M) is erroneous for the area surrounding the proposed pit and along the perimeter of the drawdown zone. For example, the map shows glaciolacustrine sediments in an area where the proponent mapped a series of bedrock outcrops. Moreover, the map differs considerably from that of Cowan and Sharpe (1991) cited by the proponent, which appears to be more accurate in many respects. The missing surficial units may play a key role on groundwater recharge and flow.

Information Request:

1. Update Figure 4 (Appendix M) (i.e. the map of surficial geology of the project site and, at a minimum, the area of the drawdown cone and its perimeter). Based on the updated figure, make necessary changes to the discussion and analysis in subsequent sections of the EIS and supporting documents.
2. Update conceptual model, groundwater recharge, flow model, etc. based on the revised surficial geology information.

IR-1 Reference #: GW(1)-09
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Groundwater Quantity
Reference to EIS Guidelines: Section 9.1.2
Reference to EIS: Appendix M, Sections 3.2, 5.1.3, 5.3.5, Figure 9, Table 8
Summary of Comment/Rationale: In Appendix M, an estimate that recharge rate equals the minimum daily flow is used. This is an extreme value and corresponds to extreme minimal recharge. It would be preferable to use the average minimum daily flow over a period of 7 days or more and to calculate the base flow, thus providing minimum and maximum recharge values. In section 5.3.5 (Appendix M), the HELP model was used to calculate infiltration through the tailings management area. This model could also be used to validate the recharge estimated, based on streamflow data. The recharge rates were not included in the model sensitivity analysis. A discussion of the source of these values, justification for their applicability, evidence that they are conservative, and an assessment of model sensitivity to these values are requirements of the effects assessment.

Information Request:

1. Calculate the average minimum daily flow over a period of 7 days and the base flow at the gauging stations in order to obtain minimum and maximum recharge values. Validate these results using the HELP model.
2. Update Figure 9 (Appendix M) and add the drainage area for each station and the value of the base flow in m³/d.
3. Update the groundwater flow model and results with the recharge values obtained.
4. Adjust the recharge values in Table 8 (Appendix M) based on the updated surficial geology map, justify their applicability, provide evidence that they are conservative and assess the hydrogeological models sensitivity to these values.

IR-1 Reference #: GW(1)-10
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Groundwater Quantity
Reference to EIS Guidelines: Section 9.1.2
Reference to EIS: Appendix M, Section 5.1
Summary of Comment/Rationale: In the numerical groundwater flow model, the hydraulic conductivity (K) of the fault is lower than that of the surrounding rocks, which is unexpected. Evidence supporting this value is needed.

Information Request:

1. Explain why the hydraulic conductivity of the fault is lower than that of the surrounding rocks.

IR-1 Reference #: GW(1)-11
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Groundwater Quantity
Reference to EIS Guidelines: Section 9.1.2
Reference to EIS: Appendix M, Figure 14
Summary of Comment/Rationale: The hydraulic conductivity (K) values of the groundwater model presented in Figure 14 (Appendix M) could be more variable for depths 0-100 m. For the first 100 m, it is unclear whether this variability of K values been considered in the sensitivity analysis.

Information Request:

1. Discuss variability of K values for the first 100 m in the sensitivity analysis.

IR-1 Reference #: GW(1)-12
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Groundwater Quantity
Reference to EIS Guidelines: Section 9.1.2
Reference to EIS: Appendix M, Figure 17
Summary of Comment/Rationale: Figure 17 (Appendix M), which presents the results of the model calibration, does not show the location of the wells. Although the bias is low, it is not possible to interpret the spatial trends without identifying/labelling the wells.

Information Request:

1. Add and label the wells in Figure 17 (Appendix M) and discuss the spatial trends of the residuals.
2. Provide a plot of the mean value of the residuals (measured minus simulated values) and the mean of the residuals in absolute value in the graph.

IR-1 Reference #: GW(1)-13
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Groundwater Quantity
Reference to EIS Guidelines: Section 9.1.2
Reference to EIS: Appendix M, Figure 19
Summary of Comment/Rationale: For a better understanding and assessment of the groundwater model and its calibration, Figure 19 (Appendix M) should show all the gauging stations.

Information Request:

1. Include all gauging stations at which base flow is affected by the Project in Figure 19 (Appendix M), namely those within the drawdown area. Readjust the limits (minimum and maximum base flow) according to the revised information.

IR-1 Reference #: GW(1)-14
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Groundwater Quantity
Reference to EIS Guidelines: Section 10, 11
Reference to EIS: Appendix M, Figure 2
Summary of Comment/Rationale: Figure 2 (Appendix M) shows that the waste rock storage area (WRSA) rests partly on bedrock outcrops and thin deposits, which can allow and even promote vertical migration of potential contaminants in several parts of the project site. The proponent needs to explain how vertical infiltration from the WRSA will be controlled. For example, whether the bottom of the WSRA will be covered with a clay layer or an impermeable material.

Information Request:

1. Explain how vertical infiltration from the WSRA will be controlled.

IR-1 Reference #: GW(1)-15
Links to Annexes A3 and A4: PC(1)-22; PC(1)-32; PC(1)-33; PC(1)-34; AC(1)-14; AC(1)-15; AC(1)-400
s.5 Effect/Valued Component/EA Item: Groundwater Quantity
Reference to EIS Guidelines: Section 10, 11, 12
Reference to EIS: Appendix M, Section 5.3.3, Figures 20, 21
Summary of Comment/Rationale: While the proposed groundwater monitoring locations appear reasonable, additional groundwater monitoring locations will be required to provide an adequate groundwater monitoring network. It does not appear as though any domestic use wells were included in the groundwater monitoring program. Wells of interest surrounding the Project should be considered for inclusion in the groundwater monitoring quality and level monitoring programs. Figures 20 and 21 show that several wells will be affected by drawdown due to mine dewatering. The proponent has not explained whether it would remediate any damage that these activities could cause to individual wells (water level and quality). Mitigation measures will have to be planned for all wells, regardless of their context. Additionally, the impact of drawdown on streams is unclear. The requested information will also be required in complete detail during the provincial permitting phase when applying for required Permits to Take Water.

Information Request:

1. Include surrounding domestic use wells in the groundwater monitoring program, upon receiving permission from the well owners.
2. Describe mitigation measures for the wells affected by dewatering of the pit.
3. Replace the basemap in Figures 20 and 21 with the revised surficial geology map requested in GW(1)-09.
4. Describe and quantify the impact of drawdown relative to total and base flows.
5. Describe the impact of drawdowns on streams in the LSA.

IR-1 Reference #: GW(1)-16
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Groundwater Quantity
Reference to EIS Guidelines: Section 11
Reference to EIS: EIS Section 13.6.2; Figure 13.6.1
Summary of Comment/Rationale: According to section 13.6.2 (EIS), monitoring well locations will be determined on the basis of flow directions provided by the model. If the adjustments to the model suggest a different flow pattern, the monitoring program will have to be adjusted accordingly. For effective adjustment, the well network must cover all possible flow directions. However, the locations of monitoring wells down gradient of the low-grade stockpile have not been proposed. It is recommended that the monitoring program be designed to detect all changes in direction of lateral and vertical flow, even after mine decommissioning, until water quality parameters have returned to baseline conditions.

Information Request:

1. Revise the monitoring program to detect all changes in direction of lateral and vertical flow, even after mine decommissioning, until water quality parameters have returned to baseline conditions.

IR-1 Reference #: GW(1)-17
Links to Annexes A3 and A4: PC(1)-06; PC(1)-33; AC(1)-400; AC(1)-408
s.5 Effect/Valued Component/EA Item: Groundwater Quantity
Reference to EIS Guidelines: Section 10, 11
Reference to EIS: Appendix M, Section 5.3.5
Summary of Comment/Rationale: The current groundwater flow model predicts potential tailings management area (TMA) and waste rock storage area (WRSA) seepage to receiving environments. Given that it is highly likely that the seepage will be contaminated, it is recommended that the proponent monitor groundwater and develop a plan to collect groundwater that will not be intercepted by the drainage ditches a short distance from the TMA and WRSA, should it exceed provincial water quality limits. It is recommended that monitoring wells be installed all around the facilities and in each aquifer to confirm the direction of migration of potential contaminants.

Information Request:

1. Provide additional detail for the groundwater monitoring program to detect exceedances of water quality standards in the direction of flow from structures and provide a mitigation/contingency plan in the event of exceedances to prevent the spread of contaminants to receiving environments.

IR-1 Reference #: GW(1)-18
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Groundwater Quantity
Reference to EIS Guidelines: Section 10
Reference to EIS: Appendix M, Figure 4
Summary of Comment/Rationale: A large part of the project site is overlain by lacustrine clay. In this context, groundwater drawdown is known to cause significant ground settlement and can affect mine infrastructures.

Information Request:

1. Identify potential areas and extent of ground settlement within the project area.
2. Indicate areas at risk of damage due to ground settlement caused by groundwater drawdown due to mine dewatering and propose mitigation measures, as required.

IR-1 Reference #: GW(1)-19
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Groundwater Quantity
Reference to EIS Guidelines: Section 9.1.2
Reference to EIS: Appendix M, Section 5
Summary of Comment/Rationale: The uncertainty of the groundwater flow model is associated with hydraulic parameters such as hydraulic conductivity and recharge, but also with the selected conceptual geological model.

Information Request:

1. Review and revise the groundwater flow model results and sensitivity and the discussion on the basis of the corrected information.
2. Incorporate the revised groundwater flow model in the follow-up program. Review the model simulation results annually and adjust the groundwater quality and level monitoring plan, as required.

IR-1 Reference #: GW(1)-20
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Groundwater Quantity
Reference to EIS Guidelines: Section 10
Reference to EIS: Appendix M, Figures 24, 25
Summary of Comment/Rationale: The particle-tracking results in Figures 24 and 25 (Appendix M) show the possible migration pathways of potential contaminants. However, it is not possible to identify the aquifer through which the water flows, or the travel time toward receiving environments. It is unclear whether all wells identified on the map are part of the monitoring program that will be implemented during the mine activities and at the time of mine decommissioning.

Information Request:

1. Indicate the aquifer through which the water flows and the travel time towards the receiving environments for Figures 22 to 25 (Appendix M).
2. Identify the wells that are part of the monitoring program to be implemented during the mining activities and at the time of mine decommissioning.

IR-1 Reference #: GW(1)-21
Links to Annexes A3 and A4: AC(1)-07; AC(1)-24; AC(1)-391
s.5 Effect/Valued Component/EA Item: Groundwater Quantity; Migratory Birds; Species at Risk; Wetlands
Reference to EIS Guidelines: Section 5, 9.1.2, 10
Reference to EIS: EIS Section 6.2.1.12; Appendix G Section 9.3.6.1; Appendix F of Appendix M Figure 1; Appendix S; Table 3.4
Summary of Comment/Rationale: The proponent states in section 6.2.1.12 (EIS): "Makeup water may be required for operation of the processing plant and may be obtained from groundwater wells or via pipeline from the old tree nursery irrigation ponds located on the Hoffstrom's Bay tributary on the Treasury offices site which has potential to reduce water quantity and, indirectly, habitat quality." No details are provided on these withdrawals. The hydrogeology of the project area as shown in Figure 1 (Appendix F of Appendix M) includes a portion of Lola Lake Provincial Park, which is an extensive wetland area. Section 9.3.6.1 (Appendix G) states: ".it [Lola Lake Wetland] likely provides the area with significant ecological functions such as groundwater discharge, wildlife habitat and carbon storage (Harris pers. comm. 2011). The presence of iron precipitates (Appendix VII-2, Plate 11) and rich minerotrophic indicators including sticky tofieldia (Triantha glutinosa), tufted clubrush (Trichophorum cespitosum), and creeping juniper (Juniperus horizontalis) indicates that there is a strong flow of nutrient rich groundwater from the peatland (NE to SW) into the ponds at the tree nursery grounds and eventually into Thunder Lake." In addition, Table 3.4 (Appendix S, page 17) indicates the olive sided flycatcher, a migratory bird and threatened species at risk, was identified in the portion of Lola Lake Provincial Park wetland area adjacent to the irrigation ponds. The potential environmental effects on the wetland area from the groundwater withdrawals are unclear.

Information Request:

1. Provide information on makeup water withdrawals: quantity, location of withdrawal sites, and impact on groundwater (drawdown).
2. Based on the information gathered for WL(1)-03 and request A above, reassess and describe the potential effects and any residual effects from groundwater drawdown on wetlands, including the Lola Lake Provincial Park wetlands, adjacent to the irrigation ponds, considering the magnitude, extent, duration, frequency, reversibility criteria to determine significance of adverse environmental effects.

IR-1 Reference #: GW(1)-22
Links to Annexes A3 and A4: AC(1)-366; AC(1)-401
s.5 Effect/Valued Component/EA Item: Groundwater Quantity
Reference to EIS Guidelines: Section 9
Reference to EIS: EIS Section 6.3.1.10
Summary of Comment/Rationale: Section 6.3.1.10 (EIS) states: "Previous assessment of surface water hydrology in the watersheds surrounding the proposed mine development area have found that aquifer discharge provides for a negligible amount of creek base flow so depression of the groundwater surface would likely not impact the surface water regime to any significant extent." This statement may need to be modified based on the information and model updates that may result from the proponent's response to IRs on groundwater and surface water.

Information Request:

1. Analyze the impacts to the surface water regime, based on responses to IRs on groundwater and surface water, and update the effects assessment accordingly.

IR-1 Reference #: GW(1)-23
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Groundwater Quantity
Reference to EIS Guidelines: Section 5, 10, 11
Reference to EIS: EIS Sections 11.2.2, 11.4.3
Summary of Comment/Rationale: The details of the source of the groundwater (an estimated 524 233 m³/year, approximately 1 436 255 L/day) to be used for enhanced pit flooding are not provided in section 11.2.2 (EIS). Section 11.4.3 (EIS) mentions that pit filling will be augmented by other groundwater/surface water sources, but no details regarding these sources are provided. The requested information will also be required in complete detail during the provincial permitting phase when applying for required PTTWs.

Information Request:

1. Discuss the source of groundwater to be used for enhanced flooding of the pit and any associated effects and required mitigation measures related to groundwater quality and quantity.

SURFACE WATER QUALITY AND QUANTITY

IR-1 Reference #: SW(1)-01
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Surface Water Quality
Reference to EIS Guidelines: Section 9.1.2
Reference to EIS: EIS Sections 3.5.1-3.5.3, 3.8.4, 3.8.8
Summary of Comment/Rationale: In sections 3.5.1 to 3.5.3 (EIS), the proponent has indicated that ditching and seepage collection will be installed around the edges of the mine rock, overburden, low grade ore and other stockpiles. However, no design details are provided. It is not clear how deep the ditches will be, and whether or not they will be dug to bedrock. This information is important in order to understand the effectiveness of the collection system, especially with respect to seepage. Section 3.8.8 (EIS) states that surface water runoff (SWR) from site (rain) is not expected to require treatment. Limited information is given regarding how SWR will be diverted from the site. If SWR were to combine with seepage then it would likely require treatment. Ditches and SWR are not shown in Figure 3.8.4 (EIS, page 3-54) as referenced in section 3.8.8 (EIS). In addition, the proponent has not indicated to where this surface water runoff will discharge. It is important to know whether this SWR will also be discharged to Blackwater Creek and where with respect to the other final discharge point as it could have both an individual and a combined impact on Blackwater Creek. Further information is also required to determine whether this point of discharge will be considered as another final discharge point under the MMER. The proponent states in 3.8.4 (EIS) that "freshwater may also be required for truck wash facilities within the maintenance facilities and dust control during summer open pit operations. This water used for these purposes is anticipated to be sourced from any supplemental mine water runoff that does not require further treatment for use." If this is the case, it is unclear how the water will be segregated and its suitability for these purposes will be determined. The proponent should provide a figure showing all ditches to be installed on the project site in order to ensure that mine contact water will be collected for treatment and that surface drainage will be diverted to avoid contamination.

Information Request:

1. Confirm whether there is one drainage ditch to collect both surface water runoff and seepage or two separate ditches. If runoff and seepage are combining in a shared ditch, provide methodology and rationale for determining whether treatment is needed. Describe the contingency measures to be put in place in cases where water quality exceeds the standards.
2. Provide a figure showing all drainage ditches (runoff and seepage collection) to be installed on the project site.
3. Provide a description of these drainage and seepage collection ditches, including but not limited to, their design capacity and where the water and/or effluent collected by each of the drainage and seepage collection ditches will be deposited.
4. Confirm to where the surface water runoff will be discharged.
5. Provide methodology for determining that mine water is suitable for additional purposes such as washing trucks and dust control or general discharge into the environment.

IR-1 Reference #: SW(1)-02
Links to Annexes A3 and A4: AC(1)-372; AC(1)-389
s.5 Effect/Valued Component/EA Item: Surface Water Quality
Reference to EIS Guidelines: Section 9.1.2
Reference to EIS: EIS Section 4.3.2.2
Summary of Comment/Rationale: Section 4.3.2.2 (EIS) indicates: "The ditches will be lined to ensure that seepage is contained within the ditch and that erosion damage does not occur. " The proponent needs to explain what will be used to line the ditches and whether all ditches on the project site will be lined.

Information Request:

1. Describe how the perimeter seepage collection ditches for the tailings storage facility will be lined and indicate whether all ditches on the project site will be lined.

IR-1 Reference #: SW(1)-03
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Surface Water Quality
Reference to EIS Guidelines: Section 9.1.2
Reference to EIS: EIS Figures 3.8.3, 3.8.4
Summary of Comment/Rationale: Figure 3.8.3 (EIS, page 3-49) shows the leachate and runoff from the waste rock pile collection pond discharging into the low grade ore stockpile collection pond for leachate and runoff. However, in Figure 3.8.4 (EIS, page 3-54), there is no connection between the water output from the waste rock storage collection pond and the low-grade stockpile collection pond. A good understanding of how mine water is conveyed between the different water management structures is essential to ensure that mine water is being treated and has no significant impact to water quality.

Information Request:

1. Confirm and describe how leachate and runoff is conveyed from the waste rock pile collection pond and the low grade ore stockpile collection pond and provide figures to further describe mine water conveyance.

IR-1 Reference #: SW(1)-04
Links to Annexes A3 and A4: AC(1)-372
s.5 Effect/Valued Component/EA Item: Surface Water Quality
Reference to EIS Guidelines: Section 9.1.2
Reference to EIS: Appendix F, Sections 2.1.6, 4.1.1
Summary of Comment/Rationale: Section 4.1.1 (Appendix F) states: "Based on geochemistry test work, it is assumed that all runoff water from the Goliath site will potentially be acidic and contain at least trace amounts of dissolved metals." However, section 2.1.6 (Appendix F) indicates: "Surface water runoff from the processing plant site is not expected to require treatment. In the future, provision could be made for containment and pumping of the contaminated surface water to the tailings storage facility using a portable pumpBy design, plant site surface water will drain into the surrounding terrain and ultimately to Blackwater Creek." The two sections appear to contradict each other. An explanation is required from the proponent as to why surface water runoff from the processing plant site does not need to be collected and treated.

Information Request:

1. Explain the predicted quality of surface water runoff from the processing plant site with a rationale as to why it will not require collection and treatment.
2. Indicate how this surface water runoff will be monitored to determine if it can be released into the receiving environment.
3. Describe the contingency measures, should surface water runoff not meet water quality standards.

IR-1 Reference #: SW(1)-05
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Surface Water Quality
Reference to EIS Guidelines: Section 9.1.2
Reference to EIS: Appendix M, Section 5.3.5
Summary of Comment/Rationale: Seepage has been predicted from the tailings management area and the waste rock storage area in Section 5.3.5 (Appendix M). However, it appears that seepage has not been predicted for the overburden stockpile and the low-grade ore stockpile.

Information Request:

1. Confirm whether seepage has or has not been predicted for the overburden and low-grade ore stockpiles. If seepage has not been predicted from these stockpiles, provide an explanation as to how this conclusion was drawn. If it has been predicted, describe the potential effects and mitigation measures that would be applied.

IR-1 Reference #: SW(1)-06
Links to Annexes A3 and A4: AC(1)-389
s.5 Effect/Valued Component/EA Item: Surface Water Quality
Reference to EIS Guidelines: Sections 9.1.2, 10.1.2
Reference to EIS: Appendix M
Summary of Comment/Rationale: The proponent has estimated seepage volumes, but has not determined the potential effects of seepage upon the surface water quality of nearby waterbodies. Such an assessment should consider the estimated seepage volumes that will report to surface waters and the concentrations of contaminants of concern it is predicted to contain over time.

Information Request:

1. Assess the potential effects of seepage upon surface water quality during operations and through the abandonment phase.

IR-1 Reference #: SW(1)-07
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Surface Water Quality
Reference to EIS Guidelines: Section 9.1.2
Reference to EIS: EIS Section 2.3.2
Summary of Comment/Rationale: Section 2.3.2 (EIS) indicates that residual hydrocarbons will be removed in sumps. The proponent has not explained how this would be achieved in the sumps. If not removed, residual hydrocarbons have the potential to lead to adverse effects on water quality and ultimately fish and fish habitat.

Information Request:

1. Explain how residual hydrocarbons will be removed in sumps (in pit or underground).

IR-1 Reference #: SW(1)-08
Links to Annexes A3 and A4: AC(1)-303
s.5 Effect/Valued Component/EA Item: Surface Water Quality
Reference to EIS Guidelines: Section 9.1.2
Reference to EIS: EIS Section 3.3.2
Summary of Comment/Rationale: Section 3.3.2 (EIS) indicates that surface water runoff will be prevented from entering the open pit by means of a small berm or ditch and that the water will be collected to form part of the recycled water used for processing in the plant facility. This small berm or ditch is not shown in any of the figures and the proponent does not indicate where this water will be collected.

Information Request:

1. Provide a figure showing the small berm or ditch around the open pit and indicate where the surface water runoff will be collected.

IR-1 Reference #: SW(1)-09
Links to Annexes A3 and A4: AC(1)-14; AC(1)-364
s.5 Effect/Valued Component/EA Item: Surface Water Quantity
Reference to EIS Guidelines: Section 9.1
Reference to EIS: Appendix F, Sections 1.3, 2.0, 2.3; EIS Section 3.8.5
Summary of Comment/Rationale: The proponent has conducted a preliminary site water balance based on a yearly average assessment (Appendix F). The preliminary assessment indicates a positive water balance, where excess water is anticipated for average years and that excess water will be continually treated via an effluent treatment plant. The proponent also states that a further study that considers seasonal variations and storm event variations will be required in subsequent stages of the Project. Effluent discharges are expected to vary throughout the year, with the highest discharge occurring during spring thaw. Extremely wet or dry year scenarios resulting from climate variability are not considered in the calculations. Considerations of extreme climate conditions are important to assess infrastructure requirements and consideration of mitigation measures in case of extreme excess or shortage of water during mine operations. The proponent should comment on measures that would be considered if, during a dry period, there is not enough water cover over the tailings to minimize acid generation of the tailings solids. On the other hand, the maximum operating level of the tailings storage facility (TSF) is said to be set to contain runoff from average and wet precipitation conditions. An additional containment storage volume will be provided based on the Environmental Design Storm (1000-yr event). The ability to remove excess water in a timely manner to maintain the maximum operational level and to maintain the 1000-yr storage above seems to be governed by the effluent treatment plant capacity. Should wet conditions prevail during mine operation, it is unclear whether there is any ability to increase the effluent treatment rate to prevent excess water from accumulating in the TSF. Evaluation of wet year precipitation conditions and consideration of seasonal variation are critical to the preliminary design.

Information Request:

1. Elaborate on the adequacy of the TSF sizing, effluent treatment rate selected, and possible mitigation measures in consideration of natural variation in weather conditions, including seasonal variations.

IR-1 Reference #: SW(1)-10
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Surface Water Quality
Reference to EIS Guidelines: Section 9.1.2
Reference to EIS: EIS Section 3.5.3
Summary of Comment/Rationale: Section 3.5.3 (EIS) indicates that there may be several smaller runs of mine piles of varying grade in the general area of the low–grade stockpile. The proponent has not indicated whether these piles will be within the ditching and seepage collection of the low-grade stockpile. If these runs of mine piles are not within the ditching and seepage collection of the low-grade stockpile, surface water runoff may be contaminated and could impact water quality.

Information Request:

1. Confirm whether the smaller runs of mine stockpiles are within the ditching and seepage collection area of the low-grade stockpile.
2. Describe how surface water runoff will be collected, seepage will be controlled and provide mitigation measures for the additional stockpiles if they are not located within previously described ditching and seepage collection areas.

IR-1 Reference #: SW(1)-11
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Surface Water Quality
Reference to EIS Guidelines: Section 9.1.2
Reference to EIS: EIS Sections 3.6.2, 3.6.4
Summary of Comment/Rationale: Section 3.6.2 (EIS) and section 3.6.4 (EIS) mention an emergency stockpile but no further information is provided about this stockpile.

Information Request:

1. Clarify the purpose of this emergency stockpile, its location, size, potential to leach contaminants of concern and any measures that would be implemented to collect and contain effluent (seepage and runoff) so its flow and quality can be measured via a final discharge point prior to its release to the receiving environment.
2. Provide the location of the final discharge point for the emergency stockpile and describe potential impacts on the environment resulting from discharge.

IR-1 Reference #: SW(1)-12
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Surface Water Quality
Reference to EIS Guidelines: Section 9.1.2
Reference to EIS: EIS Figure 3.8.2; Appendix F Figure 2-2
Summary of Comment/Rationale: The direct pond precipitation values in Figure 3.8.2 (EIS, page 3-47) are different from the net precipitation value presented in Figure 2-2 (Appendix F, page 10).

Information Request:

1. Clarify the difference between the direct pond precipitation values in Figure 3.8.2 (EIS, page 3-47) and the net precipitation value presented in Figure 2-2 (Appendix F, page 10).

IR-1 Reference #: SW(1)-13
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Surface Water Quality
Reference to EIS Guidelines: Section 9.1.2
Reference to EIS: EIS Table 3.8.3
Summary of Comment/Rationale: Table 3.8.3 (EIS, page 3-50) shows the predicted tailings supernatant concentration for Ammonia (as N) with an asterisk, which means "Assumed Values". The proponent should explain what is meant by assumed values. Furthermore, there is a second note with two asterisks, which means "At least one value used in determination was based on limit of detection". The proponent should explain what is meant by this note and to which parameter(s) this note refers.

Information Request:

1. Explain what is meant by "Assumed Values" for Ammonia (as N) in Table 3.8.3.
2. Explain what is meant by "At least one value used in determination was based on limit of detection" in Table 3.8.3 and indicate which parameter(s) are referred to in the statement.

IR-1 Reference #: SW(1)-14
Links to Annexes A3 and A4: AC(1)-124; AC(1)-306
s.5 Effect/Valued Component/EA Item: Surface Water Quality
Reference to EIS Guidelines: Section 9.1.2
Reference to EIS: EIS Table 3.8.3; Appendix F Sections 4.4, 4.5, Table 4.3
Summary of Comment/Rationale: Table 3.8.3 (EIS, page 3-50) is identical to Table 4.3 (Appendix F, page 24). Section 4.4 (Appendix F) explains that a PHREEQCI model was used to predict preliminary and conservative concentrations for contaminants in the tailings storage facility (TSF) solution and the model is based on previously discussed yearly average water balance and geochemical test work performed by Ecometrix. It further states: "Neither cyanide destruction nor tailings attenuation test work have been performed to date and therefore assumptions have been made based on industry standards". The proponent should indicate what industry standards have been used to make the assumptions. In the MEND Report 3.50.1 - Study to Identify BATEA for the Management and Control of Effluent Quality from Mines, page 323 identifies some challenges associated with the INCO SO2/Air process. In particular, it notes that: Addition of copper catalyst may cause non-compliance with copper limit if not adequately precipitated and separated from effluent; Generation of sulfate may be undesirable, depending on downstream processes or receiving bodies; and Generation of ammonia may cause non-compliance with potential future ammonia limit as well as toxicity issues if not managed. The proponent should indicate whether the increase in copper, sulfate and ammonia into the predicted tailings supernatant concentrations was factored in the data in Table 3.8.3.

Information Request:

1. Identify the industry standards which have been used to make the assumptions about cyanide destruction and tailings attenuation.
2. Explain whether the increase in copper, sulfate and ammonia from the INCO SO2/Air process has been factored into the predicted tailings supernatant concentrations in Table 3.8.3 (EIS). If they have not, justify this decision.

IR-1 Reference #: SW(1)-15
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Surface Water Quality
Reference to EIS Guidelines: Section 9.1.2
Reference to EIS: EIS Section 5.8.1, Table 5.8.2
Summary of Comment/Rationale: Table 5.8.2 (EIS, page 5-58) shows total suspended solids (TSS) as one of the conventional parameters that were measured in 2010/2011 and 2012/2013. However, the 3rd paragraph of section 5.8.1 (EIS) indicates that total dissolved solids (TDS) were measured. The proponent should clarify whether TSS or TDS was measured.

Information Request:

1. Clarify whether TSS, TDS or both parameters were measured in 2010/2011 and 2012/2013.

IR-1 Reference #: SW(1)-16
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Surface Water Quality
Reference to EIS Guidelines: 10.1.2
Reference to EIS: EIS Table 6.4.2
Summary of Comment/Rationale: Table 6.4.2 (EIS) under the potential effects states: "Increased flows in Blackwater Creek in years 1 -3 due to increases in the runoff coefficient of developed areas and discharge from the secondary treatment plant, including mine dewatering and process water" and under the column labeled magnitude it states "No surface water quantity effects in receiving waters anticipated as flow changes are within natural variation and channel capacity"; This information is not consistent as the plant is estimated to discharge 1900-1400 m³/d over and above the natural flow, which is outside of the natural variation.

Information Request:

1. Quantify the base flow requirements in Blackwater Creek.
2. Describe the methods used and provide the results of hydrologic modelling to determine effects to Blackwater Creek as a result of variable flow rates throughout all project phases.
3. Clarify whether Blackwater Creek will have to handle more water than it currently does. If so, describe the possible impacts (i.e. erosion of the stream banks and sediment running downstream) and indicate how these impacts will be mitigated.
4. Provide a description of the proposed monitoring plan for Blackwater Creek, including monitoring parameters, methods, sampling locations, applicable standards, duration and frequencies. These plans should clearly outline action levels that may trigger certain mitigations.

IR-1 Reference #: SW(1)-17
Links to Annexes A3 and A4: PC(1)-07; AC(1)-19; AC(1)-322; AC(1)-324; AC(1)-387
s.5 Effect/Valued Component/EA Item: Surface Water Quality
Reference to EIS Guidelines: Section 9.1.2
Reference to EIS: EIS Section 6.2.1.8; Appendix C of Appendix F Section 5.5
Summary of Comment/Rationale: It is unclear whether the open pit will be filled with treated effluent, surface runoff from the developed areas, water from the dewatering activities in the underground stopes, or a combination of these. Section 6.2.1.8 (EIS) indicates that during the development of the underground mine in years 4 to 12, the treated effluent will be directed to the open pit and total runoff in the Blackwater Creek will be reduced as surface runoff from the developed areas will be collected, treated, and discharged to the pit lake rather than to Blackwater Creek. However, in Appendix C of the Water Management Plan (Appendix F), it is indicated that the water from the dewatering activities in the underground stopes will be used to fill the pit and that the quality of this water is assumed to be the same as pit run-off water. Additional leaching or dissolution from the pit walls is assumed to cease once the pit wall is submersed. Therefore, the water quality within the pit lake is equivalent to the long term water quality of the underground seepage, which is very similar to the long term waste rock storage facility (WRSF) run-off. Without the inclusion of secondary reactions, it follows that the water quality within the pit lake will remain constant over time and after decommissioning, and will be roughly equivalent to the long term water quality of the waste rock run-off. The proponent should provide information on secondary reactions that could occur in the pit lake to alter its water quality, including a discussion of the magnitude, duration, and likelihood of these reactions and their potential to lead to significant adverse effects in the receiving environment downstream of the open pit.

Information Request:

1. Provide clarification on the method and source of water to be used to fill the open pit.
2. Provide information on any secondary reactions that could occur in the pit lake to alter its water quality. Describe the potential for significant adverse effects in the receiving environment downstream of the open pit resulting from secondary reactions and propose mitigation measures to address such effects.

IR-1 Reference #: SW(1)-18
Links to Annexes A3 and A4: PC(1)-13; AC(1)-09; AC(1)-307; AC(1)-309; AC(1)-314
s.5 Effect/Valued Component/EA Item: Surface Water Quality
Reference to EIS Guidelines: Section 9.1.2
Reference to EIS: EIS Section 3.8.7, Table 3.8.3
Summary of Comment/Rationale: Section 3.8.7 (EIS) identifies reverse osmosis (RO) as the proposed method for treating the mine contact water from the tailings storage facility to achieve provincial water quality objectives (PWQO) values prior to its discharge into Blackwater creek. The Agency is not aware of any current use of RO systems to treat effluent from existing metal mines. The following is a link to a report that was published September 2014 by the Mine Environment Neutral Drainage (MEND) program: http://mend-nedem.org/wp-content/uploads/MEND_3.50.1_BATEA.pdf. A review of RO can be found from pages 363 to 369 which points to a limited amount of full-scale experience with this technology in mine effluent treatment applications and the high capital and operating costs associated with the technology. The proponent must provide examples and evidence of where RO systems have been used to treat effluent to PWQO or better values that has similar characteristics and volumes as predicted for the Project, especially since Table 3.8.3 (EIS, page 3-50) shows several parameters (aluminum, cadmium, copper, iron, mercury, phosphorus, thallium, and zinc) in the predicted tailings supernatant to exceed PWQOs and/or Canadian Water Quality Guidelines (CWQGs). Furthermore, the proponent should: consider the feasibility of using such a treatment system beyond the intended effluent treatment time if such measures are deemed necessary based on water quality at this time; explain how treatment would occur and what would be the effectiveness of the measure if this was deemed necessary due to water quality changes 20 years into the abandonment phase; identify whether it will be necessary to remineralize the purified water before discharging it into the environment; and describe and provide a quantitative analysis of the need for remineralization and the remineralization process.

Information Request:

1. Provide examples and evidence of where RO systems have been used to treat effluent to PWQO, CWQG or better values that has similar characteristics and volumes as predicted for the Project.
2. Describe the feasibility (economic and practical) of using the RO treatment system and the intended effluent treatment time if such measures are deemed necessary based on monitoring results.
3. Describe conditions (e.g. water quality exceedances) that would trigger the need to treat runoff and seepage into the abandonment phase.
4. If purified water requires remineralization prior to being discharged into the environment provide quantitative analysis and justification of the remineralization process.

IR-1 Reference #: SW(1)-19
Links to Annexes A3 and A4: PC(1)-02; AC(1)-322; AC(1)-324; AC(1)-348; AC(1)-392; AC(1)-419; AC(1)-438
s.5 Effect/Valued Component/EA Item: Surface Water Quality
Reference to EIS Guidelines: Sections 6.4, 9.1.2
Reference to EIS: EIS Sections 6.4.1.8, 13.8.1;
Summary of Comment/Rationale: The description of the effluent discharge is unclear. The proponent states that treated water will initially be discharged into Blackwater Creek during the development of the open pits (years 1 to 3) which will result in slightly higher than natural flows, but that afterward there will be a reduction in Blackwater Creek flow from years 4 to 12 since the water/effluent will be redirected into the pit to accelerate filling. The way it is described it seems that there would be no effluent discharged to the environment after year 3. The proponent needs to clarify this. The proponent should note that if a mine has more than one final discharge point, effluent and water quality monitoring has to be conducted at all final discharge points. Effluent discharged into Blackwater Creek is eventually discharged into a section of Keplyn Bay that is transected by a Canadian Pacific Rail causeway. This section of the bay drains under the causeway via a set of three culverts into the main waterbody of Wabigoon Lake. The proponent should provide evidence that the three culverts are capable of handling effluent discharge volumes in addition to natural flow. If it will be necessary to modify the causeway to provide increased drainage the necessary modifications should be described.

Information Request:

1. Describe the effluent discharges that are planned throughout the life of the project over time and by project phase.
2. Provide predicted effluent chemistry for the point of discharge to Blackwater Creek. This should include, but not be limited to, metals, sulphate and general chemistry parameters.
3. Confirm whether treated effluent will only be discharged into Blackwater Creek for 3 years (during the development of the open pits, years 1 to 3) and indicate where the final effluent will be discharging starting in Year 4.
4. Provide an effluent water quality monitoring plan that accounts for all final discharge points.
5. Provide evidence that the three culverts are capable of handling effluent discharge volumes in addition to natural flow. Describe the necessary modifications, if it will be necessary to modify the causeway to provide increased drainage.

IR-1 Reference #: SW(1)-20
Links to Annexes A3 and A4: AC(1)-365; AC(1)-422; AC(1)-423; AC(1)-440
s.5 Effect/Valued Component/EA Item: Surface Water Quality
Reference to EIS Guidelines: Section 12
Reference to EIS: Table 12.4.1
Summary of Comment/Rationale: The proponent only provides a general statement in regards to the surface water quality monitoring program that they will undertake during pre-development to abandonment. They do not provide any specific parameters or frequency of sampling in the information that has been presented. Water quality monitoring for environmental effects monitoring (EEM) under the MMER is only conducted at an exposure and reference area for each discharge point, thus not all receivers listed would be monitored as part of the MMER. For environmental assessment (EA) purposes, a certain amount of detail should be provided on monitoring programs that form the basis of EA follow-up. While the specifics of monitoring protocols can be developed at a later stage, a robust framework for the follow-up should be described. The ability to monitor for and adaptively manage against adverse water quality impacts before they become significant is a key factor in managing to reduce the potential for significant adverse environmental effects. Given the amount of potentially acid generating material associated with the site and the potential for significant impacts to water quality through acid rock drainage/metal leaching, the ability to detect and manage impacts to water quality is important. The surface water quality monitoring framework should include but not be limited to: the valued components of concern for follow-up on water quality changes, rationale for inclusion of water quality monitoring, potential adaptive management measures to consider if monitoring results indicate or forecast the occurrence of adverse effects, the regulatory instruments that relate to this aspect of the follow-up program and responsibilities for producing, reviewing and making decisions on the information that is produced.

Information Request:

1. Provide a framework that can be used to develop the water quality aspects of the follow-up monitoring program for the Project.

IR-1 Reference #: SW(1)-21
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Surface Water Quality
Reference to EIS Guidelines: Section 12
Reference to EIS: Table 12.4.2
Summary of Comment/Rationale: For the monitoring of total suspended solids (TSS) and turbidity, the proponent only specifies that this will be monitored downstream of active construction areas, however, higher flows are predicted into Blackwater Creek that also have the potential to contribute TSS and increase turbidity in the downstream through the process of erosion. As such, it is recommended that the proponent develop plans to monitor, and, if necessary, mitigate for impacts of these higher flows into Blackwater Creek.

Information Request:

1. Develop a plan to monitor TSS, turbidity, and erosion and if necessary, mitigate against the impact of higher flow rates into Blackwater Creek.

IR-1 Reference #: SW(1)-22
Links to Annexes A3 and A4: AC(1)-17; AC(1)-421
s.5 Effect/Valued Component/EA Item: Surface Water Quality
Reference to EIS Guidelines: Section 12
Reference to EIS: Table 12.4.2
Summary of Comment/Rationale: For water quality monitoring the proponent states that the various method detection limits for parameters will be to Canadian Council of Ministers of the Environment (CCME) standards. Environment Canada's target method detection limit (during environmental effects monitoring) for the sampling of total mercury in water quality and effluent quality is 0.00001 mg/L (0.01 µg/L), which is lower than that under CCME. Environment Canada recommends that the proponent use a method detection limit of 0.00001 mg/L (0.01 µg/L) for mercury as stated in the comments provided on the proponent's baseline report on May 21, 2014. Additional information is needed to assess the potential impact of mercury loadings to surface water receivers. This information should include, but not necessarily be limited to, consideration of the following: Establishing pre-development mercury loadings from the various watersheds; Estimating the potential concentrations of mercury within the final effluent and other associated drainages; The potential impact that increased sulphates may have on increasing the methylation rates; Potential mitigation measures to reduce the discharge of mercury from the site; The development of a monitoring plan that considers mercury in, at a minimum, the water column and fish tissue. Criteria should be developed that would trigger remedial measures; Data should be collected using advanced sampling and analytical protocols for mercury to define baseline conditions, determine potential loadings, and to monitor the potential impacts of the project over time.

Information Request:

1. Use a method detection limit of 0.00001 mg/L (0.01 µg/L) for mercury and revise water quality studies accordingly.
2. Provide additional information on the following to assess the potential impact of mercury loadings to surface water receivers: Establishing pre-development mercury loadings from the various watersheds; Estimating the potential concentrations of mercury within the final effluent and other associated drainages; The potential impact that increased sulphates may have on increasing the methylation rates; Potential mitigation measures to reduce the discharge of mercury from the site; The development of a monitoring plan that considers mercury in, at a minimum, the water column and fish tissue. Criteria should be developed that would trigger remedial measures; Data should be collected using advanced sampling and analytical protocols for mercury to define baseline conditions, determine potential loadings, and to monitor the potential impacts of the project over time.

IR-1 Reference #: SW(1)-23
Links to Annexes A3 and A4: PC(1)-09; PC(1)-35; AC(1)-16
s.5 Effect/Valued Component/EA Item: Surface Water Quality
Reference to EIS Guidelines: Sections 5.6, 7.1.2, 10.1.1, 11
Reference to EIS: Appendix F, Section 3.2.1
Summary of Comment/Rationale: The cyanide destruction circuit is anticipated to be designed to meet the Metal Mining Effluent Regulations (MMER) discharge limits at the point of discharge to the tailings storage facility (TSF). In the event that anticipated cyanide destruction cannot be attained in this manner, retention time of water in the TSF should be considered as a contingency for natural attenuation of cyanide in the TSF.

Information Request:

1. Provide an estimate of the retention time of TSF water and the anticipated effluent concentration and discharge rates as it relates to natural attenuation of cyanide for the purposes of a contingency for the cyanide destruction circuit.

IR-1 Reference #: SW(1)-24
Links to Annexes A3 and A4: AC(1)-292
s.5 Effect/Valued Component/EA Item: Surface Water Quality
Reference to EIS Guidelines: Section 10.1.2
Reference to EIS: Appendix F, Sections 4.1.1, 4.1.5
Summary of Comment/Rationale: Nutrients from blasting residue and from treated sewage wastewater (proposed to be discharged into the tailings pond) can potentially cause eutrophication within the tailings pond. Depending on the design of the effluent treatment system, this could potentially interfere with the functioning and effectiveness of the system. The proponent should assess the potential for eutrophication to occur within the tailings pond, and the problems that eutrophication may cause with the effluent treatment process and its ability to achieve provincial water quality objective values (as stated by the proponent) when discharging to the receiving environment. The assessment should consider potential loadings of nutrients into the tailings pond and whether these loadings pose a potential for eutrophication. If the potential for eutrophication is high, it is recommended that the proponent provide information concerning the implications this has for the performance of the effluent treatment system.

Information Request:

1. Assess the potential for eutrophication to occur within the tailings pond, and the problems that eutrophication may cause with the effluent treatment process and its ability to achieve provincial water quality objective values when discharging to the receiving environment.
2. Provide mitigation measures to ensure tailings pond effluent meets water quality standards in the event that eutrophication occurs.

IR-1 Reference #: SW(1)-25
Links to Annexes A3 and A4: PC(1)-05; AC(1)-24; AC(1)-372; AC(1)-387; AC(1)-389
s.5 Effect/Valued Component/EA Item: Surface Water Quality
Reference to EIS Guidelines: Sections 9.1.2, 10.1.2
Reference to EIS: Appendix F; Sections 4.4, 11, Table 4.3 F
Summary of Comment/Rationale: Although the proponent has committed to a collection system for their seepage, there will be a percentage of seepage that cannot be collected and will discharge to the watershed. Anticipated seepage water quality indicates that some contaminants of concern (COCs) will exceed provincial water quality objectives (PWQO) in the seepage from some mine facilities. Because the small tributaries within the project area have no assimilative capacity, seepage will be required to meet very stringent criteria at the point of discharge to surface waters (i.e., PWQO or background concentrations). The proponent will need to provide expected receiver loading calculations. Updated source concentrations and calculated discharge loadings to surface water receivers will need to be incorporated into the assessment to evaluate the impact to surface waters. Section 4.4 (Appendix F) states: "These concentrations, along with corresponding MMER and PWQO guidelines, are presented in Table 4.3 Predicted Tailings Storage Facility Supernatant Concentrations Based on Preliminary Data and Worst Case Assumptions." Table 4.3 (Appendix F) does not include PWQO criteria values as claimed in section 4.4. When comparing the values in the table to PWQO, concentrations of most COCs exceed or significantly exceed the criteria in this scenario.

Information Request:

1. Describe seepage water quality during operations, decommissioning and abandonment from the major mine features, including the pit lake, WRSA, TSF, and LGO stockpile, surface water impacts associated with explosives, and seepage loadings to receivers. Include conservative estimates of loadings to surface water, predicted effects to offsite surface water and feasible mitigation measures.
2. Quantify and assess potential impacts to surface water from the pit lake and TSF discharges. Provide a monitoring program and a contingency plan, and include trigger criteria and feasible mitigation and remediation measures.
3. Update Table 4.3 (Appendix F) to include PWQO criteria and discuss the significance of the PWQO exceedances in this scenario and the impact on TSF effluent treatment.

IR-1 Reference #: SW(1)-26
Links to Annexes A3 and A4: PC(1)-12; PC(1)-19; AC(1)-18
s.5 Effect/Valued Component/EA Item: Surface; Water Quantity; Groundwater
Reference to EIS Guidelines: Section 5
Reference to EIS: EIS Sections 3, 5
Summary of Comment/Rationale: There is considerable confusion and a number of inconsistencies in the EIS and appendices regarding where the proponent will source fresh water for mining operations. Studies outlining the ability of irrigation ponds and their tributaries (Lola Lake Nature Reserve) to supply needed water to the project site have not been conducted. The proponent states in section 3.8.3 (EIS) once operations commence an additional 600m³/d of fresh water will be required and will be taken from either underground wells or irrigation ponds. Section 3.8.4 (EIS) then states that the 600 m³/d will come from groundwater wells without mentioning ponds. Other sections of the EIS then suggest that additional mine processing water will be taken only from the irrigation ponds.

Information Request:

1. Conduct and provide surface water studies on Lola Lake Nature Reserve's ability to supply the appropriate amount of mine process water via Thunder Lake Tributary #3 without adversely affecting the wetland in the Nature Reserve.
2. Clearly describe all source(s) of mine processing water and include the justification for the assertion the sources are able and available to supply the demand. Update relevant sections of the EIS to provide consistency across sections.

IR-1 Reference #: SW(1)-27
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Surface Water Quantity
Reference to EIS Guidelines: Section 9.1
Reference to EIS: Appendix O, Sections 2.5, 3.4
Summary of Comment/Rationale: Many approaches have been used by the proponent to estimate the runoff coefficient. The runoff coefficients estimated from the measured data (Table 2-10, Appendix O, page 15) range from 0.04 (station HS5) to 0.65 (station HS4). The runoff coefficients estimated using the Ontario Ministry of Transportation (MTO) Northern Ontario Hydrology Method (NOHM) range from 0.18 (station HS4) to 0.47 (station HS7). However, for the three stations located on the Blackwater Creek, i.e. TL1A, JCTA and TL3, the estimated runoff coefficients are in a close range (0.36 to 0.37). The runoff coefficient estimated on the Blackwater Creek using the NOHM method are consistent with the regional runoff coefficients derived from the data of the hydrometric station 05QD016 (0.29) and the Hydrological Atlas of Canada (0.33). There seems to be a consensus for the values of runoff coefficients between 0.3 and 0.4. However, there seems to be some discrepancies between the observed runoff coefficients reported in Tables 2-10 and 3-4 (Appendix O, pages 15 and 22). It is our understanding that the runoff coefficients were used as a means of validating the hydrologic model. It is not clear whether they were used, or will be used, for the sizing and design of the project's infrastructure. If they were used, it is also not clear what long-term runoff coefficients were used for calculations. This information is needed to assist in the analysis of the site surface water run-off predictions and capacity of the infrastructure to manage surface water.

Information Request:

1. Report the long-term estimate that is being used and elaborate on the discrepancies between the observed runoff coefficients reported in Tables 2-10 and 3-4 (Appendix O, pages 15 and 22) if runoff coefficients are used, or will be used, in the sizing and design of the project's infrastructure.

IR-1 Reference #: SW(1)-28
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Surface Water Quantity
Reference to EIS Guidelines: Section 9.1
Reference to EIS: Appendix O, Section 3.3
Summary of Comment/Rationale: The results of the baseline model showed that flows from simulated events generally peaked higher than observed data. Adjusting input parameters during model calibration, the proponent found that the model could not estimate the peak flow for rainfall events. For example, Figure 3-3 (Appendix O, page 20) shows that the model overestimated the peak flow resulting from the July 25, 2013 rainfall event by around 50% while the discharge for the August 29, 2013 rainfall event was underestimated by around 40%. The Green Ampt infiltration method used in the model to take into account losses by infiltration is more suitable to single event simulations (USACE 2000. HEC-HMS technical reference manual). The Continuous Soil-moisture Accounting (SMA) Model is reported to be more adapted to continuous simulations (See Chu, X. and A. D. Steinman. 2009. Combined event and continuous hydrologic modeling with HEC-HMS. American Society of Civil Engineers Journal of Irrigation and Drainage Engineering 135:119–124).

Information Request:

1. Clarify whether any alternative infiltration loss method was applied to assess whether concurrence between simulated and observed peak flows could be improved.
2. Describe the suitability of using peak flow estimates from the hydrologic model in the sizing and design of the project's infrastructure.

IR-1 Reference #: SW(1)-29
Links to Annexes A3 and A4: AC(1)-364
s.5 Effect/Valued Component/EA Item: Surface Water Quantity
Reference to EIS Guidelines: Section 9.1
Reference to EIS: Appendix O
Summary of Comment/Rationale: Although the hydrologic model is based on accepted practices, the possibility for its validation is limited given that the flow monitoring period at the site is over a short period of time. Part of the baseline data used to validate the hydrologic model was questioned by Environment Canada in the comments submitted May 21, 2014. Further information is required concerning the impact of uncertainties that could result from the baseline data on the model results. This information could be presented in the form of a sensitivity analysis on the main input parameters.

Information Request:

1. Provide a sensitivity analysis on the main input parameters or conduct some other test in order to provide further information on the impact of uncertainties on the effects assessment, mitigation, and follow-up that could result from the baseline data.

IR-1 Reference #: SW(1)-30
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Surface Water Quantity
Reference to EIS Guidelines: Section 9.1
Reference to EIS: Appendix O
Summary of Comment/Rationale: In its present state the absolute value of peak flow predicted by the model is not validated. Therefore, the model should not be used for determining the size of structures such as ditches, storage ponds, etc. Other methods, or combination of methods, for determining the extreme flows such as the one presented in sections 3.5.2.3 and 3.5.2.4 (Appendix G) should be preferred.

Information Request:

1. Validate the absolute value of peak flow predicted by the model if the model is to be used in determining the size of structures such as ditches, storage ponds, etc.

IR-1 Reference #: SW(1)-31
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Surface Water Quantity
Reference to EIS Guidelines: Section 9.1
Reference to EIS: EIS Section 6.4.1.8
Summary of Comment/Rationale: Section 6.4.1.8 (EIS) reports the effects of the Project on surface water quantity at different stages of the mine life. A quantification of the effect of the mine on both flow rates and water levels is required to improve understanding of the Project's effect on water quantity over time and to support the arguments being made. To better understand the effect of the Project on surface water, the proponent should present a summary table showing the flow rates/water levels at different monitoring stations for each of the following stages of the mine cycle: baseline (long term conditions), construction, operations, decommissioning and abandonment. The proponent should also describe the major changes to the baseline conditions using numbers that can identify their significance. This could be done by presenting the baseline values, the values at each phase of the mine life, and the change from the baseline values (absolute values and percentage).

Information Request:

1. Provide a summary table showing the flow rates/water levels at different monitoring stations for each stage of the mine cycle.
2. Describe the major changes to the baseline conditions using numbers that can identify their significance.

IR-1 Reference #: SW(1)-32
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Surface Water Quantity
Reference to EIS Guidelines: Section 9.1
Reference to EIS: Appendix O, Section 2.4.3
Summary of Comment/Rationale: Evaporation is an important meteorological element in water balance and hydrological impact assessments. However, only the long-term annual average evaporation rate was reported in the assessment and used in hydrologic modeling. Rationale should be provided for the application of long-term mean evaporation data as the inputs chosen for the analysis. The analysis should include a broad range of inter-annual evaporation values (well beyond annual mean values) to demonstrate that the system is robust enough to withstand a range of climate situations including wet and drought conditions. There can be a substantial variation in annual evaporation rates from year to year and understanding this temporal range is important to support the selection of suitably conservative evaporation rate(s) for subsequent water balance calculations. The proponent should provide additional analysis in the water balance assessments and hydrological impact modeling using a range of inter-annual evaporation data (i.e. the minimum and maximum annual lake evaporation from the observed historical period). Specifically, the observed lake evaporation data at Rawson Lake station (ID: 6036904, approximately 80 km southwest of the project site) are available for the period 1969–1999. During the period the minimum and maximum observed annual evaporation values are 432.4 mm and 629.8 mm, respectively in 1993 and 1987.

Information Request:

1. Provide additional analysis in the water balance assessments and hydrological impact modeling using a range of inter-annual evaporation data.

IR-1 Reference #: SW(1)-33
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Surface Water Quantity
Reference to EIS Guidelines: Section 9.1
Reference to EIS: Appendix O, Sections 4.2, 4.3
Summary of Comment/Rationale: Hydrologic model outputs for four low-flow years (1979, 1989, 2005, 2013) and four high-flow years (1974, 1991, 1996, 2000) were presented in the report to represent the dry and wet conditions at the project site. These analyses are important because the dry and wet conditions influence hydrological impact and water balance. However, the information regarding evaporation data used for those years' model runs is missing from the report. The evaporation data should be the observed or estimated values for each of the individual years rather than the long-term average value for every year of the analysis. Annual evaporation rates vary greatly from year to year; for example, annual evaporation rates are 438.1 mm and 592.0 mm, respectively for 1979 (low flow year) and 1991 (high flow year).

Information Request:

1. Identify and report the evaporation data used in hydrologic modeling study for these 8 years.

IR-1 Reference #: SW(1)-34
Links to Annexes A3 and A4: AC(1)-314; AC(1)-364
s.5 Effect/Valued Component/EA Item: Surface Water Quantity
Reference to EIS Guidelines: Section 9.1
Reference to EIS: EIS Section 3.7.1; Appendix D Section 2.5
Summary of Comment/Rationale: The proponent reported that the 1000-year return period value for the 24-hour storm extreme rainfall is 125 mm for the project area. This return value appears low for a 1:1000 year event. This value is closer to the 1:100 year event expected for the area. For example, the 100-year return values of the 24-hour storm extremes are 160 mm and 123 mm, for Kenora and Thunder Bay respectively, based on data through 2004. The Ontario Ministry of Transportation provides an on-line rainfall Intensity-Duration-Frequency look-up utility. This utility estimates that the on-site, interpolated 100-year return 24-hour rainfall value is 123 mm (http://www.mto.gov.on.ca/IDF_Curves/terms.shtml). The rainfall extreme return values for the project area presented in the assessment reports were derived based upon the methods and estimated coefficients/maps in "Rainfall Frequency Atlas For Canada" (Hogg and Carr, 1985). The Rainfall Frequency Atlas uses data ending before 1985. The use of the Hogg and Carr IDF maps is suspect due to the age of the data. It is important that Intensity-Duration-Frequency calculations include the most recent rainfall data and extremes available. For example, a 24-hour rainfall amount of 153.5 mm was recorded at Kenora on July 27, 1993. The proponent should also be careful about deriving a 1000-year rainfall extreme return value since uncertainty is increased when deriving long return period rainfall values (>100 years) from relatively short data records (<50 years).

Information Request:

1. Revise analysis using Environment Canada's or Ministry of Transportation's rainfall extreme return values which include recent rainfall extreme data.

IR-1 Reference #: SW(1)-35
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Fish and Fish Habitat; Surface Water Quantity
Reference to EIS Guidelines: Sections 4, 10.1.2
Reference to EIS: EIS Section 6.4.1.12
Summary of Comment/Rationale: Section 6.4.1.12 (EIS) suggests that the impacts of different flows are reversible. However, there is no consideration of loss of flow to groundwater fed streams such as Hughes Creek. If this is reversible, describe the timeframe for reversibility and how this may change the duration score of the significance analysis.

Information Request:

1. Clarify the effects of altered flows on fish and fish habitat, taking into account the loss of flow to groundwater fed streams and using the framework to determine significance of adverse environmental effects.

FISH AND FISH HABITAT

IR-1 Reference #: FH(1)-01
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Fish and Fish Habitat; Project Description
Reference to EIS Guidelines: Sections 4, 10.1.2
Reference to EIS: EIS Summary section 4.5.1, Figure ES.5.2
Summary of Comment/Rationale: Section 4.5.1.1 (EIS Summary) indicates that the tree nursery ponds, connected to Thunder Lake Tributary 3, are the preferred water source for operations of the mine. Figure ES.5.2 (EIS Summary, page ES-54) shows that the tree nursery ponds are connected to Thunder Lake Tributary 2. Water taking has the potential to impact fish and fish habitat within the tree nursery ponds and the associated tributary of Thunder Lake as well as areas upstream from the tree nursery ponds. The water intake structures also have potential to impact fish and fish habitat.

Information Request:

1. Clarify whether the tree nursery ponds are located on the Unnamed Thunder Lake Tributary 2.
2. Describe the impacts to fish and fish habitat in the tree nursery ponds, the associated unnamed tributary of Thunder Lake and upstream reach of the tributary from the tree nursery ponds, resulting from water taking.
3. Confirm whether impacts to fish and fish habitat from water taking have been accounted for in the total amount of area lost. If not, include it in the assessment of fish habitat lost within the fish habitat compensation and offsetting plans.

IR-1 Reference #: FH(1)-02
Links to Annexes A3 and A4: AC(1)-363
s.5 Effect/Valued Component/EA Item: Fish and Fish Habitat; Project Description
Reference to EIS Guidelines: Section 10.1.2
Reference to EIS: EIS, Section 3.3.4.1; Appendix G Section 10.4.2.2.1, Figure 10.4
Summary of Comment/Rationale: Section 3.3.4.1 (EIS) indicates that a small laydown area may be used to accommodate larger items for spare parts and other maintenance necessities and will be located within the general footprint of the maintenance and mill facilities. Figure 3.0.1 (EIS, page 3-2) shows the Laydown Area overprinting the main channel of Blackwater Creek. The creation of the small laydown area over the main channel of Blackwater Creek may impact water quality and fish and fish habitat. In addition, Appendix G notes that commercial baitfish licenses are tied to the pond (site 7 on Figure 10.4 of Appendix G, page 255) on the main channel of Blackwater Creek upstream of Norman Road. If the laydown area is built over the main channel of Blackwater Creek, fish habitat will be destroyed and the passage of fish to and from the pond will be restricted. No information is given in regard to surface water runoff and seepage from this area(s) and whether or not it will be collected.

Information Request:

1. Quantify the impacts to fish and fish habitat as a result from the construction and operation of the laydown area.
2. Evaluate the effects to fish and fish habitat from this activity, using the framework to determine significant adverse environmental effects.
3. Identify how avoidance measures to fish and fish habitat were considered in choosing the location for the small laydown area. If the impacts to fish and fish habitat are unavoidable, identify mitigation measures that will be implemented to minimize the impacts on fish and fish habitat.
4. Provide a description of the planned duration for which the laydown area will be used.
5. Assess the need for surface water runoff and seepage collection systems in the laydown area(s). Describe how runoff and seepage from these areas will be collected and update relevant map(s)/figure(s).

IR-1 Reference #: FH(1)-03
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Fish and Fish Habitat; Project Description
Reference to EIS Guidelines: Section 4, 10.1.2
Reference to EIS: EIS Summary, EIS Section 4.10 Figure ES4.19; EIS, Figure 3.11.1
Summary of Comment/Rationale: Figures ES4.19 (EIS Summary, page ES-42) and 3.11.1. (EIS, page 3-57) show a created water structure just south of the collection pond (south of Norman Road) in the main channel of Blackwater Creek. The purpose of this created water structure is not clear and is not described in the narrative text.

Information Request:

1. Describe the purpose and details of the created water structure.
2. Evaluate the effects on fish and fish habitat from the creation of this water structure, if applicable.
3. Provide information on any mitigation measures that will be implemented to reduce the effects on fish and fish habitat during the construction and use of the created water structure, if applicable.

IR-1 Reference #: FH(1)-04
Links to Annexes A3 and A4: AC(1)-363; AC(1)-370; AC(1)-405
s.5 Effect/Valued Component/EA Item: Fish and Fish Habitat
Reference to EIS Guidelines: Section 4, 8
Reference to EIS: EIS Summary Sections 4.7, 4.7.6, 4.13, 4.13.9; Figures ES4.17, ES4.18; EIS Appendix F Section 4.1.4
Summary of Comment/Rationale: Section 4.7.6 (EIS Summary) and Figure ES4.17 (EIS Summary, page ES-39) indicate that only one minor watercourse realignment of approximately 429 m in Blackwater Creek Tributary 2 is needed to carry out the project. Figures ES4.17 and ES4.18 (EIS Summary, page ES-40) do not provide any detail regarding the design of the new channel, other than to state the new channel will be trapezoidal and provide like for like habitat. The channel will not provide like for like habitat unless it is designed and engineered to do so. Section 4.13 (EIS Summary) indicates that the new alignment of Blackwater Creek will naturalize over the life of the mine and become the permanent creek channel. In section 4.7.6 and Figure 4.17, the EIS Summary indicates that the only watercourse realignment required is in Blackwater Creek Tributary 2.

Information Request:

1. Provide habitat mapping (all life history requirements: spawning, nursery, rearing, food supply, migration areas) for Blackwater Creek and its tributaries that will be impacted by the mine and mine infrastructure.
2. Clarify which watercourses, wetlands, or waterbodies will be diverted or dewatered to accommodate the mine site.
3. Describe the effects of fish and fish habitat from the watercourse and wetland alterations or disruptions for the life of the mine and identify mitigation measures.
4. Clarify whether or not a watercourse re-alignment, other than that in Blackwater Creek Tributary 2, is proposed in Blackwater Creek. Provide the conceptual designs for the proposed watercourse realignments, including fish habitat features.

IR-1 Reference #: FH(1)-05
Links to Annexes A3 and A4: PC(1)-15; PC(1)-34
s.5 Effect/Valued Component/EA Item: Fish and Fish Habitat; Groundwater Quantity
Reference to EIS Guidelines: Section 4
Reference to EIS: EIS Summary Section 6.6
Summary of Comment/Rationale: Section 6.6 (EIS Summary) indicates that groundwater drawdown due to open pit mine development is predicted to cause base flow reductions around 5% and 1% in Thunder Lake tributaries 2 and 3 and Hughes Creek respectively. Losses of groundwater input in watercourses reliant on recharge, especially in low flow times, for example the winter, could impact fish and fish habitat.

Information Request:

1. Quantify effects to fish and fish habitat as a result of groundwater drawdown in Thunder Lake tributaries 2 and 3 and Hughes Creek.
2. Provide a description of the environmental monitoring plan for effects of groundwater drawdown on fish and fish habitat during the operation and decommissioning phases, including monitoring parameters, methods, sampling locations, applicable standards, duration and frequencies. These plans should clearly outline action levels that may trigger certain mitigations.

IR-1 Reference #: FH(1)-06
Links to Annexes A3 and A4: PC(1)-02; PC(1)-03; AC(1)-04; AC(1)-06; AC(1)-107; AC(1)-147; AC(1)-186; AC(1)-193; AC(1)-224; AC(1)-226; AC(1)-240; AC(1)-292; AC(1)-321; AC(1)-342; AC(1)-207; AC(1)-286; AC(1)-369; AC(1)-370; AC(1)-405; AC(1)-408; AC(1)-424; AC(1)-425
s.5 Effect/Valued Component/EA Item: Fish and Fish Habitat
Reference to EIS Guidelines: Sections 4, 9, 9.1, 9.1.2
Reference to EIS: EIS Summary sections 12.4.2, 12.4.2.12; EIS, Sections 6.2.1.12, 6.4.1.12; Appendix II; Section 3.3
Summary of Comment/Rationale: Sections 12.4.2 (EIS Summary) and 6.2.1.12 (EIS) indicate that the Project will result in approximately 6 ha of fish habitat loss due to the location of the tailings storage facility and pit excavation and that both a Fisheries Act authorization and an amendment to Schedule 2 of the Metal Mining Effluent Regulations will be required. However, Appendix II indicates that the total amount of habitat lost will be 9.5 ha. Section 3.3 (Appendix II) presents uncertainty in relocating the stream channel in the footprint of the current location of the overburden stockpile, thus, the impacts of the proposed mine waste disposal alternatives cannot be fully understood and therefore it cannot be determined if the proposed mitigation measures are appropriate. Section 5.0 (Appendix II) states that "no current locations for in-kind offset habitat locations have been selected due to non-finalized Project design, and lack of First Nation and public input into the design of the NNLP." However, section 6.4.1.12 (EIS) states that potential candidate sites for fish habitat compensation are Thunder Lake, Thunder Creek and Wabigoon Lake. There is not enough detail to quantitatively assess whether the habitat lost can be mitigated. In the absence of conceptual details of the fish habitat compensation/ offsetting measures, the significance conclusions for fish and fish habitat are not supported by evidence of mitigation measures. The conceptual plans for fish habitat offsetting/ compensation, taking into consideration Aboriginal and public input are required to ensure that the amount of habitat lost can be offset and mitigated. Appendix II provides limited information on proposed offsetting/ compensation strategies. The appendix states "The local fish species sampled within the LSA may not represent or support commercial, recreational, or Aboriginal value, and therefore may not be of interest to DFO, and there is only inconclusive evidence to support the presence of large bodied fish". To clarify, the Fisheries Act prohibition against causing serious harm to fish states "No person shall carry on any work, undertaking or activity that results in serious harm to fish that are part of a commercial, recreational or Aboriginal fishery or to fish that support such a fishery".

Information Request:

1. Provide detailed outline of the effects to fish and fish habitat in each watercourse, waterbody, and wetland as a result of the mine and mine infrastructure.
2. Provide updated tables that identify the fish habitat effects by mine component, the amount of habitat created or restored to offset the loss of fish habitat, a summary breakdown of project components with consideration under Fisheries Act section 35(2) or the Metal Mining Effluent Regulations Schedule 2 amendment.
3. Provide an updated figure that shows the watercourses, waterbodies and wetlands impacted by project components.
4. Clarify the intent with respect to the overburden stockpile and the stream channel realignment.
5. Describe proposed fish habitat compensation/offsetting measures for Thunder Lake, Wabigoon Lake and Thunder Creek and any other measures that have incorporated Aboriginal and public input. Provide a map that shows the potential locations of the fish habitat compensation measures in relation to the project site.
6. Responses comment E above need to integrate results of discussions with Fisheries and Oceans Canada, Environment Canada, and the Ministry of Natural Resources and Forestry and engagement with the Aboriginal groups and the public prior to finalizing the response to FH-06.
7. Provide baseline information regarding all commercial, recreational or Aboriginal fisheries present in the Local Study Area and Regional Study Area, including all forage and baitfish that support said commercial, recreational or Aboriginal fisheries.
8. Provide a map that identifies any commercial bait fisheries within the Local Study Area. Provide effects assessment on all commercial bait fisheries within the Local Study Area and identify mitigation measures that will prevent significant adverse environmental effects.
9. Provide a description of the environmental monitoring plan for effects to fish, commercial bait fisheries, and fish habitat, including monitoring parameters, methods, sampling locations, applicable standards, duration and frequencies. These plans should clearly outline action levels that may trigger certain mitigations.

IR-1 Reference #: FH(1)-07
Links to Annexes A3 and A4: AC(1)-428
s.5 Effect/Valued Component/EA Item: Fish and Fish Habitat; Effects Assessment Methodology
Reference to EIS Guidelines: Sections 4, 9, 9.1, 9.1.2
Reference to EIS: EIS Summary Sections 12.4.2, 12.4.2.12; EIS section 6.4.1.12, Table 6.4.2; Appendix G; Appendix Q
Summary of Comment/Rationale: Sections 12.4.2.12 (EIS Summary) and 6.4.1.12 (EIS) state that a potential effect to fish during the operation phase is fish mortality resulting from changes in water quality due to increased sediment from runoff and/or release of deleterious substances and from potential degradation of habitat availability and quality. The proponent predicted these effects to be significant. Mitigation measures identified in section 6.4.1.12 (EIS) include the implementation of comprehensive EMP measures (including erosion and sediment control measures) that minimize the potential for habitat disturbance; equipment used will be well-maintained and will carry appropriately stocked spill kits; operators will be trained in their use and have a spill response plan in place; and, disturbed soils will be stabilized where possible to limit potential for erosion and sediment mobilization. These mitigation measures are too vague to assess whether they are sufficient in preventing significant adverse environmental effects. Section 6.4.1.12 (EIS) states that the residual effect on fish mortality from changes in habitat quality is predicted to be significant and that the proponent will carry out monitoring to detect ongoing or potential adverse effects and manage such issues when they arise. Section 6.4.1.12 (EIS) also states that follow up fish surveys to assess species distribution and species composition will be undertaken. These measures require further detail to allow the Agency to assess whether they are sufficient in preventing significant adverse environmental effects.

Information Request:

1. Provide details of additional mitigation measures (e.g. sediment and erosion control plan) to prevent increased sediment and release of deleterious substances into a waterbody.
2. Provide detail on proposed monitoring plan, include duration (years), data collection methods (sampling methods), and means of analyzing data which will be implemented to detect ongoing or potential adverse effects. Include the proposed mitigation strategies or adaptive management or adaptive management strategies that will be used if adverse effects are detected.
3. Describe all future fish survey plans.

IR-1 Reference #: FH(1)-08
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Fish and Fish Habitat; Surface Water Quality
Reference to EIS Guidelines: Section 9.1.2
Reference to EIS: Appendix C of Appendix Q
Summary of Comment/Rationale: Appendix C of Appendix Q shows site photographs of Hoffstrom's Bay and Kelpyn Bay. However, Appendix D of Appendix Q provides fish habitat data sheets for the waterbodies mentioned above as well as Blackwater Creek and the tributaries of Thunder Lake. Site photographs of Blackwater Creek and its tributaries and those of Thunder Lake are mentioned in the fish habitat data sheets but not provided. This information will assist the Agency in understanding the existing conditions within Blackwater Creek and its tributaries and those of Thunder Lake.

Information Request:

1. Provide the site photographs of Blackwater Creek and its tributaries and the tributaries of Thunder Lake.

IR-1 Reference #: FH(1)-09
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Fish and Fish Habitat
Reference to EIS Guidelines: Section 4
Reference to EIS: EIS Summary Sections 12.4.2, 12.4.2.12
Summary of Comment/Rationale: Section 12.4.2 indicates that changes to water quantity could have an effect on downstream habitats and that mitigation through on-site water management plans will maintain the water balance.

Information Request:

1. Provide the water management plans for water diversions on, and around the mine site to address any downstream fish habitat impacts.
2. Describe all potential mitigation measures.

IR-1 Reference #: FH(1)-10
Links to Annexes A3 and A4: AC(1)-286; PC(1)-02; AC(1)-04; AC(1)-363; AC(1)-369; AC(1)-370; AC(1)-405
s.5 Effect/Valued Component/EA Item: Fish and Fish Habitat
Reference to EIS Guidelines: Section 4
Reference to EIS: EIS Sections 5.0, 5.8.4; Table 5.8.14
Summary of Comment/Rationale: There were several surveys done of fish and fish habitat presented in various appendices, e.g. Appendix G, Appendix Q, and Appendix II. In addition, the baseline work in Appendix G suggests that further field surveys should be considered as the majority of streams within the local study area were not assessed for their total lengths due to access, fish captures in several tributaries were not representative, and the captures were completed only over one field season. However, Appendix Q indicates additional field work was undertaken in 2012 that concentrated on Thunder Lake, Wabigoon Lake, Thunder Creek, Blackwater Creek and an unnamed tributary to Thunder Lake. Without a summary, it is difficult to interpret whether these surveys were adequate in determining a baseline awareness of habitat types and fish occurrences. This information is required to properly assess effects to fish and fish habitat as a result of the project.

Information Request:

1. Provide a summary of fish and fish habitat information collected for the Project both within and outside of the Local Study Area–similar to Table 5.8.14–including habitat mapping (all life history requirements: spawning, rearing, migration areas, food supply, nursery), fish species assemblages, and all baseline data collected.

IR-1 Reference #: FH(1)-11
Links to Annexes A3 and A4: AC(1)-24; AC(1)-363; AC(1)-368; AC(1)-375; AC(1)-430
s.5 Effect/Valued Component/EA Item: Fish and Fish Habitat
Reference to EIS Guidelines: Sections 9, 9.1, 9.1.2; Section 4
Reference to EIS: Appendix G; EIS Summary Sections 12.4.2, 12.4.2.13
Summary of Comment/Rationale: Four (4) wetland communities of significance are identified within the EA baseline data; Lola Lake Wetland, Hughes Creek Wetland, Thunder Lake Wetland and Thunder Lake, Blackwater Creek and Nugget Creek Wetlands. The EIS states a permanent loss of 39.5 ha of wetlands as a result of the project.

Information Request:

1. Clarify the potential fish habitat within the four wetland communities.
2. Identify connectivity of the wetlands to commercial, recreational or Aboriginal fisheries.
3. Identify fish species present in the wetlands.
4. Identify potential effects and mitigation measures to prevent significant adverse environmental effects to fish and fish habitat.
5. Provide a description of the environmental monitoring plan for impacts to fish and fish habitat identified in these wetlands, including monitoring parameters, methods, sampling locations, applicable standards, duration and frequencies. These plans should clearly outline action levels that may trigger certain mitigations.

IR-1 Reference #: FH(1)-12
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Fish and Fish Habitat
Reference to EIS Guidelines: Sections 9, 9.1, 9.1.2
Reference to EIS: Appendix Q; Appendix G; Appendix II
Summary of Comment/Rationale: Fisheries surveys present in this appendix focused on Thunder Lake, Wabigoon Lake, Thunder Creek, Blackwater Creek and two tributaries to Thunder Lake. The baseline data in Appendix G states that a dam north of Highway 17 excludes the upstream migration of fish from Wabigoon Lake to Thunder Lake. DFO noted that the proponent could consider re-establishing connectivity within Thunder Creek to allow fish migration between Wabigoon Lake and Thunder Lake as an offsetting strategy.

Information Request:

1. Provide information on the feasibility of re-establishing connectivity within Thunder Creek to allow fish migration between Wabigoon Lake and Thunder Lake as an offsetting strategy.
2. Provide further rationale and design elements for the fish habitat compensation and offsetting measures.

IR-1 Reference #: FH(1)-13
Links to Annexes A3 and A4: AC(1)-05; PC(1)-07; AC(1)-19
s.5 Effect/Valued Component/EA Item: Fish and Fish Habitat
Reference to EIS Guidelines: Section 10.1.2
Reference to EIS: Appendix DD; Appendix W; Appendix C of Appendix F Section 5.5
Summary of Comment/Rationale: Appendix DD states: "A conceptual closure plan for the Goliath Gold Site has been developed. It is anticipated that a portion of the open pit will fill with water to create a small but very deep lake. Such a lake has the potential to support fish populations following closure of the Goliath Mine." The executive summary of Appendix W states: "Forage fish are present within Blackwater Creek and habitat quality for fish within this system is moderate. Therefore fish would likely be exposed to the mine-related COCs proposed to be discharged in effluent. Under Post-Closure conditions the Pit Lake may also support small fish and other aquatic organismsThe Post-Closure Phase analysis relied upon modelled concentrations in Pit Water that will passively discharge into Blackwater Creek." Section 5.5 (Appendix C of Appendix F) states: "Without the inclusion of secondary reactions, it follows that the water quality within the pit lake will remain constant over time and after closure, and will be roughly equivalent to the long term water quality of the waste rock run-off." It is unclear whether the habitat within the pit lake will be suitable for fish survival, and if so what the predicted contamination level of these fish will be. The impacts of the eventual overflow of the pit lake during post-closure to Blackwater Creek on fish habitat within the creek and Wabigoon Lake are unclear.

Information Request:

1. Provide information on the predicted water quality of the pit lake following decommissioning and abandonment of the mine in relation to Provincial Water Quality Objectives and Metal Mining Effluent Regulations, including pH and metal concentrations. Provide information on whether or not fish will be able to access the pit lake from natural waterways.
2. Provide predictions of the contaminant concentrations in fish that may have access to the pit lake following decommissioning and abandonment phases. If the predictions of contaminant concentrations are high, identify mitigation measures to prevent this adverse environmental effect.
3. Describe the effects of pit lake water entering Blackwater Creek and Wabigoon Lake during the decommissioning and abandonment phases to water quality (in relation to Provincial Water Quality Objectives and Metal Mining Effluent Regulations) and use the framework to determine significance of adverse environmental effects. Provide predictions of the contaminant concentrations in fish in these waterbodies following the decommissioning phase.

IR-1 Reference #: FH(1)-14
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Fish
Reference to EIS Guidelines: Section 10.1.2
Reference to EIS: EIS, 6.4.1.12, Table 6.4.2
Summary of Comment/Rationale: Section 6.4.1.12 (EIS) summarizes the potential effects on fish and fish habitat during construction, operations, decommissioning, and abandonment phases of the project. There is no description of effects from changes to water temperature. There are occasional references throughout the document to heating pipes to prevent freezing. There is also no description of whether or not riparian vegetation and trees adjacent to the stream will still be present to provide shade (which is important to regulate water temperature).

Information Request:

1. Clarify whether there will be any effects to water temperature either due to effluent releases, or loss of shade from riparian vegetation. Describe how water temperature will impact fish and fish habitat using the framework to determine significance of adverse environmental effects.

IR-1 Reference #: FH(1)-15
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Fish
Reference to EIS Guidelines: Section 9.1.2
Reference to EIS: EIS Section 5.11.5
Summary of Comment/Rationale: Section 5.11.5 (EIS) notes that Aboriginal people fish in the vicinity of the Project. Section 5.11.5 states the following about fishing activities: "no large-bodied fish occur in Project waterbodies. However, Wabigoon Lake supports a number of large-bodied fish species of value to the public and First Nations: Walleye, Muskellunge, and Northern Pike." The geographic extent of the "Project waterbodies" is not clear.

Information Request:

1. Clarify what is meant by "Project water bodies" and clarify the geographic extent of "Project waterbodies".

IR-1 Reference #: FH(1)-16
Links to Annexes A3 and A4: AC(1)-225
s.5 Effect/Valued Component/EA Item: Fish Habitat; Effects Assessment Methodology
Reference to EIS Guidelines: Section 10.1.1
Reference to EIS: EIS Table 6.4.2
Summary of Comment/Rationale: The frequency rating in Table 6.4.2 (EIS) may have been incorrectly considered for fish habitat. The residual effect is described as "changes to water quality due to release of deleterious substance." The risk is the deleterious substance release – this may occur infrequently but the effect is the change to water quality which if it occurs is listed as having ‘the potential to persist 10 years beyond project initiation". The frequency rating downgrades the significance to "not significant" which may be inappropriate. This comment could be repeated for multiple effects ratings throughout the table. There are also parts of Table 6.4.2 that do not agree with Table 7.3.1. For example, surface water quality is said to be Level II for magnitude in Table 7.3.1, but Level I for magnitude in Table 6.4.2. Consistency in applying the approach is important to properly understand the environmental effects of the Project.

Information Request:

1. Revisit significance ratings to ensure that the frequency column is addressing the frequency of the effect on those affected and not the frequency of the risk being considered.
2. Verify the accuracy of magnitude, extent, duration, and frequency scores. Ensure there is accuracy and consistency between tables in Sections 6 and 7.

IR-1 Reference #: FH(1)-17
Links to Annexes A3 and A4: AC(1)-05
s.5 Effect/Valued Component/EA Item: Fish Habitat
Reference to EIS Guidelines: Section 5.7
Reference to EIS: EIS Section 6.4.3.1, Table 7.3.1
Summary of Comment/Rationale: There are several sections of the EIS that still state water is being taken from Thunder Lake. For example: Section 6.4.3.1 (EIS) states: "On-site water management and water withdrawals from Thunder Lake have the potential to directly affect fish and fish habitat by altering flow in Blackwater Creek particularly during low-flow periods of the year and by affecting water levels in Thunder Lake." Table 7.3.1 (EIS, page 7-16) shows that "Changes to water quantity and subsequent habitat availability/quality in Thunder Lake due to Makeup Water Pipeline."

Information Request:

1. Clarify whether or not water will be taken from Thunder Lake. If water will be taken from Thunder Lake, describe the quantity and potential environmental effects and proposed mitigation measures.

IR-1 Reference #: FH(1)-18
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Fish and Fish Habitat; Effects Assessment Methodology
Reference to EIS Guidelines: Section 10.1.1
Reference to EIS: EIS, Section 6.4.1.12
Summary of Comment/Rationale: Section 6.4.1.12 (EIS) indicates that mitigation will involve the implementation of measures to return watercourses to pre-disturbance conditions as much as is possible. It is not clear which watercourse this mitigation measure is referring to as different sections within Blackwater Creek and the Unnamed Thunder Lake Tributary 2 may be degraded.

Information Request:

1. Identify the watercourses that the proponent plans to return to pre-disturbance conditions.
2. Describe the measures to be implemented to return the watercourses, identified in the request above, to pre-disturbance conditions.

IR-1 Reference #: FH(1)-19
Links to Annexes A3 and A4: AC(1)-05
s.5 Effect/Valued Component/EA Item: Fish and Fish Habitat
Reference to EIS Guidelines: Section 11.1.1
Reference to EIS: EIS, Section 6.4.1.12
Summary of Comment/Rationale: Section 6.4.1.12 (EIS) indicates that fish salvage will be conducted prior to construction, during operations, and during decommissioning phases to mitigate direct mortality of fish due to physical activities that occur within or adjacent to a watercourse. The details of this mitigation measure and where it will be implemented (i.e. which watercourse in what phase of the Project) will assist in understanding how the measure will prevent the direct mortality of fish due to project activities.

Information Request:

1. Provide the fish salvage plan with the locations and timing of its implementation.

IR-1 Reference #: FH(1)-20
Links to Annexes A3 and A4: AC(1)-146; AC(1)-369; AC(1)-370; AC(1)-405
s.5 Effect/Valued Component/EA Item: Fish and Fish Habitat; Effects Assessment Methodology
Reference to EIS Guidelines: Section 7.2.1
Reference to EIS: Appendix G, Section 10.2, Figure 10.1
Summary of Comment/Rationale: Section 10.2 (Appendix G) states: "LSA and a RSA were established to encompass the geographic areas over which Project activities could potentially influence key aquatic resource components". As the same LSA and RSA are used for all valued components, this statement does not provide sufficient rationale for choosing the spatial boundary for the fish and fish habitat assessment. There is no description to indicate whether community and Aboriginal traditional knowledge, current land and resource use by Aboriginal groups, ecological, technical and social and cultural considerations were taken into account. Section 7.2.1 of the EIS Guidelines indicates that spatial boundaries will be defined taking into account as applicable the appropriate scale and spatial extent of potential environmental effects; community and Aboriginal traditional knowledge; current land and resource use by Aboriginal groups; and ecological, technical, social, and cultural considerations.

Information Request:

1. Provide a revised local study area and regional study area that takes into account the appropriate scale and spatial extent of potential environmental effects on fish and fish habitat; community and Aboriginal traditional knowledge; current land and resource use by Aboriginal groups; and ecological, technical, social, and cultural considerations. Provide an explanation of how these factors were taken into consideration in revising the spatial boundary.
2. If the existing LSA and RSA for the fish and fish habitat assessment already take the above factors into consideration, provide an explanation for choosing the spatial boundary as shown in Figure 10.1 of Appendix G.

IR-1 Reference #: FH(1)-21
Links to Annexes A3 and A4: AC(1)-207
s.5 Effect/Valued Component/EA Item: Fish and Fish Habitat
Reference to EIS Guidelines: Section 7.1.1, 9.1.1
Reference to EIS: EIS, Section 6.3.1.12
Summary of Comment/Rationale: Section 6.3.1.12 (EIS) states there are "two fish and fish habitat valued components identified during the environmental assessment" and the rationale for choosing these valued components is "because they are protected by the Federal Fisheries Act 2012 and the Project has potential to cause significant effects". The importance of those valued components (VCs) identified in section 6.3.1.12 (EIS) is not clear. It is also not clear how Aboriginal, social, economic, recreational, and aesthetic considerations were taken into account. The VCs selected in Section 6.3.1.12 (EIS) do not include discussion of indicators or measurable parameters.

Information Request:

1. Provide further justification for the selection of the valued components identified in section 6.3.1.12 (EIS) taking into account Aboriginal, social, economic, recreational, and aesthetic considerations.
2. Describe the indicators and measures of ecosystem health and integrity used to assess the potential for environmental effects on fish and fish habitat from the Project and relate the effects to the proposed mitigation, monitoring and follow-up measures.

IR-1 Reference #: FH(1)-22
Links to Annexes A3 and A4: AC(1)-148; AC(1)-157; AC(1)-149
s.5 Effect/Valued Component/EA Item: Fish and Fish Habitat
Reference to EIS Guidelines: Section 9.1.2
Reference to EIS: EIS, Section 5.8.4.8
Summary of Comment/Rationale: No detail is provided on the sources of information used to compile the Fish Species of Management Concern in the RSA. Section 9.1.2 of the EIS Guidelines state: "The following information sources on species at risk and species of conservation concern should be consulted: SARA (www.sararegistry.gc.ca); COSEWIC; Relevant Government agencies; Local naturalist and interest groups; and Aboriginal groups and First Nations."

Information Request:

1. Provide the sources of information used to compile the Fish Species of Management Concern in the RSA, explaining how the following were consulted/engaged: SARA (www.sararegistry.gc.ca); COSEWIC; Relevant Government agencies; Local naturalist and interest groups; and Aboriginal groups and First Nations.
2. If engagement did not occur with the people listed above to compile the Fish Species of Management Concern in the RSA, conduct engagement activities with groups listed above with a full explanation of the results from the engagement activities. Provide a revised effects assessment on any changes to the Fish Species of Management Concern in the RSA, if applicable.

WILDLIFE AND WILDLIFE HABITAT (including MIGRATORY BIRDS AND SPECIES AT RISK)

IR-1 Reference #: WL(1)-01
Links to Annexes A3 and A4: AC(1)-150; AC(1)-153; AC(1)-154; AC(1)-155; AC(1)-363; AC(1)-367; AC(1)-409
s.5 Effect/Valued Component/EA Item: Migratory birds; Current Use of Lands and Resources for Traditional Purposes
Reference to EIS Guidelines: Sections 7.2.1, 9.2.1
Reference to EIS: EIS, Section 5.9.2.1; Appendix G Section 8 .2, Figure 8.1
Summary of Comment/Rationale: Section 5.9.2.1 (EIS) indicates the local study area (LSA) selected for the wildlife baseline is a 5 km radius circle centered on the existing portal (Figure 8.1 of Appendix G, page 144). The LSA was selected to focus field study efforts on identifying and assessing the wildlife community, important wildlife habitat and species at risk (SAR) located within, and near, the area in which most project facilities were anticipated to be located based on the information provided by the proponent at the time the studies were being completed. The wildlife regional study area (RSA) is defined by the watershed boundary to the north, east, and south and by the LSA boundary to the west (Figure 8.1). The RSA was selected to examine the wildlife community, SAR, and important habitat types within a broader area, to provide a regional context for the wildlife and habitat found in the LSA. The justification for the use of a 5 km radius circle centered on the existing portal to define the LSA and a small watershed (~145 km²) to define the RSA, which are used to assess the project effects on wildlife, is not clear. Wildlife, including migratory birds and SAR, require the presence of suitable habitat to carry out their life cycle processes; this suitable habitat is typically defined by an ecological matrix (group of habitat types). The scale of the ecological matrix is different for many species because of their specific requirements (i.e. home range). Wildlife species occupy suitable habitat, which is typically defined by an ecological matrix and likely not well represented by a buffer of a single point. The careful selection of an appropriate LSA and RSA is a crucial preliminary element that is necessary to determine potential effects of the Project on wildlife and design an appropriate sampling framework. Section 9.1.2 of the EIS Guidelines include reference to "Technical Report No. 508, A Framework for the Scientific Assessment of Potential Project Impacts on Birds (Hanson et al. 2010)", which clearly identifies that project effects within a defined study area need to be related to local and regional population trends. This can only occur when an appropriate LSA and RSA are chosen and the selection criteria for these are clearly documented. It may also be necessary to define different scales for an LSA or RSA depending on the focal species.

Information Request:

1. Provide justification for the use of a 5 km radius circle (buffer) centered on the existing portal to define the local study area and a small watershed (~145 km²) to define the regional study area which are used to assess the project effects on wildlife.

IR-1 Reference #: WL(1)-02
Links to Annexes A3 and A4: AC(1)-150; AC(1)-153; AC(1)-154; AC(1)-155; AC(1)-317; AC(1)-288; AC(1)-363; AC(1)-368
s.5 Effect/Valued Component/EA Item: Migratory birds; Current Use of Lands and Resources for Traditional Purposes
Reference to EIS Guidelines: Section 9.1.2
Reference to EIS: EIS Section 5.9.2.1 - 5.9.2.4, Table 5.9.1; Appendix G, Section 9.1.2; Table 9.5, Figures 9.4 -9.7; Appendix R Executive Summary, Section 2.2
Summary of Comment/Rationale: Throughout the EIS, only the local and regional study areas have been characterized using Ecosite (ELC) information while the project footprint has been described using broad habitat classes (terrestrial and wetland). Section 3 (EIS) indicates that the Project footprint will cover approximately 188 ha during operations; however, it is not clear what area this covers. Typically the project footprint consists of the geographic area disturbed or occupied by the physical activities and project components. The Ecosite information is necessary to determine the amount (and type) of wildlife habitat that will be lost directly as a result of the project activities, and the indirect effects such as noise and lighting. This is particularly important with respect to effects on species at risk.

Information Request:

1. Provide a map that defines the project footprint (spatially) along with the difference between the project site and project study area.
2. Provide a revised version of Figure 9.4 (Appendix G) that delineates the project footprint defined in part A of this IR with respect to the local study area (LSA) and regional study area (RSA) in order to visually compare wildlife habitat within these 3 areas.
3. Provide a table that lists the Ecosite information of the project footprint defined in part A of this IR, the LSA, and the RSA in order to compare wildlife habitat within these 3 areas.
4. Provide the total area, including wetlands by Ecosite covered by all project components and by each project component (i.e. Waste rock Storage Area, Ultimate Pit, Overburden Storage Area, Low Grade Stock Pile, Processing Plant, Tailings Storage Facility, and underground workings) in percentages and in square kilometres to allow for a review of effects on migratory birds and wildlife. Refer to comment WL(1)-04 for more information.

IR-1 Reference #: WL(1)-03
Links to Annexes A3 and A4: AC(1)-24; AC(1)-152; AC(1)-317; AC(1)-208; AC(1)-363; AC(1)-368; AC(1)-375; AC(1)-420; AC(1)-426
s.5 Effect/Valued Component/EA Item: Section 5(2) Effects; Species at Risk; Migratory Birds; Wetlands; Current Use of Lands and Resources for Traditional Purposes
Reference to EIS Guidelines: Section 9.1.2
Reference to EIS: EIS Sections 5.9.2.4, 5.9.3 ; 6.2.1.13, 6.4.1.13, 9.1.2, 9.2.2.3; Appendix R ; Figure 3.1; Appendix S ; Figure 2.1; Appendix G; Appendix S, Section 2.2
Summary of Comment/Rationale: Section 5.9.3.3 (EIS) states: "Nine wetlands were identified as being potentially impacted by future development (Figure 5.9.3) and were assessed in the field using the OWES protocol." Section 2.2 (Appendix S) states: "Site visits, which included ground-truthing all accessible portions of each wetland, occurred throughout the early fall of 2012. All vegetation communities were visited in the field to confirm vegetation community boundaries and to identify vegetation forms and species." Field surveys for wetland vegetation during the early fall may not capture the species necessary to evaluate wetlands using the Ontario Wetland Evaluation System (OWES). From Figure 2.1 (Appendix S, page 10), it appears as though only nine wetlands identified to be directly affected by project activities were subsequently evaluated. Baseline surveys should have considered all wetlands within the local study area (LSA), and extended even to the regional study area (RSA) to ensure the projected areas of the groundwater drawdown are adequately sampled. An appropriate sampling framework (using the Ecosite information already available) should have been designed and documented. An important large wetland (Lola Lake Nature Reserve) was excluded from wetland surveys even though a portion of it is within the LSA, and the watershed it is within will likely be affected by project activities. Wetlands provide significant habitat for migratory birds and species at risk (SAR). In order to determine the potential effects of the Project on wildlife, including migratory birds and SAR, habitat information, including wetlands must be presented (Ecosite information), and the sampling framework must be adequately justified.

Information Request:

1. Provide dates for the wetland vegetation surveys for the nine wetlands identified and a justification that the survey period conforms to the requirements of the OWES.
2. Conduct baseline surveys, with an appropriately designed sampling framework using the Ecosite information that is already available, for all wetlands within the local study area, taking into consideration the projected areas of the groundwater drawdown, water taking for mine operations and habitats for migratory birds and species at risk. . Provide the results of these surveys.
3. Provide a spatial representation of the wetlands that were sampled. Provide a summary and map of the wetlands by Ecosite within the project footprint.
4. Provide additional information with respect to the sampling framework for wetlands to justify why only the 9 wetlands that were determined to be directly affected were sampled. In particular, explain why an important large wetland within the LSA (Lola Lake Wildlife Preserve) was excluded from wetland surveys.

IR-1 Reference #: WL(1)-04
Links to Annexes A3 and A4: AC(1)-318; AC(1)-288
s.5 Effect/Valued Component/EA Item: Species at Risk; Current Use of Lands and Resources for Traditional Purposes
Reference to EIS Guidelines: Section 9.1.2
Reference to EIS: Appendix G, Figure 9.1; Sections 9.2.1 - 9.2.2.1.1
Summary of Comment/Rationale: Table 9.2 (Appendix G, page 193) indicates targeted vegetation surveys were conducted in the local study area (LSA) in June, July and August, 2011. General vegetation observations such as vegetation community identification, Ecosite verification and vegetation species inventories were also collected in conjunction with the other baseline studies such as the aquatic field program and the wildlife field program throughout 2010 and 2011 (Table 9.2). The vegetation sampling appears to be concentrated around roads only, and not distributed throughout all the Ecosites found within the LSA. The map in Figure 9.1 (Appendix G, page 190) should include the Ecosite mapping used in other maps provided in the EIS. A summary table presenting the distribution of sample points by Ecosite within the project footprint, LSA and regional study area (RSA) should also be provided. A description of the survey design (distribution) of sample locations is necessary to justify that the sample points are representative of the project footprint, LSA, and RSA in order to determine the characteristics of the available habitat and evaluate the effects to wildlife species and impacts to Aboriginal current use of lands and resources, including plant harvesting.

Information Request:

1. Provide a revised Figure 9.1 (Appendix G) to include Ecosite mapping used Figure 9.4 (Appendix G, page 204).
2. Provide a summary table presenting the distribution of sample points within the project footprint, LSA and RSA.
3. Describe the survey design (distribution) of sample locations.

IR-1 Reference #: WL(1)-05
Links to Annexes A3 and A4: PC(1)-21; AC(1)-11; AC(1)-124; AC(1)-33; AC(1)-288; AC(1)-363; AC(1)-379; AC(1)-409
s.5 Effect/Valued Component/EA Item: Section 5(2) Effects; Migratory Birds; Current Use of Lands and Resources for Traditional Purposes
Reference to EIS Guidelines: Section 9.1.2
Reference to EIS: EIS Sections 6.2.1.11, 6.4.1.11, 6.4.1.13; Appendix F
Summary of Comment/Rationale: Section 6.4.1.13 (EIS) states: "As a result of being found in topographical depressions, wetlands may become the endpoint for contaminated runoff from mine operations. As waterfowl and wildlife (e.g., reptiles/amphibians) are attracted to wetlands for foraging and breeding, concentrations of contaminants could constitute an attractive nuisance to such species. This effect will be offset by diverting runoff to a tailings pool, with a fenced perimeter and possibly a screen over the top to prevent entry by migrating waterfowl." Appendix F states: "Unforeseen storm events will cause the release of cyanide to the environment in the event of TSF overflow. The tailings facility will not be fenced as it is not expected to contain water that would be harmful to wildlife coming in contact." The possibility of birds, ungulates, species at risk, and other wildlife accessing the tailings storage facility (TSF) for drinking water, or otherwise is not discussed in sections 6.2.1.11, or 6.4.1.11 of the EIS. As referenced above, there are two locations in the EIS that conflict on the need for fencing and netting around the TSF. In section 6.4.1.13 (EIS), reference is made to a fenced perimeter around the TSF with the possibility of netting to prevent entry of migratory birds and in Appendix F the inclusion of a fence around the TSF is not described. In particular, netting to prevent entry of migratory waterfowl from the TSF could be problematic as it has the potential to trap and cause harm or mortality to migratory birds and other wildlife. There is also reference to a "tailings pool" in section 6.4.1.13 (EIS). This terminology is not used elsewhere in the document. The location of the tailings pool is not shown on the map. This information will inform the Agency of adverse environmental effects on Aboriginal health due to the potential for wildlife, hunted by Aboriginal peoples, to drink water from the tailings management area and bioaccumulate contaminants.

Information Request:

1. Describe and analyze the possibility of birds, ungulates, species at risk and other wildlife using the tailings storage facility for drinking water and provide an analysis to determine if there is a risk to wildlife that may access the tailings storage facility. Provide a revised assessment of significant adverse effects on wildlife as described in EIS section 6.4.1.11, based on this information.
2. Clarify the intent and rationale for including or not including features to exclude wildlife from the tailings storage facility.
3. Clarify whether the tailings pool is different from the tailings storage facility. If it is indeed different, provide information on its location (shown on a map), size, and planned use and operation.

IR-1 Reference #: WL(1)-06
Links to Annexes A3 and A4: AC(1)-87
s.5 Effect/Valued Component/EA Item: Monitoring Program; Current Use of Lands and Resources for Traditional Purposes
Reference to EIS Guidelines: Section 9.1.2, 16
Reference to EIS: EIS Sections 11.3, 13.7
Summary of Comment/Rationale: Section 13.7 (EIS) states: "A wildlife monitoring plan will be implemented to ensure that effects on wildlife are properly mitigated. EMP monitoring will be based, where possible, on standard survey protocols used during baseline studies so that any changes in local species populations may be detected." The baseline information gathered is primarily presence/absence information. If population changes such as abundance are to be detected, this information needs to be collected during the baseline. The monitoring survey design should be carefully planned to ensure that it is effective in answering the questions that are being posed. No specific monitoring plans were included. This information is crucial to determining whether or not the collection of baseline data has been sufficient. In addition, no wildlife objectives for progressive rehabilitation or the decommissioning and abandonment phases are stated. There should be some measures in place to support the return of wildlife to the site that are valued components. This information is necessary to quantify the effects of the Project on wildlife in the decommissioning and abandonment phases. It will also assist the Agency in determining the potential impacts of the Project on Aboriginal peoples' current uses of lands and resources for traditional purposes. Section 6 (EIS) indicates that many of the valued components will be impacted by the mine in such a way that is reversible. For example, loss of habitat of wildlife SAR, ungulates, upland birds, wetland birds, and furbearers are said to be partially reversible. Impacts to fish abundance and distribution, and decreases in fish habitat quality are said to be partially reversible. There are no details of how these valued components (and other valued components with ‘reversible' impacts) will be monitored to ensure that they are in fact reversed.

Information Request:

1. Describe the framework for the monitoring programs for all valued components (including wildlife species at risk, ungulates, upland birds, wetland birds, furbearers, fish and fish habitat) that are designed to properly determine whether or not the impacts are reversed as claimed in Section 6 of the EIS. Provide justification for the selection of valued components that require follow-up monitoring. Also provide justification if valued components are not selected to require follow-up monitoring.
2. Provide wildlife objectives for the selected valued components for each project phase including the decommissioning and abandonment phases that can be incorporated into a follow-up monitoring program.

IR-1 Reference #: WL(1)-07
Links to Annexes A3 and A4: AC(1)-368
s.5 Effect/Valued Component/EA Item: Wetlands; Current Use of Lands and Resources for Traditional Purposes
Reference to EIS Guidelines: Section 10
Reference to EIS: EIS Sections 6.2.1.9, 6.4.1.12, 6.4.1.13, 13.1.2, Figure 13.6.1; Appendix F Section 7.2.1; Appendix M; Figure 20
Summary of Comment/Rationale: Section 6.2.1.9 (EIS) does not discuss the potential effects of dewatering on the wetlands within the anticipated zone of influence (ZOI). Section 6.4.1.12 (EIS) states: "permanent loss of up to 39.5 hectares (0.4 km²) of wetlands would occur". It is assumed that this loss is due to destruction related to mine facilities construction. However, since, it is stated that wetlands are "a dominant landcover type in this region" in section 6.4.1.13 (EIS), it is expected that other effects to wetlands are likely. Based on Figure 20 (Appendix M), the area of the 5 m drawdown cone is approximately a circle with a 1.8 km radius or an area of approximately 10 km². No discussion of the effects to the remaining wetlands that are within the dewatering area was provided. Appendix F proposes that using the two ponds near the proponent's office is the preferred alternative for the process plant freshwater source. There is no discussion regarding the impact of this dewatering on the wetlands associated with these ponds. There also appears to be a discontinuity in the model simulation results as shown in the southwest corners of the Base Case 5 m Drawdown and Zone of Influence (ZOI) boundaries in Figure 13.6.1 (EIS, page 13-7). This artefact was not discussed. The requested information will also be required in complete detail during the provincial permitting phase when applying for the required permits to take water.

Information Request:

1. Describe the anticipated effects of water takings on the wetlands that are located within anticipated zone of influence (ZOI).
2. Describe the numerical artefact observed in the model simulation results on the southwest corner of the drawdown contours as shown in Figure 13.6.1 (EIS, page 13-7) and any errors in the model results that may be associated.

IR-1 Reference #: WL(1)-08
Links to Annexes A3 and A4: AC(1)-318; AC(1)-288; AC(1)-363; AC(1)-367; AC(1)-404
s.5 Effect/Valued Component/EA Item: Ungulates; Current Use of Lands and Resources for Traditional Purposes
Reference to EIS Guidelines: Section 9.1.2
Reference to EIS: Appendix G, section 8.3.3
Summary of Comment/Rationale: Section 8.3.3 (Appendix G) states: "Moose aquatic feeding areas, calving sites, mineral licks, and animal denning sites were mapped from OMNR data." The information that has been collected by the Ministry of Natural Resources and Forestry (MNRF) in the past is minimal and has been collected for the purpose of forestry operations specifically in areas where forestry is planned. It is very likely that no surveys were done in the project area for calving sites, mineral licks, and animal denning sites. As a result, MNRF surveys in this area were extremely limited. Data collection on moose aquatic feeding areas, calving sites, mineral licks, and animal denning sites is not sufficient to determine whether or not these Significant Wildlife Habitat features occur in this area. This information will assist the Agency in determining the potential impacts of the Project on Aboriginal peoples' current uses of lands and resources for traditional purposes.

Information Request:

1. Collect data on moose aquatic feeding areas, calving sites, mineral licks, and animal denning sites to determine if Significant Wildlife Habitat features occur in the local and regional study areas. Analyze results from the data collected on moose aquatic feeding areas, calving sites, mineral licks, and animal denning sites to identify potential impacts on the ability of Aboriginal peoples to exercise traditional land use practices.

IR-1 Reference #: WL(1)-09
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Species at Risk
Reference to EIS Guidelines: Section 11
Reference to EIS: EIS Section 6
Summary of Comment/Rationale: Mitigation measures are vague in regard to species at risk. The proponent needs to elaborate on the following proposed mitigation: "Maintain outflow water quality standards to maintain wetland health". The specific processes to be put in place remain unclear.

Information Request:

1. Describe the specific mitigation measures to be put in place to protect plant and wildlife species at risk.

IR-1 Reference #: WL(1)-10
Links to Annexes A3 and A4: AC(1)-288; AC(1)-319; AC(1)-363; AC(1)-367; AC(1)-404
s.5 Effect/Valued Component/EA Item: Species at Risk
Reference to EIS Guidelines: Sections 7.1.1, 9.1.2
Reference to EIS: EIS Sections 5.10.3.2, 6.3.1.11, Table 6.3.1; Appendix G; Appendix R
Summary of Comment/Rationale: Section 5.10.3.2 (EIS) states that no reptile, amphibian, or terrestrial invertebrate species at risk (SAR) was detected in the local study area. As such no reptile valued components (VCs) were identified due to "low probability of a reptile or amphibian SAR occurring in the Project area." Small terrestrial mammals were also not selected as a VC for the same reason. The proponent justifies not selecting these VCs by stating that mitigation measures will benefit these animals as a matter of course. This suggests that mitigation measures will leave the project area in better condition than it was pre-project and that these species will be drawn to the area as a result. However, the baseline information and proposed mitigation measures are not adequately described or justified, particularly for SAR. Appendix R confirms the presence of four frog species and one salamander observed over two separate sampling days. In Appendix G, the identification of spring peepers singing in chorus may indicate Significant Wildlife Habitat (http://www.ontario.ca/document/guide-significant-wildlife-habitat). In addition, Table 8.13 (Appendix G, page 187) identifies turtle nesting habitat, and amphibian woodland breeding pools as being present in the local study area (LSA) and section 8.6 (Appendix G) states habitat for snapping turtle, a federal SAR, occurs in the LSA and this species may breed in the LSA. These survey results and observations contradict the proponent's rationale for the decision not to include reptiles and amphibians as a VC. Also, the locations where snapping turtles were surveyed and the timing of the surveys are not clear in the document.

Information Request:

1. Revise the effects assessment to include reptiles, amphibians and terrestrial invertebrates, and small mammals as valued components. Provide the indicators used to assess potential project effects on the VC.
2. Provide detailed descriptions, including Ecosite information and maps, of the various habitats of the additional VCs (i.e., reptiles, amphibians and terrestrial invertebrates, and small mammals), including ecological descriptions, potential locations for the habitats within the project footprint and LSA, and size of habitat areas potentially affected by the Project.
3. Describe potential impacts on, and mitigation for, the specific habitat types where reptiles, amphibians, terrestrial invertebrates and small mammals are found.
4. Explain with scientific justification the assumption that "mitigation measures will benefit these animals as a matter of course."
5. Provide a summary of the locations and timing of surveys for snapping turtles. Provide Ecosite information of the sites surveyed in order to determine how much of the potential habitat was surveyed.

IR-1 Reference #: WL(1)-11
Links to Annexes A3 and A4: AC(1)-363; AC(1)-367; AC(1)-404; AC(1)-420
s.5 Effect/Valued Component/EA Item: Species at Risk
Reference to EIS Guidelines: Section 9.1.2
Reference to EIS: Appendix R, Section 2.3
Summary of Comment/Rationale: Section 2.3 (Appendix R) indicates that small mammal trapping was completed in October 2013. Ministry of Natural Resources and Forestry (MNRF) protocols suggest that mammal trapping be done between July – September. If any conclusions are drawn based on the catch-per-unit-effort during the small mammal trapping, the accuracy of these conclusions may be questionable.

Information Request:

1. Conduct additional small mammal trapping surveys according to MNRF protocols and prescribed time period, and include the survey findings and results in the updates to related EIS sections and appendices.

IR-1 Reference #: WL(1)-12
Links to Annexes A3 and A4: AC(1)-363; AC(1)-367; AC(1)-404
s.5 Effect/Valued Component/EA Item: Species at Risk
Reference to EIS Guidelines: Section 9.1
Reference to EIS: Appendix R, Section 3.3.2
Summary of Comment/Rationale: Section 3.3.2 (Appendix R) states: "Five out of six monitoring locations where the ultrasonic recorders were deployed recorded Little Brown Myotis (Myotis lucifugus), one location detected Northern Myotis (Myotis septentrioalis)Ultrasonic recorders only indicate presence/absence as opposed to quantity (Table 3.9)." Little Brown Bat and Northern Myotis are listed as endangered species in Part 2 of Schedule 1 of the federal Species at Risk Act. Also both these species are listed as endangered on the Species at Risk List of Ontario and receive species and habitat protection under Ontario's Endangered Species Act. The presence of bats suggests that there is potential for protected bat habitat to occur within the project footprint. Specifically, there is the potential for natural and anthropogenic maternity roosts for both species. To determine whether maternity roost habitat is present, bat roosting surveys of Little Brown Myotis and Northern Myotis during the roosting period at the abandoned structures located at UTM: 528144 E, 5511709 N are required. The old underground ramp, where exploration occurred and is now sealed may also be a potential roosting and/or hibernacula site for bats. In addition, the quantification of the quality of potential maternity roost habitat present through ELC delineation and snag density calculations is required. Dryden District MNRF will provide more information for guidance on survey and habitat quantification methodologies.

Information Request:

1. Determine the use of the abandoned structures by protected bat species, using exit surveys executed in accordance with MNRF protocols and recommended procedures. Provide documentation of results, and where signs of protected species are detected, revise the effects assessment accordingly.
2. Provide Ecosite (ELC) information for potential high quality bat habitat.
3. Conduct a snag survey in accordance with MNRF protocols and recommended procedures to determine the quality of bat habitat within the project footprint based on ELC information and snag tree calculations. Provide documentation of results, and revise the effects assessment accordingly.

IR-1 Reference #: WL(1)-13
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Species at Risk
Reference to EIS Guidelines: Sections 9.1.2, 11.4, 16
Reference to EIS: EIS Sections 6.4.1.13, 11.3, 11.5, 12.4.2, 13.7; Appendix R
Summary of Comment/Rationale: Species at Risk (SAR) information in the project phase tables presented in section 6 (EIS) focuses primarily on bats. Considering that six bird SAR were identified in the local and regional study areas, these birds should also be discussed. Section 3.2.5 (Appendix R) states: "Avian SAR detected at the Project Study area include Bald Eagle, Common Nighthawk, Barn Swallow, Canada Warbler and Olive-sided Flycatcher (Figure 3.4). Other SAR that may occur based on available habitat but were not detected in 2012 include American White Pelican (Pelecanus erythrorhynchos – Threatened), Black Tern (Chlidonias niger – Special Concern), Bobolink (Dolichonyx oryzivorus – Threatened), Eastern Whip-poor-will (Threatened), Golden Eagle (Aquila chrysaetos – Endangered), Least Bittern (Ixobrychus exilis – Threatened), Peregrine Falcon (Falco peregrinus – Special Concern), Short-eared Owl (Asio flammeus – Special Concern), and Yellow Rail (Endangered)." Follow-up monitoring is listed as none required for changes in VC populations as a result of habitat removal. A follow-up program should be designed to determine if the predictions regarding displacement of migratory birds and SAR are accurate. The monitoring plan should be informed by information collected during baseline studies and presented in the effects assessment. The effects assessment should estimate the amount of habitat (by Ecosite type) to be removed and the associated breeding bird community population (using density estimates) by species. The follow-up program should therefore assess the use of the local study area (and regional study area, if applicable) by breeding birds (including SAR) to determine if the residual effects were properly predicted during the construction and operation phases. Once reclamation has begun, habitat restoration should be monitored to determine the habitat characteristics (by Ecosite) and evaluate the breeding bird community (migratory birds and SAR) compared to the baseline conditions. Follow-up monitoring should also be considered to gauge the level of common nighthawk activity on and in the vicinity of roads. The monitoring results will inform mitigation planning, i.e. scheduling traffic to avoid peak time periods when nighthawks are observed roosting on gravel roads.

Information Request:

1. Revise the effects assessment to include bird SAR as VCs. Provide the indicators used to assess potential project effects on the VC.
2. Design a follow-up program to determine if the predictions regarding displacement of migratory birds and bat and bird SAR are accurate.
3. Design and provide a follow-up monitoring program to gauge the level of common nighthawk activity on and in the vicinity of roads.

IR-1 Reference #: WL(1)-14
Links to Annexes A3 and A4: AC(1)-161; AC(1)-363; AC(1)-367; AC(1)-404
s.5 Effect/Valued Component/EA Item: Species at Risk
Reference to EIS Guidelines: Section 9.1.2
Reference to EIS: EIS Section 5
Summary of Comment/Rationale: Section 5.9.5 (EIS) states that intensive nest searches were not conducted. The proponent used evening surveys for bird IDs, which the proponent claims are allowable but admits will likely result in lower detection probability. This statement suggests additional survey work is needed. However, it is unclear whether the proponent intends to complete a more comprehensive survey. Also, the proponent should explain the difference between stick and active nests referred to in section 5.9.5 (EIS): "No active stick nests were detected within the LSA; however, active nests were detected for several species."

Information Request:

1. Explain why current survey sampling methods are adequate and justify why further studies are not necessary to reliably predict migratory bird species and bird SAR in the project area.
2. Clarify the statement from section 5.9.5 (EIS) about active stick nests and active nests.

IR-1 Reference #: WL(1)-15
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Migratory Birds; Species at Risk
Reference to EIS Guidelines: Section 9.1.2
Reference to EIS: EIS Section 5.10.3.2; Appendix R Section 2.2.1
Summary of Comment/Rationale: Section 5.10.3.2 (EIS) states: "The 2013 marsh bird surveys were conducted in accordance with Bird Studies Canada protocols. However, the choice of evening surveys, though allowable in the protocol, will result in lower detection probability of target species. In addition, the Bird Studies Canada protocol does not do a good job of surveying one of the target species (Least Bittern), which is why a new national Least Bittern survey protocol has been developed as part of the proposed Least Bittern Recovery Plan (Environment Canada 2011)." If the 2013 Marsh Monitoring Program surveys were not adequate to detect Least Bittern, then the proponent should provide justification as to why the national Least Bittern protocol was not used, considering it was publically available in late 2011 with the separate release of the Proposed Least Bittern Recovery Strategy and Survey Protocol.

Information Request:

1. Provide scientific justification as to why the national Least Bittern protocol was not used.

IR-1 Reference #: WL(1)-16
Links to Annexes A3 and A4: AC(1)-363
s.5 Effect/Valued Component/EA Item: Migratory Birds; Species at Risk
Reference to EIS Guidelines: Section 9.1.2
Reference to EIS: Appendix G; EIS Section 11.3.5
Summary of Comment/Rationale: The proponent states in Appendix G: "Barn swallows were observed foraging over ponds, lakes, fields and other open habitat in the LSA and were commonly observed along roads. Active nests were observed on buildings on the former tree nursery grounds in June 2011." Section 11.3.5 (EIS) states: "All buildings and infrastructure will be dismantled and removed from site to a licensed landfill." and "The former Tree Nursery buildings will be retained and serve as the base of operations for closure and monitoring activities as well as ongoing mineral exploration programs." Barn swallows are migratory birds that are assessed and designated as a threatened species by the Committee on the Status of Endangered Wildlife in Canada. In addition, this species is listed as threatened on the Species at Risk List of Ontario and receives species and habitat protection under Ontario's Endangered Species Act. As such, barn swallow surveys should be conducted in accordance with MNRF protocols and recommended procedures. (See also RG(1)-19 in Table 1 of Annex A2.)

Information Request:

1. Complete an Information Gathering Form to provide information on any potential impacts to barn swallows on the project site. This includes nesting barn swallows within the old tree nursery buildings, as well as any other nest locations that may be found.
2. Conduct surveys in accordance with MNRF protocols and recommended procedures to confirm the presence or absence of barn swallows. If barn swallows are confirmed to be present, revise the effects assessment, and the follow-up program.

IR-1 Reference #: WL(1)-17
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Species at Risk
Reference to EIS Guidelines: Section 9.1.2
Reference to EIS: EIS Section 6.4.1.11
Summary of Comment/Rationale: To minimize the potential for effects on roosting bats and nesting birds, Treasury will conduct all habitat clearing activity outside of bat and bird migration and breeding 0guidance includes a compilation of information on core nesting periods for all regions in Canada. Proponents can access the latest "General Avoidance Information" at: http://www.ec.gc.ca/paom-itmb/default.asp?lang=En&n=1B16EAFB-1. This information is provided to proponents in order for them to make timing decisions with respect to construction activities.

Information Request:

1. Develop and incorporate in the environmental management plan explicit timing restrictions for the clearing of vegetation to avoid impacts to migratory birds in accordance with current guidance, including http://www.ec.gc.ca/paom-itmb/default.asp?lang=En&n=1B16EAFB-1

IR-1 Reference #: WL(1)-18
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Species at Risk; Aboriginal Health and Socio-economic Conditions
Reference to EIS Guidelines: Sections 5, 10, 11
Reference to EIS: EIS Section 6
Summary of Comment/Rationale: Potential effects of wildlife interacting with project tailings is not described in effects assessment tables although it is briefly mentioned in section 6.4.1.11 (EIS), where the proponent proposes building a fence around tailings ponds and possibly covering ponds with a net to restrict entry from above. It is unclear whether the fence will be left in place after abandonment, if it is constructed. If a fence will be constructed, long-term fence maintenance requirements should also be outlined. No information is presented to describe whether a net covering the tailings pond is economically feasible or effective. Section 11.1.1 of the EIS Guidelines states: "The EIS will indicate what other technically and economically feasible mitigation measures were considered, including the various components of mitigation, and explain why they were rejected. Trade-offs between cost savings and effectiveness of the various forms of mitigation will be justified." This information will inform the Agency of adverse environmental effects on Aboriginal peoples' health due to the potential for hunted wildlife to drink water from the tailings management area and bioaccumulate contaminants.

Information Request:

1. Clarify plans to keep wildlife from interacting with tailings pond.
2. Describe the anticipated effectiveness of the proposed mitigation measures to limit wildlife interaction with the tailings storage facility.

IR-1 Reference #: WL(1)-19
Links to Annexes A3 and A4: AC(1)-363; AC(1)-367
s.5 Effect/Valued Component/EA Item: Species at Risk
Reference to EIS Guidelines: Section 9.1.2
Reference to EIS: Appendix G, Section 8.3.2.1; Figure 8 .2; Appendix R Sections 2.2.1, 2.2.4, 3.3.2, Tables 3.2 – 3.8, 3.9, Figure 3.6
Summary of Comment/Rationale: Fifty-nine stations located at least 250 m apart were selected to sample the full range of habitats present in the local study area (LSA). The distribution of bird and bat survey points (Breeding Bird Survey, Marsh Monitoring Program, Whip-poor-will, and Bats) within the LSA is an important aspect to determine whether potential project effects are accurately predicted. It appears as though the area for the tailings storage facility and the habitat type contained within it are not adequately sampled. Maps presenting any point count or song recorder locations with Ecosite information and a table with a summary of all point counts by Ecosite (ELC) for the project footprint, LSA, and RSA would be of assistance in understanding the sampling that was conducted. This information is needed to determine if the project footprint has been adequately characterized and the effects on migratory birds and SAR can be accurately determined. All of the bird and bat survey information from 2011 to 2013 (DST and KCB baseline reports combined) should be summarized to facilitate the review. A summary of Ecosite information by major habitat types (Coniferous, Deciduous, Succession, Wetland, and Upland) is required in order to determine specific habitat associations and effects on migratory birds and species at risk. The proponent should also provide a summary table with the number of each species and amount of habitat to be removed within the project footprint. To allow for a review of effects on wildlife, the footprint information should be provided as a total and by project component (i.e. Waste Rock Stockpile Area, Ultimate Pit, Overburden Stockpile Area, Low Grade Ore Stockpile, Processing Plant and Tailings Storage Facility).

Information Request:

1. Provide maps presenting all point count or song recorder locations that include Ecosite information, and a table with a summary of all point count locations by Ecosite (ELC) for the project footprint, LSA and RSA.
2. Provide a summary of all of the bird and bat survey information from 2011 to 2013, following the format in Appendix R, Table 3.2 – 3.8.
3. Provide a summary of Ecosite information by major habitat types (Coniferous, Deciduous, Succession, Wetland, and Upland) in order to determine specific habitat associations and effects on migratory birds and species at risk.
4. Provide a summary table with the number of each species and amount of habitat to be removed within the project footprint. Present the footprint information as a total and by project component.

ATOMOSPHERIC ENVIRONMENT (including AIR QUALITY, LIGHT, NOISE)

IR-1 Reference #: AE(1)-01
Links to Annexes A3 and A4: PC(1)-29; AC(1)-12; AC(1)-96; AC(1)-283
s.5 Effect/Valued Component/EA Item: Air Quality
Reference to EIS Guidelines: Section 9
Reference to EIS: Appendix J; Sections 3.2, 5.2; Table 5
Summary of Comment/Rationale: On-site baseline air quality data has not been collected for the project (Appendix J, Section 5.2). Only modeled project emissions are provided some of the predicted concentrations of metals are approaching the applicable guideline values. Therefore, baseline monitoring should be considered for some metals which are to be emitted by the Project (e.g. lead, manganese and chromium). Incorporating baseline information will provide a more accurate estimation of baseline + project emissions and ensure potential risks to human health are not underestimated. This information is important for inclusion in the human health risk assessment (see HE(1)-01). Collecting on-site background data is also important for assessing the efficacy of proposed mitigation measures and, if necessary, designing follow-up monitoring. Real-time air quality monitoring is not addressed in Appendix J. Real-time air quality monitoring is instrumental in verifying predictions and implementing mitigation measures.

Information Request:

1. Conduct baseline air quality measurements for metals that are approaching or exceeding guideline values. Describe and justify the decision not to collect on-site air quality baseline data for some metals.
2. Develop a real-time air quality monitoring plan to be implemented during all project phases.

IR-1 Reference #: AE(1)-02
Links to Annexes A3 and A4: PC(1)-29
s.5 Effect/Valued Component/EA Item: Air Quality
Reference to EIS Guidelines: Sections 9, 10.1.3, 11.4
Reference to EIS: EIS Sections 6.4.1.5, 12.4, 13.2; Tables 6.4.1, 6.4.2, 6.4.3; Appendix J; Table 5
Summary of Comment/Rationale: There appears to be inconsistencies for air quality monitoring in different sections of the EIS and there is no mention of monitoring in Appendix J. In section 6.4.1.5 (EIS) and in Tables 6.4.1, 6.4.2 and 6.4.3 (EIS, pages 6-51 to 6-59, 6-60 to 6-68, and 6-69 to 6-77), no follow-up monitoring is planned for air quality. Since TSP and PM₁₀ are expected to be above provincial thresholds at the property line (Appendix J, Table 5, page 25) and PM_2.5 and NOx (NO2) will be close to the provincial thresholds, monitoring of these four compounds should be undertaken during site preparation, construction, operation, decommissioning (closure) and abandonment (post-closure) phases. PM₁₀ and PM_2.5 should be included in the list of substances to monitor (exceedances were predicted during operation) as these substances are not included in Table 12.4.1 (EIS, page 12-3). The proponent should develop an ambient air quality follow-up monitoring program in consultation with relevant regulatory agencies that clearly outlines thresholds that trigger the need to consider additional mitigation. The plan should include the details about the monitoring parameters, methods, sampling locations, applicable standards, duration, and frequencies for information to be submitted for review prior to commencing work for the construction phase. The plan should also commit to real time ambient air monitoring during site preparation, construction, operation, decommissioning (closure) and abandonment (post-closure) phases for TSP, PM₁₀, PM_2.5, Metals and NOx at a minimum. Section 11.4 of the EIS Guidelines requires the follow-up monitoring program to monitor the effectiveness of mitigation measures in relation to environmental effects with respect to Aboriginal peoples' [health]. Also, the program should encompass measures to address public concerns, where appropriate.

Information Request:

1. Provide a comprehensive follow-up monitoring plan for air quality.

IR-1 Reference #: AE(1)-03
Links to Annexes A3 and A4: AC(1)-139; AC(1)-203
s.5 Effect/Valued Component/EA Item: Air Quality
Reference to EIS Guidelines: Section 9
Reference to EIS: Appendix J; Section 2.1.1; Table 1
Summary of Comment/Rationale: Section 2.1.1 (Appendix J) states that ozone is not addressed as an air quality issue in the report. In the absence of quantitative analysis, the environmental assessment should include a discussion of the NOx/VOC balance in the area and what the expected direction of ozone formation would be as a result of changes in NOx levels and other precursors, in order to justify its exclusion from assessment. This issue is important given the high NO2 concentrations found in certain areas.

Information Request:

1. Provide a discussion of NOx/VOC balance in the area and what the expected direction of O3 formation would be as a result of changes of NOx and other precursors in the Air Quality Study section.

IR-1 Reference #: AE(1)-04
Links to Annexes A3 and A4: AC(1)-137
s.5 Effect/Valued Component/EA Item: Air Quality
Reference to EIS Guidelines: Section 9.1.2
Reference to EIS: Appendix J; Section 3.2
Summary of Comment/Rationale: Section 3.2 (Appendix J) states: "Although it would be ideal to estimate future background air quality conditions in the area by examining historical monitoring data from similar areas, there were no suitable monitoring stations located in such an area. Therefore, the most recent available monitoring data from the closest MOE operated monitoring station was used to estimate background air quality conditions." The monitoring station in Thunder Bay is quite distant and is more urban than the study area. Pickle Lake is approximately the same distance away to the north, but this station would be more representative of the study area due to its rural setting. To avoid confusion in public review the proponent should justify their decision to use data from the Thunder Bay monitoring station. The proponent should include example calculations and methodology used to determine air quality thresholds and provide a clear explanation of why using Thunder Bay data is more/less conservative than using Pickle Lake data.

Information Request:

1. Provide rational for using air quality data from the Thunder Bay monitoring stations and provide sample calculations and methodology for determining air quality thresholds.

IR-1 Reference #: AE(1)-05
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Air Quality
Reference to EIS Guidelines: Section 10.1.3
Reference to EIS: Appendix J; Section 4.2
Summary of Comment/Rationale: Section 4.2 (Appendix J) states that "Although the NAAQOs will eventually be replaced by CAAQS, they are used as criteria for compounds for which CAAQSs have not yet been developed."; Please note that CCME is in the process of establishing CAAQS for NO2 and SO2 which will replace the NAAQOs and it is expected that the new CAAQs will be lower (more conservative) than the NAAQOs. Therefore, it is suggested to use the province of Ontario ambient air quality criteria.

Information Request:

1. Use the province of Ontario ambient air quality criteria for NO2 and SO2 for thresholds in the analysis.

IR-1 Reference #: AE(1)-06
Links to Annexes A3 and A4: PC(1)-28; PC(1)-29
s.5 Effect/Valued Component/EA Item: Air Quality;
Reference to EIS Guidelines: Section 10.1.3
Reference to EIS: Appendix J; Table 5, Section 7.4
Summary of Comment/Rationale: Table 5 (Appendix J, page 25) shows exceedances are predicted for TSP and PM₁₀ during the operational phase. PM_2.5 and NO2 are also predicted to increase significantly over background concentrations and approaching thresholds. This is a concern as health risks exist below guidelines for these non-threshold substances. It should be noted that the guiding principles of Keeping Clean Areas Clean and Continuous Improvement are operative, thus proposed mitigation measures should not be confined to meet the standards, but should also be targeted towards reducing population exposure to PM and NO2 associated with the Project (CCME 2007). Therefore, additional mitigation measures should be used to adequately protect human health. For example, the estimation of emission control efficiency for each source of emission could be undertaken in order to optimize the overall emission control efficiency of the project. Reference: http://www.ccme.ca/files/Resources/air/pm_ozone/1389_ci_kcac_e.pdf. In addition, section 7.4 (Appendix J) states: "Treasury metals will ensure that best practices are followed during the Operational phase to ensure that air emissions are minimized." All best practices applicable to the activities taking place should be followed during all phases of the Project, not only the operational phase.

Information Request:

1. Identify and describe additional mitigation measures, including best practices, to reduce PM₁₀, PM_2.5, and NO2 concentrations associated with all project activities for all phases of the Project.

IR-1 Reference #: AE(1)-07
Links to Annexes A3 and A4: PC(1)-25; PC(1)-28
s.5 Effect/Valued Component/EA Item: Air Quality
Reference to EIS Guidelines: Section 10.1.3
Reference to EIS: Appendix J; Section 3.4, Tables 3, 4, 8
Summary of Comment/Rationale: Section 3.4 (Appendix J) states that the Operational phase will pose the longest term potential air quality impact and, as a result the Operations phase alone was selected for the dispersion modelling portion of the assessment. Tables 3, 4 and 8 (Appendix J, pages 23, 25, and 43) show that the emission rates of PM_2.5 during construction/site preparation and decommissioning/restoration phases are approximately 50% of the operational phase emissions rate. However, annual TSP emissions rates during construction/site preparation and decommissioning/restoration phases are approximately doubled compared to the operational phase. It is stated that the increased emissions are further away from the receptors of interest than during the operations phase; however, since there was no discussion about restricting site access during operations, this assumption may be in question. As such, the most conservative assessment of exposure to air contaminants would be to evaluate exposure at the location of the highest predicted air contaminant concentrations. Modelling and assessment of the air quality effects of Construction and Site Preparation Phase and the Closure, Decommissioning and Restoration Phase is required.

Information Request:

1. Model and assess potential air quality impacts during construction/site preparation and decommissioning/restoration phases of the project.
2. Include dispersion modelling of short term air quality impacts from site preparation and construction activities with a focus on NOx, TSP, PM₁₀ and PM_2.5.
3. Describe how site access will be limited to workers only. If site access is not expected to be restricted, evaluate health risks to non-workers, particularly Aboriginal peoples that use proximate lands and resources for traditional purposes, using the highest predicted air contaminant concentrations (which may be on-site concentrations).
4. Include other emission sources such as emissions from on-road, aggregate pits and diesel generators in the assessment. Revise Table 4 (Appendix J) accordingly.

IR-1 Reference #: AE(1)-08
Links to Annexes A3 and A4: PC(1)-28; AC(1)-12
s.5 Effect/Valued Component/EA Item: Air Quality
Reference to EIS Guidelines: Section 9.1.2, 10.1
Reference to EIS: Appendix J, Tables 4, 5, 7; Section 7
Summary of Comment/Rationale: The following clarifications and justifications are needed in order to understand the validity of the operational phase air quality assessment: Clarify if emission sources such as aggregate pits and on site traffic (worker/passenger vehicles) have been considered in Table 4. Table 5 shows exceedance of TSP and particulate matter. Clarify if the mitigation measures and control efficiency were incorporated into the model and whether these exceedances are before or after mitigation measures. The mitigation measures described in Section 7.4 (Appendix J) do not provide detail with respect to the frequency of their application or their control efficiencies. Information on these aspects of the proposed mitigation measures is needed to better understand how they factor into the air quality assessment.

Information Request:

1. Revise Tables 4 and 5 to include other emission sources, such as aggregate pits and onsite traffic, if applicable and incorporate into the impact assessment or provide justification if they are considered insignificant sources.
2. Provide a rationale as to why short term exceedances of TSP and PM₁₀ and long term (annual) exceedance of TSP is predicted.
3. Provide a summary table of mitigation measures including the control efficiency of each measure that was used for modelling (if used). If the measures and their control efficiencies were not included, modelling should be revised to include these considerations.
4. Provide detail with respect to mitigation measures, the frequency of their application and their control efficiencies.

IR-1 Reference #: AE(1)-09
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Air Quality
Reference to EIS Guidelines: Section 10.1.3
Reference to EIS: Appendix J; Section 7.3; Table 7
Summary of Comment/Rationale: Section 7.3 (Appendix J) states "Federal EA requirements prescribe that impacts be assessed at the nearest receptors, and not specifically at the property boundary. As such, the particulate levels in Table 7 (Appendix J, page 27) below reflect the predicted impacts at the nearest receptors. These are the concentration values that are applicable to the criteria as per Federal EA requirements." It is unclear which federal guidelines or reference was used for the above mentioned statement on "Federal EA requirements".

Information Request:

1. Provide a reference for the federal EA requirements mentioned on page 27 of Appendix J.

IR-1 Reference #: AE(1)-10
Links to Annexes A3 and A4: AC(1)-328; PC(1)-28; PC(1)-30
s.5 Effect/Valued Component/EA Item: Air Quality
Reference to EIS Guidelines: Section 10.1.3
Reference to EIS: Appendix J; Section 3.5.5, Table 7; List of Figures
Summary of Comment/Rationale: Locations and descriptions of sensitive receptors are not clearly presented in Appendix J. Sensitive receptors are shown in proximity to only one section of the Project boundary (as outlined in white square below). Section 3.5.5 (Appendix J) states: "Forty-four receptors of interest were identified within the local study area. Where the surface mining rights have been secured by Treasury Metals, land use was assumed to be non-sensitive and no receptors were identified. All other vacant lands in the vicinity of the Project that were found to be inaccessible (except by a rough cut-in through the forest) were not considered as receptors. Forty-two of the receptors were identified as houses. One was identified as the campground at Aaron Provincial Park. One receptor is a trailer located on otherwise vacant land. There are no receptors identified within the local study area to the north east, because Treasury Metals has surface rights to all land in that direction." While lands may be inaccessible by vehicle they are not inaccessible overall. Sensitive receptors should be identified with Aboriginal traditional use of land in mind. Owning the surface rights to a section of land does not preclude the company from identifying potential sensitive receptors on that land. The proponent's selection of sensitive receptors should be revised with these facts in mind.

There is a map indicating the location of all sensitive receptors within 20 km of the mine property line.

Maps indicating locations of all sensitive receptors and their precise locations and distinguish between Aboriginal and non-Aboriginal receptors with respect to the Project and the COPC concentrations in these locations are required. In addition, Table 7 (Appendix J, page 27) indicates that impacts are assessed at the "most-impacted receptor location". The receptors as a group are described in Section 3.5.5 (Appendix J) but the nearest receptor is not identified in the document. It is crucial to conduct impact assessment for all the sensitive receptors within 20 km of the mine property line (local study area) due to exceedances of TSP and PM₁₀. PM_2.5. NOx should also be included. In the List of Figures (Appendix J) Figure 5 is mislabeled as "Modelled Receptors". Figure 5 is actually a wind rose diagram. A "Modelled Receptors" figure is missing from Appendix J.

Information Request:

1. Revise the selection process for sensitive receptors. Describe all sensitive receptors and distinguish between Aboriginal (i.e. Aboriginal dwellings, camps, cabins, recreational sites, hunting, fishing, and country foods collecting areas, etc.) and non-Aboriginal receptors Indicate the proximity of these receptors in relation to the Project site. Provide a map that clearly shows all sensitive receptors and distinguish between Aboriginal and non-Aboriginal receptors. Also indicate the most impacted receptor's location.
2. Provide a map showing the locations of sensitive receptors versus the estimated COPC concentrations.
3. Conduct an AQ impact assessment for sensitive receptors such as the Village of Wabigoon, City of Dryden, Townships of Hartman and Zealand and Aaron Park given their proximity to the site.
4. Provide a revised version of Table 7 which identifies each receptor and that also incorporates PM_2.5 and NOx as indicators.
5. Provide an isopleth/contour map should to show the maximum predicted concentrations at each receptor.

IR-1 Reference #: AE(1)-11
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Air Quality
Reference to EIS Guidelines: Sections 10.1.3; 12.1.1
Reference to EIS: EIS Section 6; Figure 6.1.3; Tables 6.4.1, 6.4.2, 6.4.3
Summary of Comment/Rationale: Section 6.4.1.5 (EIS) does not align with Table 6.4.2 (EIS, page 6-61). The table shows magnitude and geographic extent at Level II, and frequency at Level III (residual effect occurs frequently or continuously), while the text in Section 6.4.1.5 deems these all to be Level I in determining an overall magnitude Level I. These inconsistencies need to be corrected. No methodology has been provided for determining the reversibility of effects. The determination that the "effect is readily reversible over a relatively short period", especially for PM_2.5/PM₁₀, is debatable given that exposures below the CAAQS may be associated with respiratory and cardiovascular effects. The determination that duration is Level I (residual effect is temporary or not measurable beyond given project phase) is incorrect as the operational phase is 11 years long, which provides ample time for potential adverse health effects to manifest as a result reduced air quality. Health effects that develop over 11 years may very well persist beyond this period. In summary, it is questionable to summarize across all air pollutants in the residual effects characterization when each pollutant has its own properties and potential health effects and should be considered individually. No data has been provided that quantify the frequency of exceedances and exposures leading to potential health effects.

Information Request:

1. Clarify the discrepancies between EIS Section 6.4.1.5 and Table 6.4.2.
2. Describe how reversibility of effects was determined and why all air contaminants were evaluated together given their different health effects.
3. Justify using Level I with respect to duration, taking into account the length of the operational phase and given that exposure to some air contaminants may result in adverse effects even after exposure has ceased.

IR-1 Reference #: AE(1)-12
Links to Annexes A3 and A4: PC(1)-28
s.5 Effect/Valued Component/EA Item: Air Quality
Reference to EIS Guidelines: Section 10.1.3
Reference to EIS: Appendix J
Summary of Comment/Rationale: Section 1.4 (Appendix J) states "In practice, air quality impacts from a project of this magnitude are anticipated to be indistinguishable from background levels at distances 10 km and greater from the nearest active project area. The study therefore focuses on areas within a 20 km by 20 km area." This claim needs to be quantitatively justified or a quality reference produced. The wind rose presented in Figure 5 (Appendix J, page 17) roughly indicates peak wind speeds directed toward the village of Wabigoon, Wabigoon Lake, Thunder Lake, and Dryden. The EIS should discuss the role that the wind rose data played in selecting sensitive receptors and present quantitative data justifying the choices.

Information Request:

1. Quantitatively prove that the statement presented in section 1.4 (Appendix J) is true and provide sample calculations or a reference.
2. Provide quantitative data backing up the decision to exclude the city of Dryden and the village of Wabigoon as sensitive receptors. If the data does not support this decision include these areas as sensitive receptors and revise air quality discussions/studies accordingly.

IR-1 Reference #: AE(1)-13
Links to Annexes A3 and A4: PC(1)-28; PC(1)-29; AC(1)-13
s.5 Effect/Valued Component/EA Item: Air Quality
Reference to EIS Guidelines: Section 10.1.3
Reference to EIS: EIS Section 6
Summary of Comment/Rationale: In Section 6 (EIS) the proponent appears to take a generalized approach to dispersion modelling of dust vs. gaseous emissions. Dust and gaseous emissions display different dispersion characteristics and should be discussed separately. Furthermore dust from general mining operations and dust from blasting activities should be discussed separately considering trace contaminants present in the dust, the volume of dust produced over a given time period and the height that the dust will reach in the local atmosphere. Mitigation measures are not specifically addressed for dust from blasting.

Information Request:

1. Justify why dust and gaseous emissions are grouped under the same dispersion model and LSA/RSA. If the conclusion is that they cannot be grouped, discuss and model the dispersion characteristics separately.
2. Revise corresponding figures in the EIS to show the LSA/RSA for dust and gaseous emissions.
3. Describe dust resulting from blasting activities and contrast with dust from general operations (e.g. road dust, crusher dust etc.).
4. Provide mitigation measures related to dust from blasting.

IR-1 Reference #: AE(1)-14
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Air Quality
Reference to EIS Guidelines: Section 9.1.2
Reference to EIS: Appendix J, Section 3.3.2
Summary of Comment/Rationale: Emission estimate calculations for road dust from unpaved roads assumed a silt content of 5.8% based on taconite mining and processing haul road as per Table 13.2.2-1 in AP-42 (U.S. EPA Compilation of Air Pollutant Emission Factors) and a mitigation control efficiency of 75%. The basis of the 75% control efficiency and the reason why a low silt content was assumed is unclear. The rationale and basis for these two values is needed to understand the extent to which they effect the predictions that have been made for air quality and their relevance to conditions at the site.

Information Request:

1. Provide a rationale as to why a low silt content of 5.8%, was assumed (dust emission are directly proportional to the silt content) as there are other values provided in the AP-42 table ranging from 3-16% with a mean value of 10% (9.14% is typical for mining sector in Ontario).
2. Provide an explanation for the use of 75% control efficiency.

IR-1 Reference #: AE(1)-15
Links to Annexes A3 and A4: PC(1)-53
s.5 Effect/Valued Component/EA Item: Air Quality
Reference to EIS Guidelines: Section 11.1
Reference to EIS: Appendix J, Sections 6.3, 7.4, 8.3; Appendix D
Summary of Comment/Rationale: Due to the predicted exceedances and the details missing about the Dust Best Management Plan (DBMP) and the mitigation measures, there is some uncertainty about the potential for significant adverse impacts on air quality that could result from the project. For example, it is important to understand the objectives to be achieved through air quality mitigation measures, the methods to be applied and the conditions that trigger the need for mitigation. The Proponent should be advised that compliance with the following regulations and code of practice will help to ensure that emissions are reduced throughout all phases of the project: Vehicle and fuel regulations addressing air pollutants and GHGs; On-road vehicle and engine regulations that establish maximum levels for a number of pollutants including particulate matter and ozone precursors such as NOx and VOCs; On-Road Vehicle and Engine Emission Regulations: http://laws-lois.justice.gc.ca/eng/regulations/SOR-2003-2/index.html; Off-road diesel engine emission regulations that also control these air pollutants. These have been recently updated to align with US EPA's Tier 4 regulations: Off-Road Compression Ignition Engine Emission Regulations:http://laws-lois.gc.ca/eng/regulations/SOR-2005-32/index.html; Sulphur in gasoline and in diesel regulations are in place that ensure that the fuel will not impede the effective operation of advanced emissions control technologies installed on vehicles and engines (technologies such as particulate filters): Sulphur in Gasoline Regulations: http://laws-lois.gc.ca/eng/regulations/SOR-99-236/index.html; Sulphur in Diesel Fuels Regulations: http://laws-lois.gc.ca/eng/regulations/SOR-2002-254/index.html; Passenger Automobile and Light Truck Greenhouse Gas Emission Regulations, SOR/2010–201; 74, aligned with the US, setting progressively stricter GHG emissions standards for 2011-2016 model years: http://laws-lois.gc.ca/eng/regulations/SOR-2010-201/index.html; Heavy-duty Vehicle and Engine Greenhouse Gas Emission Regulations, SOR/2013-24, apply to 2014 and later model years: http://laws-lois.gc.ca/eng/regulations/SOR-2013-24/index.html; Renewable Fuels Regulations, SOR/2010–189: http://laws-lois.gc.ca/eng/regulations/SOR-2010-189/index.html; Management practices for reducing emissions from mine fleet equipment including compliance with EC's off-road diesel engines regulations and use of tier 4 technologies and engine operation and maintenance guidelines as per EC's Environmental Code of Practice for Metal Mines (2009): http://www.ec.gc.ca/lcpe-cepa/default.asp?lang=En&n=CBE3CD59-1; The following guidance document is a valuable source of information on air quality mitigation (for example on the use of water and dust suppressants to mitigate fugitive dust from site preparation, storage piles, unpaved roads, etc.); "Best Practices for the Reduction of Air Emissions from Construction and Demolition Activities" (ChemInfo, 2005). A copy of this document can be provided by Environment Canada at the proponent's request.

Information Request:

1. Incorporate the regulations and code of practice into Best Management Plan for dust (DBMP), greenhouse gas (GHG) emission plan, Engine Maintenance Program and other mitigation actions for all phases of the project.

IR-1 Reference #: AE(1)-16
Links to Annexes A3 and A4: PC(1)-20; AC(1)-117b
s.5 Effect/Valued Component/EA Item: Light
Reference to EIS Guidelines: Section 9.1.2
Reference to EIS: EIS Sections 3, 6, 13; Appendix I
Summary of Comment/Rationale: A description of the proposed artificial lighting setup to be used for nighttime operations is not included in the EIS.

Information Request:

1. Provide a description and schematic of the artificial lighting setup to be used for nighttime operations.
2. Provide technical specifications for the proposed artificial lighting setup and model light trespass and its effect on sensitive receptors based on this information.
3. Use the information attained from the artificial lighting study to clearly define the associated LSA/RSA. Use this information to justify the current selection of sensitive receptors and the reasons for not including the city of Dryden and the village of Wabigoon as part of the LSA for light.

IR-1 Reference #: AE(1)-17
Links to Annexes A3 and A4: AC(1)-94; AC(1)-142
s.5 Effect/Valued Component/EA Item: Light
Reference to EIS Guidelines: Section 9.1.2
Reference to EIS: EIS Section 5; Appendix I
Summary of Comment/Rationale: The EIS Guidelines state: "The EIS will describe night-time illumination levels during different weather conditions and seasons." The baseline study was conducted July 2-3, 2013; no seasonal or weather based variations were discussed.

Information Request:

1. Provide baseline illumination levels that account for different weather conditions and seasons.

IR-1 Reference #: AE(1)-18
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Light
Reference to EIS Guidelines: Section 9.1.2
Reference to EIS: EIS Sections 6, 13; Appendix I
Summary of Comment/Rationale: No light monitoring program is described in section 13 (EIS) although it is referred to in the section 6 tables. Under the magnitude column in Tables 6.4.1 – 6.4.3 (EIS, pages 6-51 to 6-77) the proponent refers to light trespass being within federal/provincial guidelines. It is not clear to which guidelines the proponent is referring.

Information Request:

1. Provide a reference to the federal/provincial guidelines that will be used do define light thresholds for the Project. In the event that federal/provincial guidelines are unclear, define and justify acceptable values for magnitude of light at sensitive receptors.

IR-1 Reference #: AE(1)-19
Links to Annexes A3 and A4: AC(1)-202;
s.5 Effect/Valued Component/EA Item: Light
Reference to EIS Guidelines: Section 9.1.2
Reference to EIS: EIS Section 6; Appendix I
Summary of Comment/Rationale: Proponent has identified two light related VCs: 1. light trespass to nearby properties, 2. wildlife attraction to light sources. The proponent should elaborate on "wildlife attraction" to include specific effects on nocturnal migratory birds, species at risk, and the use of lands and resources for traditional purposes by Aboriginal peoples. Attaining this information will require engagement with local Aboriginal peoples/communities.

Information Request:

1. Assess and describe the potential effects of light on migratory birds, species at risk, and the use of lands and resources for traditional purposes by Aboriginal peoples.

IR-1 Reference #: AE(1)-20
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Noise
Reference to EIS Guidelines: Section 9
Reference to EIS: EIS Section 3.15.3
Summary of Comment/Rationale: Section 3.15.3 (EIS) is focused mainly on air quality. Currently limiting drop height is the only noise relevant mitigation measure listed. It is unclear why this sole noise mitigation measure is considered sufficient.

Information Request:

1. Revise Section 3.15.3 and provide justification why the only noise relevant mitigation measure is limiting drop height.
2. Describe the proposed mitigation strategies in the context of the Project.

IR-1 Reference #: AE(1)-21
Links to Annexes A3 and A4: AC(1)-140
s.5 Effect/Valued Component/EA Item: Noise
Reference to EIS Guidelines: Section 9
Reference to EIS: EIS Sections 3, 5, 6; Appendix H
Summary of Comment/Rationale: The LSA and RSA are not clearly defined within the EIS for noise.

Information Request:

1. Define and justify the LSA and RSA in relation to noise. Base the definition on quantitative analysis and discuss this analysis.
2. Where appropriate provide a reference to a figure illustrating the LSA and RSA for noise in the EIS.

IR-1 Reference #: AE(1)-22
Links to Annexes A3 and A4: PC(1)-02; PC(1)-31; AC(1)-189; AC(1)-200
s.5 Effect/Valued Component/EA Item: Noise/ Vibration
Reference to EIS Guidelines: Section 9
Reference to EIS: EIS Sections 6.4.1.12, 13; Appendix H
Summary of Comment/Rationale: The proponent does not discuss vibration from blasting and its effect on the surrounding area (e.g. Effect of blasting related vibration on fish/fish habitat). Furthermore the proponent has no plans to include vibration monitoring during monitoring activities. The proponent states in Section 6.4.1.12 (EIS): "Habitat avoidance and disruption of fish spawning potential from noise and vibration disturbances resulting from heavy equipment operation. Specific mitigation measures will be detailed in the EMP, which will include measures to reduce potential impacts of noise and vibration, such as utilizing well-maintained equipment operated at optimum loads." Timing is a main mitigation component to protect fish spawning sites from equipment that causes noise and vibration. Consider listing timing restrictions as a mitigation measure to protect spawning shoals for fish species from noise and vibration impacts.

Information Request:

1. Assess vibration related to blasting at the project site and describe potential effects and related mitigation strategies. Provide quantitative analysis to support the vibration assessment and mitigation strategies.
2. Justify the decision to not implement vibration monitoring during blasting activities.
3. Provide a plan to implement timing restrictions as a mitigation measure to protect spawning shoals for fish species from noise and vibration impacts. If this plan is viewed as unnecessary provide justification.

IR-1 Reference #: AE(1)-23
Links to Annexes A3 and A4: PC(1)-31; AC(1)-189
s.5 Effect/Valued Component/EA Item: Noise
Reference to EIS Guidelines: Section 11
Reference to EIS: EIS Section 13.3; Appendix H; Section 10
Summary of Comment/Rationale: Section 13.3 (EIS) states, "Treasury plans to measure sound levels at (or near) residences positioned around the Project.", and "Monitoring results will be provided to the appropriate bodies through all phases of the Project". However, section 10 (Appendix H) states monitoring is not recommended under the Health Canada (HC) guidelines since the predicted levels are well below the point where adverse human health effects can potentially occur. These statements appear to contradict each other and it is unclear whether a noise monitoring program will be implemented or not. No monitoring plans are outlined or discussed in the EIS. In the case of a noise complaint the proponent states that the details of a monitoring program will be determined on a case-by-case basis. Additional details surrounding monitoring and mitigation in these cases must be presented to ensure complainants are treated consistently and fairly, and that proposed monitoring and mitigation are appropriate. In addition to monitoring, it would be beneficial to develop a formalized complaint resolution mechanism and an engagement plan given that the Project includes extended work during the day that produces high levels of noise (i.e. blasting, rock crushing, drilling), and is expected to produce noise outside of normal working hours (i.e. activities would occur 24-hours per day during the operations phase). Monitoring of sound levels during all phases of the Project to verify modeled sound levels and ensure compliance with applicable regulatory guidelines is recommended. In addition, the statement "monitoring is not recommended under the Health Canada (HC) guidelines" is false given that it is based on the DRAFT HC 2011 document that is not supported by HC. HC does not issue sound monitoring guidelines and, as such, it would be appropriate to revise this statement.

Information Request:

1. Clarify whether a noise monitoring program will be implemented and during which phases of the Project noise monitoring is planned.
2. Identify and describe potential mitigation measures that would be considered in order to reduce noise levels in the event that they are unacceptable to nearby sensitive receptors.
3. Outline a formalized complaint resolution mechanism and an engagement plan for project noise.
4. Revise the statement "monitoring is not recommended under the Health Canada (HC) guidelines".

IR-1 Reference #: AE(1)-24
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Noise
Reference to EIS Guidelines: Section 10
Reference to EIS: Appendix H; Sections 6, 7, and 8
Summary of Comment/Rationale: It does not appear that vehicle traffic to and from the project site (e.g. vehicles transporting supplies off-site) was included in the noise modelling. Given that there will be increased traffic on surrounding roads these changes should be quantitatively evaluated and discussed in the noise modelling section(s).

Information Request:

1. Include traffic to and from the project site in the noise modelling.

IR-1 Reference #: AE(1)-25
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Noise
Reference to EIS Guidelines: Section 9
Reference to EIS: Appendix H; Section 3
Summary of Comment/Rationale: The report states that all measurements were consistent with ISO 3744:1994 and ISO 3746:1995 measurement standards. However, both standards have been revised and replaced with ISO:3744:2010. (https://www.iso.org/obp/ui/#iso:std:iso:3744:ed-3:v1:en) and ISO 3746:2010 (https://www.iso.org/obp/ui/#iso:std:iso:3746:ed-3:v1:en). Use of current standards and guidance is recommended to ensure the noise assessment is based on the best possible characterization of baseline and project-related noise and its impact on potential noise-sensitive receptors.

Information Request:

1. Provide an explanation of how the study deviates from the current standards and discuss any uncertainties/ limitations resulting from the use of non-current standards. If necessary revise the noise study using the most recent standards and guidance.

IR-1 Reference #: AE(1)-26
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Noise
Reference to EIS Guidelines: Section 10.1.3
Reference to EIS: Appendix H, Section 4.2.1
Summary of Comment/Rationale: Current guidance on noise (http://www.hc-sc.gc.ca/ewh-semt/pubs/eval/environ_assess-eval/index-eng.php) refers to potential noise sensitive receptor locations as any areas in which receptors could be considered to have a reasonable expectation of "peace and quiet" (i.e. "quiet rural areas"). Section 4.2.1 (Appendix H) states the noise sensitive receptor locations are identified using the Ministry of Environment and Climate Change (MOECC) definition of noise sensitive receptor. However, it is unclear whether current use of lands and resources by Aboriginal peoples for traditional purposes was considered in identifying the noise sensitive receptor locations.

Information Request:

1. Engage local Aboriginal groups to identify current use of lands and resources for traditional purposes in areas around the project footprint and incorporate this information in the identification of sensitive receptor locations and the noise assessment.

IR-1 Reference #: AE(1)-27
Links to Annexes A3 and A4: PC(1)-24
s.5 Effect/Valued Component/EA Item: Noise
Reference to EIS Guidelines: Section 10
Reference to EIS: Appendix H, Section 4.2.1.2
Summary of Comment/Rationale: Section 4.2.1.2 states: "There is a non-linear relationship between Percent Highly Annoyed and LEQ. In practice this means that in a quiet area, an increase in sound level will result in a lower change in percent highly annoyed than the same change in sound level in a louder area." This statement is incorrect. In a quiet area, an increase in sound level would most likely result in a greater change in percent highly annoyed than the same change in sound level in a louder area.

Information Request:

1. Provide the rationale and reference for the statement in section 4.2.1.2 (Appendix H). If the statement is erroneous, correct the error and revise the EIS and appendices where appropriate to ensure discussion(s) of Percent Highly Annoyed are accurate.

IR-1 Reference #: AE(1)-28
Links to Annexes A3 and A4: PC(1)-24; PC(1)-31; AC(1)-189
s.5 Effect/Valued Component/EA Item: Noise
Reference to EIS Guidelines: Section 10
Reference to EIS: Appendix H, Sections 6.3.2, 7.3.2
Summary of Comment/Rationale: Sections 6.3.2 and 7.3.2 (Appendix H) both state that: "Blasting at the site is to take place no more than once per day, during daytime hours only. Since the Health Canada (HC) guidelines average sound levels over a 24-hour period, with additional penalty for the nighttime period, a single blast per day was considered to be infrequent and was not further assessed against these guidelines." Given that blasting is expected to occur during the construction/site preparation and operations phases for duration of more than one year, ISO 1996-1:2003 guidelines should be followed. According to ISO 1996-1: 2003, "because of the differences in noise annoyance to differing sources of sound, sound character, times of day, etc. adjustments should be added to measured or predicted levels." ISO 1996-1:2003 (Table A.1) presents typical adjustments based on sound source category and time of day. For highly impulsive noises (such as blasting) an adjustment level of 12 dB is recommended. For current guidance on noise, refer to "Useful Information for Environmental Assessments" publication: http://www.hc-sc.gc.ca/ewh-semt/pubs/eval/environ_assess-eval/index-eng.php

Information Request:

1. Revise Sections 6.3.2 and 7.3.2 to reflect proper guidance on noise. Make the appropriate adjustments to measured and/or predicted levels.

IR-1 Reference #: AE(1)-29
Links to Annexes A3 and A4: PC(1)-24
s.5 Effect/Valued Component/EA Item: Noise
Reference to EIS Guidelines: Section 10
Reference to EIS: Appendix H
Summary of Comment/Rationale: Section 3.3 (Appendix H) states "Sources that have characteristics considered to be particularly annoying receive additional consideration in accordance with NPC-104 guidelines (MOE, 1978). The adjustment is based on assessment at the point of reception, as described in Publication NPC-103. No sources were identified to exhibit annoying sound emissions." Publication NPC-104 Sound Level Adjustments describes when sound level adjustments to NPC-300/NPC-232 are required. The adjustments are required for any tonal, cyclical or quasi-steady impulsive sounds. The operations of fans, electrical motors, generators, drills, etc. at the site may generate these types of sounds and therefore warrant a sound level adjustment as described in NPC-104. This has not been considered in the noise assessment. The EIS (Appendix H) claims the noise sources were assessed based on the worst case scenario as required by Section A.4 of NPC-233 (Annex to Publication NPC-232). Section 1 (Appendix H) states: "This assessment focuses on sound levels due to the Project at surrounding worst-case sensitive receptors. Sources at the facility include: ventilation equipment, building exhausts, on site vehicle traffic, and rock crushing equipment." The worst case scenario presented did not include any sound level adjustments that would have lowered the allowable limits at sensitive receptors. (Note that this may also be considered during the provincial permitting process.)

Information Request:

1. Adjust sound characteristics described in Table 1 (Appendix H) accordingly to account for sound level adjustments.
2. Revise the noise assessment to include sound level adjustments in the limits at sensitive receptor locations.

IR-1 Reference #: AE(1)-30
Links to Annexes A3 and A4: AC(1)-33; AC(1)-189
s.5 Effect/Valued Component/EA Item: Noise; Species at Risk
Reference to EIS Guidelines: Section 9.1.2
Reference to EIS: EIS Section 6.4.1.3
Summary of Comment/Rationale: Tables 6.4.1 to 6.4.3 (EIS) state: "To mitigate potential noise-related effects, Treasury will utilize new, low-noise-engineered machinery, will time major activities (e.g., blasting) to minimize adverse effects, and will minimize night-time activities where practical. With the application of these appropriate mitigation and monitoring strategies, the potential Noise-related residual effects of the Project should not be significant." The EIS does not recognize or describe any effects of noise on wildlife including ungulates, furbearers, amphibians, reptiles, migratory birds and SAR. As noted on Environment Canada's ‘Incidental Take of Migratory Birds in Canada' website (http://www.ec.gc.ca/paom-itmb/Default.asp?lang=En&n=C51C415F-1), migratory birds are typically disturbed by sound levels exceeding 50 dBA. Such disturbance could contribute to adverse effects on migratory birds and SAR. The response to this IR will also assist the Agency in determining the potential impacts of the Project on Aboriginal peoples' current uses of lands and resources for traditional purposes.

Information Request:

1. Provide a map at a relatively large scale which shows the area surrounding operations affected by 50 dBA or greater, overlaid on habitat types, and a table summarizing areas within this threshold by habitat type (Ecosite). The footprint information should be provided as a total and by project component (i.e. Waste Rock Storage Area, Ultimate Pit, Overburden Storage Area, Low Grade Stock Pile, Processing Plant and Tailings Storage Facility).
2. Describe the impacts of noise on wildlife including ungulates, furbearers, amphibians, reptiles, migratory birds and SAR within the effects assessment.

IR-1 Reference #: AE(1)-31
Links to Annexes A3 and A4: PC(1)-31
s.5 Effect/Valued Component/EA Item: Noise
Reference to EIS Guidelines: Section 16
Reference to EIS: Appendix H, Sections 4, 7.2.1
Summary of Comment/Rationale: Limited details regarding the types of equipment to be used during all three phases were available at the time of the Environmental Noise Assessment. If the selected equipment varies from those modeled, modeling would need to be revisited and revised. It would also be beneficial to conduct actual noise monitoring at representative receptors to verify modeled sound levels during all project phases. Monitoring during all phases of the Project will also be beneficial given that the baseline study involved long-term measurements of background ambient sound levels conducted from December 5 to 7, 2011, and July 3 to 9, 2013, both relatively brief time periods.

Information Request:

1. Revise noise modeling for all phases if equipment selection differs from those modeled. B) Design and describe a noise monitoring program to verify modeled sound levels during all phases of the Project.

HUMAN ENVIRONMENT (including IMPACTS ON ABORIGINAL PEOPLES)

IR-1 Reference #: HE(1)-01
Links to Annexes A3 and A4: AC(1)-21; AC(1)-35; AC(1)-230; AC(1)-262; AC(1)-284; AC(1)-290; AC(1)-293; AC(1)-316; AC(1)-327; AC(1)-333; AC(1)-338; AC(1)-345; AC(1)-328; AC(1)-356; AC(1)-371; AC(1)-379; AC(1)-409; AC(1)-427; AC(1)-430
s.5 Effect/Valued Component/EA Item: Health and Socio-economic Conditions
Reference to EIS Guidelines: Section 9.1.2, 10.1.3
Reference to EIS: Section 5, 6.4.2.5, Tables 6.4.6 – 6.4.8
Summary of Comment/Rationale: Section 9.1.3 of the EIS Guidelines states: "The Proponent will include all baseline information relevant to human health in one section of the EIS. The Proponent should refer to Health Canada's Useful Information for Environmental Assessments document in order to include the appropriate baseline information relevant to human health. In describing the socio-economic environment, the proponent should provide information on the functioning and health of the socio-economic environment, encompassing a broad range of matters that affect communities and Aboriginal peoples in the study area in a way that recognizes interrelationships, system functions and vulnerabilities." Section 5 of the EIS, does not include a baseline description of Aboriginal consumption rates that are used to identify potential effects. Further, Aboriginal groups have identified that traditional land use has not been adequately described. In section 6 (EIS), human health is considered as a potential effect to the Aboriginal peoples valued component, rather than its own valued component. The characterization of residual effects is limited to a discussion of potential water quality impacts to human health.

Information Request:

1. Confirm Aboriginal receptors, including but not limited to: a. residences, cottages, cabins, camps, campsites; b. recreational and traditional land users; and c. areas used for harvesting, hunting, trapping and fishing.
2. Identify exposure pathways, including inhalation, dermal and oral exposure to air, water, soil and country foods, based on Aboriginal land use and traditional land and resource use practices. Investigate all exposure pathways as part of the human health risk assessment.
3. Engage Aboriginal groups to obtain site-specific consumption data, including water resources, species, rates, and specific parts that are consumed for fish, wildlife, and plants.
4. Define valued components and indicators to assess potential impacts to Aboriginal health, linking in the results from relevant sections of the biophysical, land use, traditional land use, and human health risk assessments, including, but not limited to: a. Air quality; b. Noise and vibration; c. Drinking water quality from ground and surface water sources; d. Recreational water quality (wading, swimming, boating, fishing, etc.); e. Access and availability to traditional foods and country foods that provide food security, nutrition and have cultural value; and f. Contamination of country foods including wildlife, fish and plants, through air, water, and soil.
5. Using the valued components identified in part D of this IR, identify potential effects to Aboriginal human health where exposure pathways exist (including exposure rates for specific contaminants), and clearly define mitigation measures for potential Aboriginal human health effects.
6. Apply an impact matrix methodology to determine the significance of residual effects of the Project on Aboriginal human health for each of the project components and physical activities, in all phases, incorporating the results from relevant sections of the biophysical, land use, traditional land use, and human health risk assessments.
7. Describe a follow-up program that includes measures related to Aboriginal human health, including monitoring measures to verify environmental assessment predictions and to verify the efficacy of mitigation measures. Identify how and which Aboriginal groups will be engaged during implementation of the follow-up program.

IR-1 Reference #: HE(1)-02
Links to Annexes A3 and A4: PC(1)-24; AC(1)-328
s.5 Effect/Valued Component/EA Item: Health and Socio-economic Conditions
Reference to EIS Guidelines: Section 10.1.3
Reference to EIS: Appendix W, Section 4.2.2
Summary of Comment/Rationale: A number of contaminants of concern (COCs) were identified in waste rock and tailings for the operations phase of the project (i.e., aluminum, arsenic, cadmium, chromium, cobalt, copper, iron, lead, mercury, nickel and zinc). Despite this, only mercury and lead were retained as human health COCs in the HHRA. No justification was provided in the report for excluding the other COCs identified. For those identified COCs with screening criteria available, no Tier 2 screening against applicable human health component values was conducted. In addition, for those identified COCs without screening criteria available (i.e., aluminum and iron), no justification for exclusion was provided, such as whether they would be expected to be present at non-toxic levels. Such discussions should be included in the human health risk assessment (HHRA) to ensure transparency in any of the decisions made in the HHRA. Other metals may pose other health effects not considered in the HHRA. Focusing solely on mercury and lead does not account for the fact that some of the COCs may act via the same target organ and/or via a similar mode of action, and as such the potential for additive risks was not considered in this HHRA. Summing up the effects of substances that affect the same target organ(s) (non-carcinogens) and also for those substances that can result in the same types of cancers(s) (carcinogens) to ensure health risks are not underestimated is preferred.

Information Request:

1. Describe the evaluation process for screening in COCs in the HHRA and provide a justification for excluding any COCs identified in waste rock and tailings for the Operational phase of the project.
2. For the screened in COCs sum up the effects of non-carcinogenic substances that affect the same target organ(s) and also sum up the effects of carcinogenic substances that can result in the same types of cancer(s).
3. In cases where COCs are screened out, explain the uncertainties and relevance of the exclusions to the conclusions of the HHRA.

IR-1 Reference #: HE(1)-03
Links to Annexes A3 and A4: PC(1)-04
s.5 Effect/Valued Component/EA Item: Health and Socio-economic Conditions
Reference to EIS Guidelines: Section 10.1.3
Reference to EIS: Appendix W, Section 4.2.4.1
Summary of Comment/Rationale: Direct soil contact via incidental ingestion and dermal contact pathways has been excluded for the operations phase (due to restricted access to the mine site) and the post-closure phase (due to the waste rock and tailings areas being covered). However, the potential for on-site surface soils (not directly on the above-ground waste rock and tailings storage areas) to become contaminated as a result of wet/dry deposition of dust generated during the 12-year operations phase has not been considered. In addition, since access to the mine site during the post-closure phase will be unrestricted, it is important to consider on-site surface soils beyond the covered waste rock and tailings areas. A monitoring program should be in placed to prevent levels in soils from increasing to the point where they may pose unacceptable risks to human health.

Information Request:

1. Explain whether or not direct soil contact (i.e., incidental ingestion and dermal contact) could be considered a viable exposure pathway.
2. If direct soil contact is a viable exposure pathway, then include this exposure route in the HHRA; if it is non-viable, then provide a justification for its exclusion and discuss the uncertainties.
3. Provide a monitoring program with established trigger levels (i.e., for taking corrective actions) to minimize dispersion and deposition of the particulate-bound contaminants to on-site and off-site soils.

IR-1 Reference #: HE(1)-04
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Health and Socio-economic Conditions
Reference to EIS Guidelines: Section 10.1.3
Reference to EIS: Appendix W, Sections 2.3, 4.2.4.3
Summary of Comment/Rationale: Section 4.2.4.3 (Appendix W) notes that ".groundwater impacts in the Post-Closure Phase are expected to be negligible as the bedrock in which the Pit Lake will be located has a very low hydraulic conductivity (AMEC 2014a)." However the subsection "Mine Pit Lake" of section 2.3 (Appendix W) indicates that although the hydraulic conductivity is very low, AMEC (2014a) has identified the potential for water from the Pit Lake to infiltrate the groundwater aquifer and travel to potable water wells located to the east (and eventually to reach Thunder Lake). This appears to contradict the statement from section 4.2.4.3 (Appendix W). Section 2.3 further states: "AMEC has reported it is difficult to reliably model groundwater data downgradient during the Closure Phase. Regular monitoring to assess groundwater quality will be scheduled (AMEC, 2014b)." There appears to be discrepancy between statements regarding water infiltration to groundwater from the Pit Lake and potential effects on potable water wells. Clarification is needed to clearly and transparently document all assumptions made in this regard, and additional mitigation may be warranted to protect local drinking water supplies.

Information Request:

1. Clearly explain whether the term "negligible" pertains to infiltration of contaminants to groundwater or risk to human health via potable water wells, and provide a justification for how it is defined and quantified.
2. Describe the monitoring plan to verify predictions regarding potable water wells and the mitigation measures.
3. Provide a map that shows all potable water wells in the LSA for groundwater and distinguish between Aboriginal and non-Aboriginal potable water wells.

IR-1 Reference #: HE(1)-05
Links to Annexes A3 and A4: AC(1)-21
s.5 Effect/Valued Component/EA Item: Health and Socio-economic Conditions
Reference to EIS Guidelines: Section 10.1.3
Reference to EIS: Appendix W; Executive Summary, Section 4.2.5, Table 9
Summary of Comment/Rationale: Section 4.2.5 (Appendix W) indicates that the drinking water source for the residents of the City of Dryden (located 20 km east of the property) is Wabigoon Lake. However, the water source for the residents of the Village of Wabigoon, which is located 4 km southeast of the property, is not specified in the report. In addition, subsection "Overall SLRA Recommendations" in the Executive Summary (Appendix W) indicates that humans may drink water from Blackwater Creek and Wabigoon Lake. If humans drink water from Blackwater Creek (e.g. recreational users), there may be less dilution of site-related discharges at the point of drinking water intake compared to Lake Wabigoon (i.e. volume of Blackwater Creek is less than that of Wabigoon Lake). As such, potential human exposures (and risks) to site-related contaminants may be higher in comparison with those from Wabigoon Lake. Further, consider whether recreational fishing may also occur on Blackwater Creek, in which case fish tissue concentration could be higher than in Wabigoon Lake due to less dilution.

Information Request:

1. Clearly indicate the drinking water source(s) for the residents of Wabigoon and explain if the water source(s) can be potentially affected by aquifers containing site-related contaminated aquifers. If the concentrations of site-related contaminants (and thus potential exposures/risks) could be higher in Blackwater Creek relative to Wabigoon Lake as a result of less dilution of site-related discharges, then reflect this in the human health risk assessment (HHRA).
2. Provide information on the use of Blackwater Creek as a source of drinking water and fishing by Aboriginal and recreational users and incorporate it in the HHRA accordingly.

IR-1 Reference #: HE(1)-06
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Health and Socio-economic Conditions
Reference to EIS Guidelines: Section 10.1.3
Reference to EIS: Appendix W, Section 4.3.2, Table J
Summary of Comment/Rationale: Exposure frequency and duration terms in Table J (Appendix W, page 30) for the urban recreational receptor were derived from defaults in the detailed quantitative risk assessment (DQRA) spreadsheet (Meridian 2011). Note that use of the DQRA spreadsheet defaults is no longer supported; where possible, site-specific information should be used instead.

Information Request:

1. Use site-specific exposure frequency and duration terms for the urban recreational user, taking into account use by Aboriginal peoples. Where site-specific data is not available, provide a clear rationale to articulate why other values were used in the human health risk assessment.

IR-1 Reference #: HE(1)-07
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Health and Socio-economic Conditions
Reference to EIS Guidelines: Section 10.1.3
Reference to EIS: Appendix W, Section 4.3.2, Table J
Summary of Comment/Rationale: Urban recreational exposure frequency and duration terms in Table J (Appendix W, page 30) are 2 hours/day, 2 days/week and 35 weeks/year spent at the site. If used directly in calculating dust inhalation exposure estimates in the detailed quantitative risk assessment (DQRA) spreadsheet, they would result in significant dilution (i.e. "dose averaging") of the estimates (i.e., 2/24 x 2/7 x 35/52 = 0.016 dilution). In addition, for the resident receptor, the use of 1.5 hours per day spent outside as an exposure frequency term (in the DQRA model – see inputs used in Appendix C of Appendix W) results in a significant dilution of dust inhalation exposure estimates for that receptor (1.5/24 = 0.0625 dilution). As indicated in a footnote for Table 4 in Health Canada (2012) preliminary quantitative risk assessment guidance, dose averaging (also called "amortization" or "dilution") should be supported by chemical-specific rationale. These rationale should include factors such as: the whole-body elimination half-life of the substance, the potential for sensitive life stages (e.g., developmental effects), the persistence/reversibility of effects and whether effects are expected to be most related to the peak concentration or to the total dose (area under the curve or "AUC") of the chemical. In terms of developmental toxicants in particular (such as lead), an exposure term (ET) of 1 (i.e., no dose averaging) is most appropriate for calculating exposure (and risk) estimates as a health protective approach. For lead specifically, dilution of exposure estimates using the above exposure frequency and duration terms may not be appropriate. It is widely known that people tend to be significantly more sensitive to adverse environmental influences during various developmental stages (Hood 2006). Thus, the timing and pattern of exposure to lead may be more important than the average concentration in determining the magnitude of such effects. Secondly, as highlighted in the Health Canada (2013) lead State of the Science (SOS) report, lead's neurological effects may persist after exposures have ceased (i.e., effects may accumulate as the result of multiple exposure events). Lastly, lead has a long elimination half-life in the body. As such, a body burden of lead may build between exposure events and act as a continual source of internal exposure.

Information Request:

1. Provide chemical specific rationales for dose averaging of all exposures, taking into consideration any adjustments needed for Aboriginal peoples. In the case of using an exposure term (ET) other than 1 for developmental toxicants, provide justification why the use of the non-unity ET is considered health protective.

IR-1 Reference #: HE(1)-08
Links to Annexes A3 and A4: PC(1)-24
s.5 Effect/Valued Component/EA Item: Health and Socio-economic Conditions
Reference to EIS Guidelines: Section 10.1.3
Reference to EIS: Appendix W, Section 4.3.2, Table J
Summary of Comment/Rationale: Only one set of ingestion rates for root vegetables, other vegetables, wild game and fish are provided in Table J (Appendix W, page 30) but no age group is provided. The values appear to reflect ingestion rates for toddlers.

Information Request:

1. Specify the age group considered for the food ingestion rates provided in Table J. If other contaminants of concern are retained that have carcinogenicity as a critical effect, then use adults or multiple age groups (i.e. life time average daily dose or "LADD") or provide a justification for not using adults or multiple age groups.

IR-1 Reference #: HE(1)-09
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Health and Socio-economic Conditions
Reference to EIS Guidelines: Section 10.1.3
Reference to EIS: Appendix W, Section 4.3.2, Table J
Summary of Comment/Rationale: A fish ingestion rate of 95 g/day (presumably for toddlers) is provided in Table J (Appendix W, page 30), based on defaults provided in the detailed quantitative risk assessment spreadsheet. Note that these rates are outdated and no longer supported. Current guidance describes fish consumption values considered from various studies and surveys on fish consumption in Canada: http://www.hc-sc.gc.ca/fn-an/pubs/mercur/merc_fish_poisson-eng.php. Where subsistence users and populations are not addressed in the guidance, site-specific values (or other relevant data) should be used along with detailed rationale provided. If non-site-specific fish consumption rates are used, it is important to identify the uncertainties associated with their use (in terms of applicability to the particular site in question) and how it may impact risk assessment conclusions (e.g. level of conservatism).

Information Request:

1. Revise the assessment to adhere to current guidance on fish ingestion rates. For subsistence users and populations not addressed in the guidance, use site-specific values (or other relevant data) and provide a detailed discussion why non-site-specific values are used, along with the associated uncertainties.

IR-1 Reference #: HE(1)-10
Links to Annexes A3 and A4: AC(1)-293
s.5 Effect/Valued Component/EA Item: Health and Socio-economic Conditions
Reference to EIS Guidelines: Section 10.1.3
Reference to EIS: Appendix W, Section 4.4.2, Table M, Appendix C
Summary of Comment/Rationale: A single toxicity reference value (TRV) for mercury is provided in Table M (Appendix W, page 32). This TRV appears to be for inorganic mercury. As TRVs for mercury depend on the form (i.e. metal species) of mercury present, please specify the specific species that is being assessed in the risk assessment and discuss whether other species of mercury are expected to be found as well at this site. In addition, in the detailed quantitative risk assessment output sheets in Appendix C of Appendix W, both inorganic mercury and methylmercury were considered for country foods scenarios. It is also important to include the TRV used for methylmercury in Table M (Appendix W, page 32).

Information Request:

1. Specify the form(s) of mercury for the mercury TRV (i.e. inorganic mercury) and include a methylmercury TRV.
2. Provide a rationale to explain which forms of mercury are expected to be present at this site and for which media.

IR-1 Reference #: HE(1)-11
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Health and Socio-economic Conditions
Reference to EIS Guidelines: Section 10.1.3
Reference to EIS: Appendix W, Section 4.4.2, Table M
Summary of Comment/Rationale: A toxicity reference value (TRV) for lead of 0.0036 mg/kg-bw/day (assuming the units of "µg/kg-bw/day" are erroneous) is provided in Table M (Appendix W, page 32) based on the detailed quantitative risk assessment spreadsheet. Note that this TRV is from outdated guidance. It is recommended that lead TRVs, which are based on more recent science be considered with sufficient rationale provided. The use of a TRV for lead from another regulatory agency should be accompanied with sufficient justification for its selection. Alternate TRVs, including risk-specific doses (RSDs) from EFSA (2013) or WHO/JECFA (2011) may be used in quantitative risk assessments, with appropriate scientific rationale.

Information Request:

1. Revise the assessment to use a lead TRV which is based on more recent science, such as EFSA (2013) or WHO/JECFA (2011), with rationale provided to support the choice as protective of the developing fetus and women of childbearing age.

IR-1 Reference #: HE(1)-12
Links to Annexes A3 and A4: AC(1)-231
s.5 Effect/Valued Component/EA Item: Health and Socio-economic Conditions
Reference to EIS Guidelines: Section 10.1.3
Reference to EIS: Appendix W, Section 4.5.5
Summary of Comment/Rationale: Estimated concentrations of lead and mercury in plants were spatially adjusted based on the size of the tailings and waste rock management areas (125 ha) relative to the potential gathering area in the region (6341 ha, based on the blueberry habitat size used as a surrogate to represent other plants). Spatially adjusting such concentrations assumes residents and recreational users are equally likely to gather plants from any one area in the region and no preferential gathering from specific areas would occur (which may or may not be the case for this region). There is an uncertainty in the assumption that receptors would be expected to exhibit an equal likelihood of gathering plants from any one location in the region. Also, the potential for preferential uptake of identified contaminants of concern (COCs) in waste rock and tailings, other than lead and mercury should be considered, and the impact of this in terms of human exposure (and risk) be discussed. In addition, only lead and mercury were considered in the country foods assessment, despite some other metals being identified as COCs in waste rock and tailings. The potential for these other identified COCs to be translocated into plants from soils has not been considered. Some of these metals could be preferentially taken up into plants, resulting in concentration profiles differing between plants.

Information Request:

1. Provide justification, using scientific rationale, to explain spatially adjusting the concentrations and the potential for preferential uptake of identified contaminants of concern in waste rock and tailings.
2. Explain why metals other than lead and mercury are excluded and discuss the impact of this in terms of human exposure and risk.

IR-1 Reference #: HE(1)-13
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Health and Socio-economic Conditions
Reference to EIS Guidelines: Section 10.1.3
Reference to EIS: Appendix W, Section 4.5.5
Summary of Comment/Rationale: A planned cap of 1 m of clean soil over the waste rock and tailings areas post-closure is indicated to likely decrease the concentrations of lead and mercury (and potentially other metals that were not carried forward in the human health risk assessment as previously discussed) in plants that grow over these areas. While this assumption may be the case for plants with shallow root systems (i.e. berries and mushrooms), it may not be the case for other gatherable plants. The Canadian Council of Ministers of the Environment (CCME)'s definition of "surface soil" is soils located within 1.5 m below ground surface (mbgs) (CCME 2006). This definition is based on the fact that terrestrial plant growth (i.e., root systems) may reach as deep as 1.5 mbgs. Therefore rationale is needed for the chosen depth which may include detailing the types of edible plants that are currently on the site and the depth of those root systems (and any other relevant information).

Information Request:

1. Explain why the depth of soil cap chosen, as opposed to 1.5 m, is sufficient to lessen human exposures (and risks) via consumption of plants growing on the waste rock and tailings areas post-closure.

IR-1 Reference #: HE(1)-14
Links to Annexes A3 and A4: AC(1)-311
s.5 Effect/Valued Component/EA Item: Health and Socio-economic Conditions
Reference to EIS Guidelines: Sections 10.1.3, 11.4
Reference to EIS: EIS Table 12.4.2; Appendix W; Section 4.5.6
Summary of Comment/Rationale: Table 12.4.2 (EIS, page 12-9) does not provide information on the frequency, duration, and number of samples to be collected for each of the aquatic biology measures. Also, no information on measuring contaminants aside from mercury is mentioned in the proposed biological monitoring plan. In section 4.5.6 (Appendix W), lead fish tissue concentrations were based on lower-trophic level fish species caught from Blackwater Creek, unlike the higher-trophic level species caught in Wabigoon Lake used to measure mercury tissue residue data. The use of lower-trophic level species for lead may underestimate lead concentrations in fish tissue from Wabigoon Lake. The fish species and chemicals selected for this type of project were incomplete. Additional baseline tissues analyses would help to reduce the uncertainty surrounding baseline levels of contaminants of potential concern in country foods, and particularly in the predicted project case scenario.

Information Request:

1. Provide details on the monitoring plan, including objectives and questions to be answered. Explain whether baseline data collection is adequate and if not, describe the plan to collect sufficient data for the monitoring plan.
2. Provide a rationale as to why lead concentrations from lower-trophic level fish species would be a reasonable approximation of higher-trophic level species.
3. Provide justification, using health science-based rationale, the plan to only measure mercury (i.e. no other contaminants) in fish tissue.

IR-1 Reference #: HE(1)-15
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Health and Socio-economic Conditions
Reference to EIS Guidelines: Section 10.1.3
Reference to EIS: Appendix W, Sections 4.7, 7.3
Summary of Comment/Rationale: The conceptual site model assumed that soil direct contact pathways of incidental ingestion and dermal contact were not operable for humans at this site during the post-closure phase as above-ground waste rock and tailings areas would be covered with either an impermeable barrier or with 1 m of soil and vegetation. To ensure that direct soil contact will not occur after closure, it will be beneficial to verify the integrity of the cover.

Information Request:

1. Describe a plan to monitor the cover for the above-ground waste rock and tailing areas during the post-closure phase to verify the exposure pathways remain inoperable.
2. If on-site soils are used as cap soil, revise the assessment to include the potential for contamination of those soils due to wet/dry deposition of suspended dust during the operations phase or provide justification why the revision is not required.

IR-1 Reference #: HE(1)-16
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Health and Socio-economic Conditions
Reference to EIS Guidelines: Section 10.1.3
Reference to EIS: Appendix W, Tables 1, 2, 5
Summary of Comment/Rationale: Several chemicals had no measured concentration data available in waste rock (Table 1, Appendix W), tailings (Table 2, Appendix W) or impacted drinking water (Table 5, Appendix W) and were not retained in the human health risk assessment because "No site data provided do not retain." Further justification for screening out contaminants based on a lack of measured or modelled concentration data is needed, particularly as some of these chemicals had screening criteria available and/or baseline concentration data available (e.g., beryllium, boron, molybdenum, selenium, etc.) but no waste rock, tailings or impacted drinking water concentrations with which to compare them.

Information Request:

1. Provide justification to explain why site data were not generated for some chemicals and whether such site data will be generated at a later point.
2. Discuss whether a lack of site data for some chemicals should be cited as an uncertainty and indicate whether risks may be underestimated as a result.

IR-1 Reference #: HE(1)-17
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Health and Socio-economic Conditions
Reference to EIS Guidelines: Section 10.1.3
Reference to EIS: Appendix W, Table 2
Summary of Comment/Rationale: The maximum concentration of antimony in tailings, 11 mg/kg, exceeds the MOE (2011) Table 2 residential site condition standard of 7.5 mg/kg. Despite this, antimony was not retained as a contaminant of concern for tailings with the following rationale provided: "Does not exceed guideline, do not retain".

Information Request:

1. Verify the antimony concentrations in the report and explain whether it should be retained as a contaminant of concern in tailings to ensure potential health risk is not underestimated.

IR-1 Reference #: HE(1)-18
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Health and Socio-economic Conditions
Reference to EIS Guidelines: Section 10.1.3
Reference to EIS: Appendix W, Table 3
Summary of Comment/Rationale: Analyte dust concentrations for a variety of metals are provided in Table 3 (Appendix W), but not for mercury (one of the two contaminants of concern retained in the human health risk assessment). As no mercury dust concentration is provided in this table or in Table H (Appendix W, page 29), it is unclear what mercury concentration in suspended particulate matter was used to derive the inhalation hazard quotient for mercury.

Information Request:

1. Provide the mercury exposure point concentration in suspended particulate matter that was used in the human health risk assessment for generating the inhalation exposure and risk estimates.

IR-1 Reference #: HE(1)-19
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Health and Socio-economic Conditions
Reference to EIS Guidelines: Section 10.1.3
Reference to EIS: Appendix W, Table 3
Summary of Comment/Rationale: Several analytes in Table 3 (Appendix W) have more than one MOE point of impingement (POI) limit (MOE 2012a) available for different averaging periods. Despite this, only maximum POI concentrations calculated for a single averaging period (usually 24-hr) were compared to the MOE POI limits. Note that MOE (2012a) indicates: "If there are multiple standards (i.e., standards with different averaging times) in Schedule 3 or multiple guidelines, when Section 20 applies, for a particular contaminant, all of them must be used for assessment purposes [emphasis added]. This is because each represents a different type of effect linked to a particular averaging period (i.e., averaging time)." Other types of effects from exposure to these substances in air may have not been considered.

Information Request:

1. Revise the assessment and use MOE POI limits for all averaging periods in screening maximum POI concentrations (as per MOE 2012a) or provide a justification that demonstrates other types of effects from exposure to these substances in air are covered without the revision.

IR-1 Reference #: HE(1)-20
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Health and Socio-economic Conditions
Reference to EIS Guidelines: Section 10.1.3
Reference to EIS: Appendix W, Table 3
Summary of Comment/Rationale: As noted in MOE (2012a), point of impingement (POI) limits are intended to assess air quality from a single facility, and not to assess general air quality from all sources. MOE (2012a) notes that ambient air quality criteria (AAQCs) are used for environmental assessments, general air quality assessments and some special studies. As such, in addition to screening against MOE POI limits, consider also summing the maximum incremental POI concentrations with the background air concentrations (for those analytes with background concentration data available) for comparison against the MOE's AAQCs and/or Canadian Ambient Air Quality Standards.

Information Request:

1. Revise the assessment to screen the total air concentrations (i.e. maximum incremental POI concentrations + background), where possible, against health-based air quality standards and guidelines.

IR-1 Reference #: HE(1)-21
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Health and Socio-economic Conditions
Reference to EIS Guidelines: Section 10.1.3
Reference to EIS: Appendix W, Table 5
Summary of Comment/Rationale: Several contaminants of concern (COCs) were excluded "due to a lack of risk-based standards for comparison". Absence of a screening criterion is not a sufficient justification for excluding a contaminant of concern. Further discussion may include whether the COCs are expected to be present at non-toxic levels or relevant to human health.

Information Request:

1. Provide health-based justification for excluding COCs without risk-based standards for comparison.

IR-1 Reference #: HE(1)-22
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Health and Socio-economic Conditions
Reference to EIS Guidelines: Section 10.1.3
Reference to EIS: Appendix W, Table 5
Summary of Comment/Rationale: Contaminants of concern appear to have been screened using incremental concentrations (i.e. contributions to concentrations in Blackwater Creek following application of a dilution factor). Human health risk depends on the total concentration of a substance following release, not an incremental concentration. In the case of cobalt, copper, and lead, the total concentrations in Blackwater Creek during the post-closure phase (i.e. 1.79, 5.30 and 3.89 µg/L, respectively) exceed the Blackwater Creek baseline concentrations (i.e. 1.76, 5.18 and 3.76 µg/L, respectively) and the provincial water quality objectives (PWQOs) and/or interim PWQOs (i.e. 0.9, 5 and 1 µg/L, respectively).

Information Request:

1. Revise the assessment to use total concentrations of substances in Blackwater Creek (incremental + baseline) for screening against Canadian Drinking Water Quality Guidelines (CDWQGs), PWQOs and MOE (2011) Table 2 site condition standards (SCSs) for the operations and post-closure phases for comparison to the CDWQGs, PWQOs and MOE (2011) residential Table 2 SCSs.
2. Revise the assessment to retain copper and lead for drinking water purposes (post-closure phase) or provide a rationale for their exclusion.

IR-1 Reference #: HE(1)-23
Links to Annexes A3 and A4: AC(1)-371
s.5 Effect/Valued Component/EA Item: Health and Socio-economic Conditions
Reference to EIS Guidelines: Section 10.1.3
Reference to EIS: Appendix W, Table 6
Summary of Comment/Rationale: Baseline lead fish tissue data were measured based on 42 fillet samples. While sports fishermen typically consume only the skinless, boneless fillet, Aboriginal members may consume not only the fillet but also other parts of the fish (i.e. other tissues and organ meats). These other parts may or may not contain higher concentrations of some substances than in the muscle tissue.

Information Request:

1. Establish baseline concentrations for whole fish consumption or for other parts of the fish consumed by Aboriginal peoples. If the baseline data is not available, indicate as an uncertainty/limitation that only fillet baseline data were available and explain how lead concentration in fillets may differ from whole fish.

IR-1 Reference #: HE(1)-24
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Health and Socio-economic Conditions
Reference to EIS Guidelines: Section 10.1.3
Reference to EIS: Appendix W, Table 9
Summary of Comment/Rationale: Incremental concentrations of mercury and lead in fish were calculated in Table 9 (Appendix W), based on percent contribution of these two substances to Wabigoon Lake baseline water concentrations and the assumption of a direct linear relationship between water and fish tissue concentrations. These incremental concentrations were noted to be used in the "HQ spreadsheet". Risk estimates should be calculated based on total concentrations, not on incremental concentrations, as risks are proportional to total exposures. The important determinant is whether incremental contributions were sufficient to increase total levels beyond an accepted risk level.

Information Request:

1. Revise the assessment, using total concentrations of mercury and lead (i.e. sum of baseline and incremental contributions) in fish to calculate hazard quotients, so potential health risks are not underestimated.

IR-1 Reference #: HE(1)-25
Links to Annexes A3 and A4: PC(1)-24
s.5 Effect/Valued Component/EA Item: Health and Socio-economic Conditions
Reference to EIS Guidelines: Section 10.1.3
Reference to EIS: Appendix W, Appendix C
Summary of Comment/Rationale: The detailed quantitative risk assessment spreadsheet outputs are provided in Appendix C of Appendix W but no examples of worked calculations are included in the report. As per Health Canada's preliminary quantitative risk assessment guidance (Health Canada 2012b), sample calculations should be included in human health risk assessment reports. Omission of sample calculations does not allow the exposure and risk estimates to be validated.

Information Request:

1. Provide worked examples for exposure (and risk) estimates for a non-carcinogen and another for a carcinogen (if applicable) in the human health risk assessment report.

IR-1 Reference #: HE(1)-26
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Health and Socio-economic Conditions
Reference to EIS Guidelines: Section 9.1.2
Reference to EIS: EIS Section 6, Table 6.4.4; Appendix J, Table 1
Summary of Comment/Rationale: NO2 background concentrations are listed as 3.3 µg/m³ for all timescales (1-hr, 24-hr, annual) in Table 6.4.4 (EIS, page 6-78 to 6-79). However, Table 1 (Appendix J, page 8) lists NO2 background concentrations at 33 µg/m³ for both 1-hr and 24-hr (90th percentile) timescales.It is somewhat unusual for the same concentration to be reported for all timescales.

Information Request:

1. Verify the background concentrations for NO2 (1hr, 24hr, annual). Provide an explanation for the same concentrations. If there is an error, revise the affected table(s) accordingly.

IR-1 Reference #: HE(1)-27
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Health and Socio-economic Conditions
Reference to EIS Guidelines: Section 10.1.3
Reference to EIS: Appendix W, Table R
Summary of Comment/Rationale: Lead concentrations in vegetation and roots/berries of 39.15 and 9.83 mg/kg dry weight are provided in Table R (Appendix W, page 37). Verify whether these values should in fact be 4.263 and 1.305 mg/kg dry weight, based on a lead soil concentration of 0.62 mg/kg and based on soil-to-plant lead transfer factors of 0.0049 and 0.015 mg lead in dry tissue per mg/kg soil, respectively.

Information Request:

1. Verify the dry weight concentrations of lead in vegetation and roots/berries in Table R and revise the assessment and table accordingly.

IR-1 Reference #: HE(1)-28
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Health and Socio-economic Conditions
Reference to EIS Guidelines: Section 10.1.3
Reference to EIS: Appendix W, Table 3
Summary of Comment/Rationale: A MOE point of impingement (POI) limit of 36 200 µg/m³ is provided for carbon monoxide (CO) in Table 3 (Appendix W). However, MOE (2012a) only provides a 1/2-hour POI limit of 6000 µg/m³ for CO, not 36 200 µg/m³.

Information Request:

1. Verify whether the MOE point of impingement limit for carbon monoxide should be 6000 µg/m³ and not 36 200 µg/m³, and revise the assessment and Table 3 accordingly.

IR-1 Reference #: HE(1)-29
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Health and Socio-economic Conditions
Reference to EIS Guidelines: Section 10.1.3
Reference to EIS: Appendix W, Appendix C
Summary of Comment/Rationale: The "Spreadsheet Tool for Human Health Detailed Quantitative Risk Assessment (DQRA)" (Meridian 2011) was used for calculating exposure and risk estimates for the screening level human health risk assessment (HHRA). Note that this spreadsheet is a contractor report and not considered official guidance since the spreadsheet contains errors and omissions.

Information Request:

1. Revise the assessment to ensure all input parameters and calculations performed with the detailed quantitative risk assessment (DQRA) spreadsheet are in accordance with current guidance on preliminary quantitative risk assessment and DQRA for chemicals (Health Canada 2010c; 2012b).

IR-1 Reference #: HE(1)-30
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Health and Socio-economic Conditions
Reference to EIS Guidelines: Section 10.1.3
Reference to EIS: Appendix W, Table 7
Summary of Comment/Rationale: Predicted tissue concentrations of mercury and lead were summed across four wild game species (i.e., moose, deer, hare and grouse) to provide a total concentration. Summing concentrations of a substance across multiple species does not seem warranted given that concentrations of different metals are not bioavailable identically across species.

Information Request:

1. Provide a technical justification and basis for summing concentrations across multiple species to generate a total concentration.
2. Explain whether using the highest tissue concentration among the four species to represent all wild game consumed may be a more appropriate approach.

IR-1 Reference #: HE(1)-31
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Health and Socio-economic Conditions
Reference to EIS Guidelines: Section 10.1.3
Reference to EIS: Appendix W, Section 4.5.7
Summary of Comment/Rationale: A total hazard quotient (HQ) of 2.69E-02 is provided for the post-closure phase of the project for the country foods assessment. This seems to be inconsistent with the sum of the lead and mercury post-closure country foods HQs as 4.9E-02 (4.19E-02 + 7.25E-03 = 0.049).

Information Request:

1. Explain the apparent inconsistency between the total hazard quotient (HQ) for the country foods assessment for the post-closure phase and the sum of the lead and mercury HQs.

IR-1 Reference #: HE(1)-32
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Health and Socio-economic Conditions
Reference to EIS Guidelines: Section 10.1.3
Reference to EIS: Appendix W; Appendix C
Summary of Comment/Rationale: The detailed quantitative risk assessment spreadsheet output for Scenario 3 (Country Foods, Resident receptor, Operational phase) provides an inhalation hazard quotient (HQ) for lead of "5.77E-06". However, the inhalation HQ for lead for this same receptor in the spreadsheet output for Scenario 1 is "1.45E-03". As both these inhalation HQs represent the same receptor group (Resident) and project phase (Operations Phase), the reason for this discrepancy is unclear whether it is a typographical or computational error.

Information Request:

1. Provide the rationale why the inhalation HQ for lead of "5.77E-06" for Scenario 3 (operations phase) is used instead of "1.45E-03" as per Scenario 1. Indicate whether there is an error and update the assessment accordingly.

IR-1 Reference #: HE(1)-33
Links to Annexes A3 and A4: AC(1)-22; AC(1)-23; AC(1)-26; AC(1)-162; AC(1)-163; AC(1)-164; AC(1)-165; AC(1)-166; AC(1)-167; AC(1)-168; AC(1)-197; AC(1)-284; AC(1)-300; AC(1)-316; AC(1)-333; AC(1)-336; AC(1)-345; AC(1)-356; AC(1)-105; AC(1)-371
s.5 Effect/Valued Component/EA Item: Aboriginal Health and Socio-economic conditions
Reference to EIS Guidelines: Sections 9.1.3, 9.2, 10.1.2, 10.1.3
Reference to EIS: EIS Sections 5.11.2, 5.11.3, 6.4.2.1, 6.4.2.2, 6.4.2.3, Table 6.4.1; Appendix T
Summary of Comment/Rationale: Local and regional study areas for the socio-economic environment are not clearly defined or rationalized in section 5 (EIS). The local study area for the socio-economic baseline provided in Appendix T does not take into account all of the Aboriginal groups identified in the EIS Guidelines; Whitefish Bay First Nation, Wabauskang First Nation, Métis Nation of Ontario, Aboriginal People of Wabigoon, and Grassy Narrows First Nation are not included in the baseline assessment. There is no discussion of either on or off-reserve baseline or effects to Aboriginal socio-economic conditions within section 5 or 6 (EIS). Data presented in community profiles (Appendix T) is from secondary sources only and therefore is limited to largely regional scale information. Section 5.11.2(EIS) does not describe the baseline information for the communities or groups that are in closest proximity to the project site and are most likely to be impacted (e.g., Wabigoon Lake Ojibway Nation, Village of Wabigoon and City of Dryden).

Information Request:

1. Define local and regional study area for the valued socio-economic components of the assessment, including maps depicting the location of study areas in relation to the project site.
2. Include all Aboriginal groups identified in the EIS Guidelines in the study area, including both on and off-reserve populations.
3. Where possible, collect data from primary sources (i.e. key informant interviews) to fully characterize existing Aboriginal socio-economic conditions that may be affected by the Project, including the Aboriginal population that resides off-reserve. Seek to collect data related to the Aboriginal populations that reside off-reserve in communities in close proximity to the Project (i.e. Village of Wabigoon, City of Dryden).
4. Reassess the potential effects to Aboriginal socio-economic conditions, including a description of baseline socio-economic conditions for Aboriginal peoples (First Nations and Métis) living in the Village of Wabigoon and the City of Dryden, and update the EIS accordingly.

IR-1 Reference #: HE(1)-34
Links to Annexes A3 and A4: PC(1)-40; PC(1)-41; AC(1)-300
s.5 Effect/Valued Component/EA Item: Aboriginal Current Use of Lands and Resources
Reference to EIS Guidelines: Sections 9.1.3, 9.2, 10.1.2, 10.1.3
Reference to EIS: EIS Sections 5.11.2, 5.11.3, 6.4.2.1, 6.4.2.2, 6.4.2.3, table 6.4.1; Appendix T
Summary of Comment/Rationale: Section 6 (EIS) does not quantify potential population increases. Increases in population may result in increased hunting and fishing pressure, resulting in potential environmental effects that reduce the availability of resources for Aboriginal land and resource use. Therefore, sufficient information regarding local workforce availability, as well as workforce requirements for each phase of the Project is needed to adequately characterize potential effects to the environment from increased population. Section 3 (EIS) does not provide any details with regards to transportation components of the Project. The ‘Land and Resource Use' paragraphs of section 6.4.2.1 (EIS) states: "The residual effect [to traffic] is predicted to be not significant based on the improved access and reduced travelling time to and from the site." It is unclear how the Project will improve access or reduce travel time. Without a clear description of the potential effects to traffic (i.e. route, number, type, frequency of additional vehicles), the significance of the adverse environmental effects related to traffic (e.g., air quality, noise, wildlife mortality, land and resource use) cannot be determined.

Information Request:

1. Quantify potential environmental effects from population and traffic increases from the project including references to primary or secondary data sources which support conclusions.
2. Assess potential impacts to current use of lands and resources from potential environmental effects related to increases in population and traffic (e.g., air quality, noise, water quality and quantity, vegetation, fish and fish habitat, wildlife).

IR-1 Reference #: HE(1)-35
Links to Annexes A3 and A4: PC(1)-24; PC(1)-27; PC(1)-37; PC(1)-38; PC(1)-39; PC(1)-43; PC(1)-44; PC(1)-51; PC(1)-60; AC(1)-22; AC(1)-23; AC(1)-24; AC(1)-25; AC(1)-36; AC(1)-197; AC(1)-264; AC(1)-270; AC(1)-299; AC(1)-300; AC(1)-301; AC(1)-316; AC(1)-333; AC(1)-336; AC(1)-342; AC(1)-345; AC(1)-371; AC(1)-406
s.5 Effect/Valued Component/EA Item: Aboriginal Health and Socio-economic conditions
Reference to EIS Guidelines: Sections 9.1.3, 10.1.2
Reference to EIS: EIS Sections 6.4.2.3, 14
Summary of Comment/Rationale: Section 6.4.2.3 (EIS) focuses only on positive economic effects to the public. Additional valued components are needed to assess the effects of changes to the environment from the Project on Aboriginal socio-economic conditions. For example, direct changes to the environment from the Project (e.g., air quality, noise, water quality and quantity) may cause potential adverse socio-economic effects to Aboriginal property values, tourism establishments (e.g. outposts, camps, motels, guiding operations), recreation activities (e.g. Lola Provincial Park, Butler Park, and Aaron Provincial Park) and other resource-based commercial operations (e.g. wild rice harvesting, chanterelle harvesting, baitfishing, trapping, hunting forestry). Valued components should be revisited in consultation with potentially affected groups. For example, based on input provided by Wabigoon Lake Ojibway Nation, consider wild rice as a valued component due to economic value. Aboriginal groups have also identified baitfishing within the project site. This activity has not been included or addressed in Section 6 (EIS). Section 14 (EIS) concludes that the Project will provide an economic net benefit to the local, Aboriginal, regional, and provincial economies; however, this conclusion is not supported by technical supporting documentation or references (e.g. no economic model completed). In addition, the preliminary economic assessment (Appendix BB) results have not been integrated into the EIS (section 6). Section 6 is limited to an assessment of economic development at the provincial level. During Agency consultation activities, concerns were raised from Aboriginal groups and members of the public about effects to Aboriginal social conditions (i.e., quality of life and community character) from direct environmental changes of the Project (i.e. air quality, noise, dust, light and visual changes to the landscape). While potential effects to local ambience are identified in section 6 (EIS), they are not completely discussed or adequately characterized using measurable indicators.

Information Request:

1. Define valued components to assess potential adverse socio-economic effects to Aboriginal peoples from environmental changes of the Project. Aboriginal socio-economic conditions include to property values quality of life and community character, tourism, recreation, and resource-based commercial operations.
2. Collect data from primary sources (i.e. key informant interviews) to fully characterize existing Aboriginal socio-economic conditions that may be affected by the Project, including, but not limited to, Aboriginal businesses and commercial operations, Aboriginal recreation activities. Aboriginal businesses and commercial operations may include tourism, recreation and resource-based commercial operations (e.g. commercial baitfish operators, sustainable forestry license holders, bear management area operators, and the local trapper's council).
3. Identify mitigation measures for potential effects to Aboriginal socio-economic conditions.
4. Utilize data to quantify, where possible, potential effects to local and regional economic conditions. Reference primary or secondary data sources which support conclusions. Provide economic modeling which substantiates conclusions identified in the EIS.

IR-1 Reference #: HE(1)-36
Links to Annexes A3 and A4: PC(1)-26; PC(1)-38; AC(1)-13; AC(1)-118
s.5 Effect/Valued Component/EA Item: Current Use of Lands and Resources for Traditional Purposes
Reference to EIS Guidelines: Sections 9.1.2, 10.1.3, 11.2, 11.3
Reference to EIS: EIS section 5.4.3.5
Summary of Comment/Rationale: Section 5.4.3.5 (EIS) indicates that the waste rock storage area (WRSA) will have a maximum vertical stack height of 20 m. The section states that "current design criteria suggestthat the vertical stack height will be limited to reduce the potential visual impact for neighboring residents." It is unclear what the height limit will be in order to reduce potential visual impact. Aboriginal peoples and members of the public mentioned impacts of the view of their use and enjoyment of Thunder Lake require analysis. The proponent should describe more precisely with text and figures how the WRSA will appear to Aboriginal peoples and the public from various vantage points, including from Thunder Lake.

Information Request:

1. Clarify what the height limit will be in order to reduce potential visual impact.
2. Provide a comparative analysis including a description of how the waste rock storage area will appear from various vantage points throughout the various phases of the Project using both text and figures drawn to scale. Vantage points from Thunder Lake should be included in the analysis.
3. Identify and demonstrate how mitigation measures will reduce potential impacts to Aboriginal peoples, including current use of lands and resources for traditional purposes, physical and cultural heritage, and socio-economic conditions.

IR-1 Reference #: HE(1)-37
Links to Annexes A3 and A4: AC(1)-352; AC(1)-355
s.5 Effect/Valued Component/EA Item: Aboriginal Health and Socio-economic conditions; Structure, Site, or Thing of Historical Archaeological, Paleontological or Architectural Significance to Aboriginal Groups; Aboriginal Physical and Cultural Heritage
Reference to EIS Guidelines: Sections 9.1.3, 10.1.2
Reference to EIS: EIS Section 6.4.2
Summary of Comment/Rationale: Definitions for characterization of magnitude provided in Section 6.1.3 (EIS) have not been applied appropriately across valued socio-economic components. For example, section 6.4.2.2 (EIS) states: "The residual effects have been categorized as Level I for magnitude (might or might not be detectable, but is within the normal range of variability)". This is not consistent with the definition of Level 1 effects provided in section 6.1.3 (EIS): "no measurable residual effect". Based on the definitions in section 6.1.3 (EIS), magnitude should be characterized as Level II "residual effect is measurable but within range of natural variation". If magnitude is characterized as Level II, the decision tree must be reapplied to determine the significance of adverse effects. Further, no scientific or technical basis is provided to support characterization of residual effects. The method to determine geographic extent of effects is not clear as study areas are not clearly defined in the EIS. Each level used to characterize residual effects for the valued socio-economic components needs to be clearly defined. For example, Magnitude – Level II was defined as "Residual effect is measurable but within range of natural variation". In section 6.4.2.1 (EIS), residual effects to local ambience and traffic are characterized as level 1 - might or might not be detectable, but is within the normal range of variability. It is unclear how this score was applied, as effects due to air quality, noise, vibration, traffic and decreased aesthetics associated with the Project would not occur normally (i.e. without the Project). Also unclear is how effects are reversible in the long term as visual changes to the site will be permanent.

Information Request:

1. Explain how natural variation was defined for socio-economic valued components.
2. Revise determination of significance analysis based on definitions provided in section 6.1.3 of the EIS.
3. Substantiate the characterization of residual effects by applying traceable technically valid methodology, including references to primary or secondary data sources which support conclusions.

IR-1 Reference #: HE(1)-38
Links to Annexes A3 and A4: PC(1)-36; PC(1)-45; PC(1)-48; PC(1)-60; PC(1)-61; PC(1)-62; PC(1)-80; PC(1)-81; AC(1)-30; AC(1)-34; AC(1)-37; AC(1)-38; AC(1)-39; AC(1)-40; AC(1)-41; AC(1)-42; AC(1)-69; AC(1)-90; AC(1)-97; AC(1)-100; AC(1)-101; AC(1)-102; AC(1)-103; AC(1)-108; AC(1)-109; AC(1)-111; AC(1)-112; AC(1)-116; AC(1)-138; AC(1)-159; AC(1)-163; AC(1)-170; AC(1)-171; AC(1)-172; AC(1)-174; AC(1)-177; AC(1)-179; AC(1)-234; AC(1)-239; AC(1)-243; AC(1)-259; AC(1)-261; AC(1)-266; AC(1)-272; AC(1)-273; AC(1)-274; AC(1)-276; AC(1)-315; AC(1)-316; AC(1)-318; AC(1)-319; AC(1)-320; AC(1)-321; AC(1)-322; AC(1)-323; AC(1)-332; AC(1)-333; AC(1)-338; AC(1)-340; AC(1)-342; AC(1)-344; AC(1)-345; AC(1)-347; AC(1)-349; AC(1)-35; AC(1)-110; AC(1)-271; AC(1)-280; AC(1)-292; AC(1)-356; AC(1)-258; AC(1)-360; AC(1)-369; AC(1)-371; AC(1)-378; AC(1)-410; AC(1)-427
s.5 Effect/Valued Component/EA Item:; Aboriginal Physical and Cultural Heritage
Reference to EIS Guidelines: Sections 2.3, 9.1.3, 9.2, 10.2, 11.2, 11.4
Reference to EIS: EIS Sections 5.11.5.1, 5.11.5.2, Tables 5.11.8, 5.11.9; Appendix DD
Summary of Comment/Rationale: According to Aboriginal groups and government reviewers, Treaty 3 was misinterpreted in section 2.1 (Appendix DD). Section 9.2 of the EIS Guidelines states that the proponent is required to engage with Aboriginal groups whose potential or established Aboriginal or Treaty rights and related interests may be affected by the Project. Additionally, section 2.3 of the EIS Guidelines states that Aboriginal persons involved must be provided with access to relevant information that allows them to understand the proposed project and to determine its impacts on their rights and interests. The proponent is not required to determine rights through the environmental assessment but rather, as identified in section 10.2 of the EIS Guidelines, to identify and assess potential adverse impacts of the Project on Aboriginal and Treaty rights and related interests. The proponent should refrain from interpreting Treaty rights in the EIS. Currently potential impacts to treaty rights are discussed in Appendix DD. While some information has been integrated into the baseline and effects assessment (sections 5 and 6 of the EIS), the proponent has not sufficiently integrated and addressed potential impacts to Aboriginal peoples in the EIS. The summary of engagement activities should include: activities conducted with each group; an overview of key comments and concerns by each group and responses provided to issues identified; where and how Aboriginal traditional knowledge or other Aboriginal views were incorporated into the consideration of environmental effects and potential adverse impacts on potential or established Aboriginal and Treaty rights and related interests; and future planned engagement activities. The assessment of adverse impacts should consider both access to lands and resources used for the exercise of rights and the availability of resources important for the exercise of rights. The assessment should also consider impacts to cultural sites and heritage resources important for the exercise of rights. The baseline description of Aboriginal peoples, including Aboriginal land and resource use in the project area, provided in section 5 (EIS) does not fully and adequately address the requirements outlined in the EIS Guidelines. The EIS Guidelines state that the EIS should "Summarize available information on the potential or established Aboriginal and Treaty rights and related interests of the named Aboriginal groups that have the potential to be adversely impacted by the project.In describing current uses of land and resources by Aboriginal groups for traditional purposes, the proponent will include activities related, but not limited, to hunting, fishing, trapping, cultural and other traditional uses of the land (e.g. collection of medicinal plants, use of sacred sites). Potential effects on current uses include access to areas that are of importance or concern to Aboriginal groups." Information on and assessment of potential impacts to Aboriginal or Treaty rights also serves to inform the assessment of effects on Aboriginal peoples, pursuant to section 5(1)c of CEAA 2012.

Information Request:

1. Revise text to remove interpretation of Treaty rights.
2. Integrate existing information pertaining to potential impacts to Aboriginal peoples, including land and resource use, into the description of baseline conditions and effects assessment sections in the EIS.
3. Collect baseline information related to potential impacts to Aboriginal peoples by the Project from primary (potentially affected Aboriginal groups) and secondary sources (i.e., community and organization websites, existing government reports, case law, etc.), including but not limited to: maps and background information of each potentially affected groups' traditional territory; geographic extent of practices, including maps showing: Areas uses for hunting, fishing, trapping and harvesting practices (e.g. hunting camps, cabins, harvesting, fishing and trapping areas); Waterways or land travel routes traditionally used for traditional practices; nature of practices, including: Hunting, fishing, trapping, and harvesting practices; Wildlife species of importance for hunting, fishing, and trapping practices (including, but not limited to, waterfowl, ruffed grouse, moose, etc.); Plant species of importance including for berry and plant harvesting (including, but not limited to, wild rice, blueberries and chanterelle mushrooms); Cultural and other traditional uses of the land (e.g. collection of medicinal plants, use of sacred sites, annual gathering, meeting and teaching grounds); frequency of practices, including data sets (e.g., fish catch numbers, harvest data by species); and timing of practices exercised within recent memory.
4. Provide documentation of baseline information identified by each group specifically.

IR-1 Reference #: HE(1)-39
Links to Annexes A3 and A4: AC(1)-371
s.5 Effect/Valued Component/EA Item: Current Use of Lands and Resources for Traditional Purposes
Reference to EIS Guidelines: Section 9.2
Reference to EIS: EIS Section 5.11.5.2, Tables 5.11.8, 5.11.9
Summary of Comment/Rationale: Section 5.11.2 (EIS) states: "The mine site area is fully enclosed within Wildlife Management Unit (WMU) 8; WMU 5 and WMU 9A are within the LSA. Trapping locations within the LSA include Trap lines DR026, DR027, and DR021. Current numbers for active hunters within the region are detailed in Table 5.11.8 and Table 5.11.9." The tables detailing hunting activity in WMU 8 do not align with the section's intent. Section 5.11.5 (EIS) is titled Aboriginal Peoples and the information in the tables comes from recreational hunters who are not necessarily Aboriginal. Similarly for trapping references, the trapline numbers align with commercial trappers but Aboriginal subsistence trapping does not need to occur on a registered trapline. To meet the section's intent, more pertinent information on Aboriginal hunting and trapping within the project area is required.

Information Request:

1. Ensure that baseline data are accurately presented and clearly identify data limitations and gaps. See IR above for specific data requirements for Aboriginal land and resource use.

IR-1 Reference #: HE(1)-40
Links to Annexes A3 and A4: AC(1)-174; AC(1)-175
s.5 Effect/Valued Component/EA Item: Current Use of Lands and Resources for Traditional Purposes
Reference to EIS Guidelines: Section 9.2
Reference to EIS: EIS Figures 5.11.1 and 5.11.2
Summary of Comment/Rationale: References for land-use information (e.g. known fishing, minnow trapping, Chanterelle mushroom harvesting, and blueberry harvesting area) presented in Figures 5.11.1 and 5.11.2 (EIS) are not clear. Aboriginal groups have also identified that the information is incomplete.

Information Request:

1. Provide references for all data that are depicted in Figures 5.11.1 and 5.11.2, and clearly identify data limitations.

IR-1 Reference #: HE(1)-41
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Current Use of Lands and Resources for Traditional Purposes
Reference to EIS Guidelines: Section 9.2
Reference to EIS: Appendix DD
Summary of Comment/Rationale: Fishing practices within the project area have been identified by Aboriginal groups to the Agency. Inconsistencies are present throughout Appendix DD in regard to fishing practices. For example section DD.5.1.2.4 states: "As there is no existing opportunity to fish on the Goliath Gold Project site, the development of the project will not result in any on site impacts to fishing." Then section DD.5.1.2.7 states: "Treasury has received some individual requests from persons wishing to trap minnows in the ponds adjacent to the Treasury offices. These ponds were created by the damming of a creek flowing past the former OMNRF Tree Nursery for the purpose of providing irrigation water to the tree nursery. In all cases, access to these ponds to trap minnows has been provided during business hours." The proponent must ensure that Aboriginal land and resource use activities identified by Aboriginal groups are accurately captured in the EIS and appropriate mitigation measures are identified where impacts are expected on Aboriginal land and resource use activities.

Information Request:

1. Identify and describe Aboriginal land and resource use activities identified by Aboriginal groups that could be affected by the Project.
2. Identify mitigation measures where impacts are expected on Aboriginal land and resource use activities.

IR-1 Reference #: HE(1)-42
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Current Use of Lands and Resources for Traditional Purposes
Reference to EIS Guidelines: Sections 9.2, 10.2, 11.2, 11.4
Reference to EIS: EIS Section 5.11.5.2, Tables 5.11.8, 5.11.9
Summary of Comment/Rationale: The discussion of impacts to Aboriginal traditional land and resource use provided in the EIS is limited to the project area. Study areas (either spatial or temporal) have not been clearly described. Study areas should be defined that include impacts from both on and off-site, direct and indirect, environmental effects and align with relevant bio-physical study areas so that potential impacts to land use activities from environmental effects are adequately characterized. For example, the study area for the assessment of potential impacts to hunting moose should align with the range of moose that may be affected by the Project.

Information Request:

1. Define temporal and spatial study areas for Aboriginal land use. Ensure that study areas align with relevant bio-physical study areas, and include potential direct and indirect impacts to access, availability and resource use.

IR-1 Reference #: HE(1)-43
Links to Annexes A3 and A4: PC(1)-45; PC(1)-46; PC(1)-47; PC(1)-62; AC(1)-31; AC(1)-34; AC(1)-38; AC(1)-39; AC(1)-40; AC(1)-43; AC(1)-69; AC(1)-90; AC(1)-91; AC(1)-110; AC(1)-111; AC(1)-113; AC(1)-121; AC(1)-169; AC(1)-188; AC(1)-209; AC(1)-210; AC(1)-211; AC(1)-214; AC(1)-228; AC(1)-234; AC(1)-235; AC(1)-237; AC(1)-238; AC(1)-241; AC(1)-255; AC(1)-256; AC(1)-257; AC(1)-258; AC(1)-259; AC(1)-262; AC(1)-271; AC(1)-263; AC(1)-272; AC(1)-274; AC(1)-280; AC(1)-289; AC(1)-292; AC(1)-315; AC(1)-316; AC(1)-318; AC(1)-319; AC(1)-320; AC(1)-321; AC(1)-322; AC(1)-323; AC(1)-338; AC(1)-340; AC(1)-341; AC(1)-342; AC(1)-349; AC(1)-355; AC(1)-356; AC(1)-88; AC(1)-345; AC(1)-369
s.5 Effect/Valued Component/EA Item: Current Use of Lands and Resources for Traditional Purposes
Reference to EIS Guidelines: Sections 9.2, 10.2, 11.2, 11.4
Reference to EIS: EIS section 6.4.2.5, Table 6.4.6-8
Summary of Comment/Rationale: The valued components identified in section 6.3.2.5 (EIS) do not address all potential effects to current use of lands and resources for traditional purposes documented in Appendix DD. Valued components for land use are limited to land and resource use, transportation, and Aboriginal peoples. While in section 6.3.2.5 (EIS) it is identified that valued components with respect to Aboriginal peoples include health, country foods, and hunting/trapping/fishing, the effects assessment presented in Tables 6.4.6 to 6.4.8 (EIS, pages 6-81 to 6-94) does not treat these items as separate valued components but rather potential effects. Potential effects to each of these table items (gathering and quality of country foods, hunting/trapping/fishing for traditional purposes) should be fully described and, where possible, quantified based on the results of the effects assessment of bio-physical environmental changes. For each pathway, more detailed information is required to fully understand baseline activities and to quantify potential effects. Adequate measures are not identified to mitigate potential effects of the Project on current use of lands and resources for traditional purposes or potential or established Aboriginal or treaty rights. For example, no mitigation measures are identified for impacts to hunting and trapping. Significance conclusions provided in the EIS for potential effects to gathering country foods, hunting, trapping and fishing should be substantiated by technical information, traditional knowledge, and input from potentially affected Aboriginal groups. In addition to changes to land use resulting from environmental effects of the Project, the EIS should, in consultation with potentially affected Aboriginal groups, document Aboriginal groups' views on the perception of environmental effects and how in turn this may affect current use of lands and resources for traditional purposes.

Information Request:

1. Identify and assess separate valued components to assess all potential impacts to activities relating to the current use of lands and resources for traditional purposes and incorporate the valued components into the effects assessment.
2. Identify appropriate mitigation and accommodation measures for effects to current use of lands and resources for traditional purposes. For each mitigation and accommodation measure, provide the following details, if applicable: which Aboriginal group each measure applies to (e.g. if a protocol is developed to notify a community whenever a burial site is found during construction, which community is notified), whether the mitigation/accommodation was proposed by and/or shared with the Aboriginal group(s), for their consideration and feedback, the geographic extent (e.g. area of compensatory habitat), and duration (construction, operation, decommissioning, and abandonment).
3. Apply an impact matrix methodology to determine the significance of residual impacts of the Project on current use of lands and resources for traditional purposes for each of the project components and physical activities, in all phases.
4. Substantiate characterization of residual effects and associated impacts by applying traceable technically valid methodology, including references to primary or secondary data sources which support conclusions.

IR-1 Reference #: HE(1)-44
Links to Annexes A3 and A4: AC(1)-34; AC(1)-109; AC(1)-261
s.5 Effect/Valued Component/EA Item: Current Use of Lands and Resources for Traditional Purposes
Reference to EIS Guidelines: Section 10.1.1
Reference to EIS: EIS sections 6.2.2.1, 6.2.4.5, Tables 6.4.6, 6.4.7
Summary of Comment/Rationale: Section 6 (EIS) does not address all the potential land use effects that may occur from gating Nursery Road. Assuming the road will be closed to the public, including Aboriginal groups, starting at the proposed new section of the Tree Nursery Road (as stated in the Project Description) the following land use effects for Aboriginal peoples would occur:

1. Restricted access to portions of Crown Land;
2. Restricted access to patent land not owned by the proponent;
3. Restricted access to recreational trails on Crown Land that are located behind the gate or directly affected by the open pit; and
4. Restricted access to lands previously accessible by trappers, bear management area operators, commercial baitfish operators, and sustainable forest license holders.

Information Request:

1. Describe the effects of restricting access to Tree Nursery Road on potentially affected Aboriginal groups and their associated land uses.
2. Identify appropriate mitigation measures for potential effects to access to land and resource uses from gating Tree Nursery Road.
3. Determine the significance of potential effects to uses of land and resources due to this change in access, taking into account that the geographic extent of effects will likely exceed the footprint of the mine.

IR-1 Reference #: HE(1)-45
Links to Annexes A3 and A4: AC(1)-262; PC(1)-51; PC(1)-63; AC(1)-24; AC(1)-25; AC(1)-32; AC(1)-33; AC(1)-34; AC(1)-35; AC(1)-36; AC(1)-119; AC(1)-150; AC(1)-151; AC(1)-152; AC(1)-153; AC(1)-154; AC(1)-155; AC(1)-158; AC(1)-159; AC(1)-160; AC(1)-171; AC(1)-173; AC(1)-173; AC(1)-174; AC(1)-176; AC(1)-178; AC(1)-196; AC(1)-201; AC(1)-214; AC(1)-236; AC(1)-291; AC(1)-292; AC(1)-318; AC(1)-319; AC(1)-324; AC(1)-111; AC(1)-363; AC(1)-367; AC(1)-368; AC(1)-371; AC(1)-378; AC(1)-403; AC(1)-404; AC(1)-409
s.5 Effect/Valued Component/EA Item: Current Use of Lands and Resources for Traditional Purposes
Reference to EIS Guidelines: Sections 7.2.1, 9.2, 10.2, 11.2, 11.4
Reference to EIS: EIS Sections 5.9.2, 5.9.3, 5.9.4, 5.9.5, 5.9.8, 5.10.3.1, 5.10.3.25.11.5.1, 5.11.5.2, Tables 5.11.8, 5.11.9
Summary of Comment/Rationale: In addition to collecting adequate information from Aboriginal groups to understand land use in the area, the baseline and effects assessment should analyze potential environmental effects from bio-physical changes (e.g. air, noise, light, and water quality) to the environment from the Project to wildlife, plants, and fish that have a land and resource use value and are of importance to Aboriginal peoples. Species of importance and/or that may be potentially affected by the Project identified during Agency consultation events include: wild rice; bear; moose and deer; fox; furbearers (e.g. beaver, muskrat, rabbit); small mammals (i.e. chipmunks, mice, and squirrels); chanterelle mushrooms; medicinal plants (e.g. low bush cranberries, snowbush berry, Labrador tea, low bush hemlock/ ground hemlock). birds (partridge, waterfowl, ruffed grouse) ; blueberries; fish; turtles and frogs; Habitat of importance and/or that may be affected by the Project identified during Agency consultation events include areas of: Lola Lake Nature Reserve; Aaron Provincial Park; Butler Provincial Park; Wabigoon lake; Thunder Lake; Thunder Creek; Blackwater Creek; Rice, Sandy, Mud and Turtle Lakes; Ghost Lake; Mavis Lake; portions of the project area (e.g., fox dens within the tailings storage facility, moose habitat along Blackwater Creek, and bear dens near the entrance of the site).

Information Request:

1. Describe baseline conditions and the environmental effects to wildlife and vegetation that may impact Aboriginal land and resource use, including the following at a minimum: Furbearers and their habitat; Amphibians and reptiles and their habitat; Ungulates and their habitat; Migratory and non-migratory birds and their habitat; Wild rice; Fish and their habitat; and Aquatic and terrestrial vegetation.
2. Incorporate or link the results from the assessment of potential environmental effects into the determination of significance of impacts on current use of lands and resources for traditional purposes.

IR-1 Reference #: HE(1)-46
Links to Annexes A3 and A4: AC(1)-20; AC(1)-292; AC(1)-297; AC(1)-431; AC(1)-432
s.5 Effect/Valued Component/EA Item: Aboriginal Health and Socio-economic conditions; Current Use of Lands and Resources for Traditional Purposes; Aboriginal Physical and Cultural Heritage
Reference to EIS Guidelines: Section 11.4
Reference to EIS: EIS Sections 6, 13, Tables 6.4.6 – 6.4.8
Summary of Comment/Rationale: Section 11.4 of the EIS Guidelines states: "The Follow-up Program will also be designed to monitor the implementation of mitigation measures resulting from Aboriginal consultation, including: Verifying predictions of environmental effects with respect to Aboriginal peoples, as well as residual impacts that could not be addressed within the context of the EA; Determining the effectiveness of mitigation measures as they relate to environmental effects with respect to Aboriginal peoples in order to modify or implement new measures where required; Supporting the implementation of adaptive management measures to address previously unanticipated adverse environmental effects with respect to Aboriginal peoples or unanticipated adverse impacts to Aboriginal rights; Verifying measures identified to prevent and mitigate potential adverse effects of the project on potential or established Aboriginal and Treaty rights; and, Providing information that can be used to improve and/or support future EAs and Aboriginal consultation processes." With the exception of Aboriginal human health, no follow-up programs are identified for any of the human environmental valued components in Tables 6.4.6 - 8 (EIS).

Information Request:

1. Describe the proposed follow-up program in sufficient detail to reliably verify predicted effects (or absence of them), and to confirm both the assumptions and the effectiveness of mitigation related to potential effects to Aboriginal peoples, including potential adverse impacts of the Project on asserted or established Aboriginal and Treaty rights.
2. Identify and describe how and which Aboriginal groups will be engaged during implementation of the follow-up program.

IR-1 Reference #: HE(1)-47
Links to Annexes A3 and A4: MTCS May 21, 2015 Letter; AC(1)-345; PC(1)-54; PC(1)-55; PC(1)-56; PC(1)-57; PC(1)-58; PC(1)-59; AC(1)-27; AC(1)-28; AC(1)-29; AC(1)-35; AC(1)-118; AC(1)-229; AC(1)-291; AC(1)-292; AC(1)-293; AC(1)-333; AC(1)-337; AC(1)-353; AC(1)-362; AC(1)-407; AC(1)-429
s.5 Effect/Valued Component/EA Item: Aboriginal Physical and Cultural Heritage; Structure, Site, or Thing of Historical Archaeological, Paleontological or Architectural Significance to Aboriginal Groups
Reference to EIS Guidelines: Sections 9.1.3, 10.1.3
Reference to EIS: EIS Sections 5.11.4, 6.3.2.4, 6.4.2.4, Table 6.4.6, and 14; Appendix DD
Summary of Comment/Rationale: Section 6.3.2.4 (EIS) does not adequately describe the assessment of potential effects for heritage valued components (i.e. archaeological sites, and historic heritage sites). The Agency's Technical Guidance (http://www.ceaa-acee.gc.ca/default.asp?lang=en&n=536A4CFE-1) defines heritage as: "A land or resource (e.g., an artifact, object or place) that is considered as heritage or any structure, site or thing is distinguished from other lands and resources by the value placed on it." Aboriginal groups, members of the public, as well as other government departments, have identified items of physical and cultural heritage value, including cultural, archaeological, and heritage sites that have not been included in section 6 (EIS), such as: sacred aspects of the environment located in the project site, including turtles, frogs, rocks and boulders; sacred sites south of Wabigoon; sacred site called the Serpent, located at Mavis and Ghost Lake; ceremonial sites in proximity to the project site; sites of historical and archaeological importance within the project boundaries, including grave sites; landscape views of cultural importance; view of Thunder Lake; traditional and historical travel routes, including portage routes, connecting historic and present communities to meeting sites and wild rice sites; and; wild rice areas in Wabigoon Lake (have spiritual and cultural value for elders to pass on practices). During Agency consultation Aboriginal groups suggested that spiritual values and wild rice should be assessed as separate valued components. Appendix DD includes a brief discussion of potential effects to traditional travel routes, and responses to comments about potential effects to landscape views of cultural importance, and sacred sites. The discussion is an inadequate assessment of potential effects. Conclusions are drawn on potential effects without references or demonstration of meaningful engagement efforts to verify the conclusions and mitigation measures presented and identify, through collaboration with Aboriginal groups, accommodation measures, as appropriate. The primary goal of mitigation and accommodation measures is to avoid, eliminate, or minimize the adverse impacts on Aboriginal peoples with respect 5(1)c of CEAA 2012 and potential or established Aboriginal or Treaty rights. If mitigation and accommodation measures are developed in response to an assessed impact, provide specific responses to the following, if applicable: which Aboriginal group each measure applies to (e.g. if a protocol is developed to notify a community if a burial site is found during construction, which community is it for?); whether the mitigation and accommodation measure was proposed by and/or shared with the Aboriginal group(s), for their consideration and feedback; what is the geographic extent of each mitigation measure; what is the duration of each mitigation measure (e.g., construction, operation, decommissioning, and abandonment). Built heritage and cultural heritage landscapes are not clearly screened in section 5 (EIS), notably section 5.11.4.2. While some cultural heritage resources have been formally identified, others may be identified through screening and evaluation. Aboriginal communities may have knowledge that can contribute to the identification of known or potential cultural heritage resources, such as sites of spiritual, cultural, ceremonial, or teaching significance, and physical and cultural landscapes of importance for spiritual or ceremonial purposes. See further comments regarding the provincial requirements for a Heritage Impact Assessment (HIA) in the Ministry of Tourism Culture and Sport (MTCS) letter dated May 21, 2015.

Information Request:

1. Engage Aboriginal groups to identify and understand the value of known or potential physical and cultural heritage resources in the local study area that may be affected by the project. Include identification of which specific Aboriginal groups identified each site, structure or thing of heritage value.
2. Review valued components based on additional information collected from Aboriginal groups, determine if additional valued components (e.g. spiritual sites or wild rice) are needed to assess potential effects to physical and cultural heritage, and explain the decision to add or exclude new valued components.
3. Define local and regional study areas for the heritage assessment, including maps that depict the location of study areas in relation to the project site.
4. Identify appropriate mitigation and accommodation measures for effects to physical and cultural heritage. For each mitigation and accommodation measure, provide the following details, if applicable: the name(s) of the Aboriginal group(s) to which each measure applies (e.g. if a protocol is developed to notify a community when a burial site is found during construction, the community to be notified); explanation whether the mitigation and accommodation measure was proposed by and/or shared with the Aboriginal group(s), for their consideration and feedback; the geographic extent of each mitigation and accommodation measure; the duration of each mitigation and accommodation measure (e.g. construction, operation, decommissioning, and abandonment).
5. Define and apply an impact matrix methodology to determine the significance of the adverse effects of the project on physical and cultural heritage for each of the project components and physical activities, in all phases. Complete a visual rendering of the view of project site from points of cultural heritage importance to support assessment of potential effects and adequacy of proposed mitigation measures.

IR-1 Reference #: HE(1)-48
Links to Annexes A3 and A4: AC(1)-29; AC(1)-429
s.5 Effect/Valued Component/EA Item:
Reference to EIS Guidelines: Sections 9.1.3, 10.1.3
Reference to EIS: Appendix DD; EIS Section 6.2.2.4
Summary of Comment/Rationale: There are inconsistencies in the description of potential effects to archeological sites between Appendix DD and the effects assessment presented in Section 6 (EIS). For example, section 7.1 (Appendix DD) identifies "archaeological sites" discussed by Wabigoon Lake Ojibway Nation on August 2, 2011. Section 6.2.2.4 (EIS) states no sites were identified by Aboriginal groups.

Information Request:

1. Revise the effects assessment to include all potential effects to archaeological sites identified by Aboriginal groups, and identify appropriate mitigation measures and a follow-up monitoring program.

IR-1 Reference #: HE(1)-49
Links to Annexes A3 and A4: AC(1)-353; AC(1)-433
s.5 Effect/Valued Component/EA Item: Aboriginal Physical and Cultural Heritage; Structure, Site, or Thing of Historical Archaeological, Paleontological or Architectural Significance to Aboriginal Groups
Reference to EIS Guidelines: Sections 9.1.3, 10.1.3, 11.4
Reference to EIS: EIS Section 6.4.2.4, Tables 6.4.6 – 6.4.8
Summary of Comment/Rationale: Section 6.4.2.4 (EIS) identifies an Archaeological and Cultural Heritage Resource Management Plan as a mitigation measure and indicates that follow-up monitoring is not needed. During Agency consultation activities, Wabigoon Lake Ojibway Nation expressed concern about how archaeological resources will be managed. It is unclear why no follow-up monitoring is proposed. Section 11.4 of the EIS Guidelines states: "A Follow-up Program is designed to verify the accuracy of the effects assessment and to determine the effectiveness of the measures implemented to mitigate the adverse effects of the project. The Follow-up Program will also be designed to monitor the implementation of mitigation measures resulting from Aboriginal consultation."

Information Request:

1. Clarify whether the Archaeological and Cultural Heritage Resource Management Plan will include follow-up monitoring and provide a rationale that takes into account the requirements of the EIS Guidelines.
2. Describe how and which Aboriginal groups may be engaged during the implementation of the Archaeological and Cultural Heritage Resource Management Plan, including how they may be involved upon discovery of archaeological resources on the site, and during any follow-up monitoring that is developed.

ACCIDENTS AND MALFUNCTIONS

IR-1 Reference #: AM(1)-01
Links to Annexes A3 and A4: AC(1)-46; AC(1)-354; AC(1)-283; AC(1)-388
s.5 Effect/Valued Component/EA Item: Accidents and Malfunctions
Reference to EIS Guidelines: Section 7.1.2
Reference to EIS: EIS Section 4.1
Summary of Comment/Rationale: Section 4.1 (EIS) states that the identification of the magnitude of an accident and/or malfunction (e.g., quantity, mechanism, rate, form, and characteristics of the contaminants) is included in section 6 of the EIS. The magnitude of accidents and malfunctions should assume that no response measures are put in place to minimize or reduce effects. By referring to section 6 (EIS) for the magnitude, it implies that the magnitude of the accident and/or malfunction is the same magnitude of a residual effect with the application of mitigation measures. The magnitude of an accident or malfunction needs to take into account failure of design features and needs to be assessed without applying mitigation measures. Section 7.1.2 of the EIS Guidelines states that "the proponent will identify the probability of potential accidents and malfunctions related to the project, including.potential consequences (including the environmental effects), the plausible worse case scenarios and the effects of these scenarios."

Information Request:

1. Describe the potential environmental effects from spills and releases, and cyanide-related accidents and malfunctions on fish and fish habitat, migratory birds, current use of lands and resources for traditional purposes, Aboriginal health and socio-economic conditions, Aboriginal physical and cultural heritage, and any structure, site, or thing of historical, archaeological, paleontological or architectural significance to Aboriginal groups.
2. Provide the magnitude, including the quantity, mechanism, rate form and characteristics of the contaminants and other materials likely to be released from spills and releases, and cyanide-related accidents and malfunctions.
3. Describe contingency and emergency response procedures for the potential effects noted above if spills and releases, and cyanide-related accidents and malfunctions occur.

IR-1 Reference #: AM(1)-02
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Accidents and Malfunctions
Reference to EIS Guidelines: Section 7.1.2
Reference to EIS: EIS Table 4.2.3
Summary of Comment/Rationale: Table 4.2.3 (EIS, page 4-5) notes a duration for the rating of the environment. The definitions of the criteria for each environment rating are not clear.

Information Request:

1. Provide explanations for the durations used in each of the five environment rating criteria.
2. Define the terms "moderate environmental impact, medium term environmental impact and severe long term environmental impact"; "major regulatory violations versus severe breach of regulations with operation suspended".

IR-1 Reference #: AM(1)-03
Links to Annexes A3 and A4: AC(1)-283
s.5 Effect/Valued Component/EA Item: Accidents and Malfunctions
Reference to EIS Guidelines: Section 7.1.2
Reference to EIS: Appendix HH; EIS Section 4.3.2
Summary of Comment/Rationale: Appendix HH does not consider slope failures of the open pit, waste rock and low grade ore stockpiles. In addition, section 4.3.2 (EIS) does not include an assessment of the failures of the seepage collection system, the tailings or effluent pipelines.

Information Request:

1. Describe the potential environmental effects from potential slope failures of the open pit, waste rock and low grade ore stockpiles and failures of the seepage collection system, the tailings or effluent pipeline on fish and fish habitat, migratory birds, current use of lands and resources for traditional purposes, Aboriginal health and socio-economic conditions, Aboriginal physical and cultural heritage, and any structure, site, or thing of historical, archaeological, paleontological or architectural significance to Aboriginal groups.
2. Describe contingency and emergency response procedures for the potential effects noted above if accidents and/or malfunctions occur.

IR-1 Reference #: AM(1)-04
Links to Annexes A3 and A4: PC(1)-64; AC(1)-44; AC(1)-215; AC(1)-227; AC(1)-325; AC(1)-326; AC(1)-350; AC(1)-374
s.5 Effect/Valued Component/EA Item: Accidents and Malfunctions
Reference to EIS Guidelines: Section 7.1.2, 10.1.2
Reference to EIS: Appendix GG, Section 3.3.4; EIS, Sections 4.3.2.3, 6.4.1.12
Summary of Comment/Rationale: Appendix GG describes what would happen to water quality in the unlikely event of a TSF breach. All of the information is based on a comparison of contaminant concentrations in water to Provincial Water Quality Objectives (PWQO). The conclusion of the study is that material that enters Wabigoon Lake from a hypothetical dam breach is diluted within several days to concentrations that meet PWQO. There is no discussion of what the contaminant levels may be within the sediment and food web of Wabigoon Lake in the event of a hypothetical breach. Although the contaminant concentration in water will be diluted, the contaminant does not disappear. Depending on the particular pathway of each contaminant, the contaminant may settle in sediment or bioaccumulate in aquatic life. A discussion of these pathways and projected concentrations within sediment and fish should be provided to fully understand the potential environmental effects from this worst case scenario. Appendix GG also does not take into account the possibility of a dam failure washing out the culverts along Tree Nursery Road, Highway 17 and the Canadian Pacific rail line. There are only three 1m wide culverts grouped together at the Canadian Pacific rail line. These three culverts are highly unlikely to accommodate the wave of water that would result from a dam failure. Section 6.4.1.12 (EIS) states that "In the highly improbable event of a catastrophic failure of the TSF, the resulting flood wave would increase the potential for fish mortality within Blackwater Creek as a result of its high kinetic energy until the flood wave velocity is attenuated as it reaches bends and beaver ponds along the creek. This highly unlikely scenario would be of a relative short duration (several hours to few days) until the flow would return to seasonal normal (Section 4.3.2)." The main concern about fish mortality due to accidental release of deleterious substances lists the volume and velocity of water as main consequences of a TSF dam breach. There is no mention of the substances that would be released in this scenario, their effect on fish health and mortality and their persistence in the downstream local environment. Section 4.3.2.5 (EIS) states that "if the tailings solids dispersed on land and water bodies are not removed in a timely manner following a TSF dam breach, there could be a long term risk of migration. Runoff could mobilize tailings particles into Blackwater Creek and negatively affect its water quality (i.e., turbidity and chemical composition). It is less likely that remobilized particles would affect the quality of Wabigoon Lake since they would likely settle in low moving water such as beaver ponds along Blackwater Creek. However, high water levels and velocities, such as spring freshet, could remobilize the settled particles and affect the water quality of Wabigoon Lake. In addition, acid generating conditions may begin where tailings solids are exposed constantly or intermittently to air." This section precludes that in the event of a dam failure most of the tailings solids and particles would settle in Blackwater Creek behind beaver dams and settle to the bottom. However there is a risk high water levels and velocities such as spring freshet would remobilize the settled particles and affect the water quality of Wabigoon Lake and acid generating condition may also begin. However this document fails to identify how long this is likely to occur and what the specific effects would be to the users of the lake and fish and fish habitat. This missing information is important to understanding the effects of a hypothetical dam breach on fish and fish habitat over the long term.

Information Request:

1. Provide an analysis of what the contaminant levels would be within the sediment and within the aquatic food web following a tailings storage facility failure, with a focus on contaminants that persist in the environment, bioaccumulate in fish or are toxic to fish, migratory birds or Aboriginal people.
2. Describe the effects and their duration if particulate materials remobilize with every heavy rainfall or spring freshet.
3. Describe detailed contingency and emergency response procedures, for a tailings storage facility failure to address effects to fish and fish habitat, migratory birds, and effects to Aboriginal peoples including, but not be limited to, country foods, current use of lands and resources for traditional purposes, and health and socio-economic conditions.

IR-1 Reference #: AM(1)-05
Links to Annexes A3 and A4: PC(1)-64; AC(1)-296; AC(1)-374
s.5 Effect/Valued Component/EA Item: Accidents and Malfunctions
Reference to EIS Guidelines: Section 7.1.2
Reference to EIS: EIS Section 3.7.1; Appendix D Section 5.5; Appendix GG
Summary of Comment/Rationale: Section 3.7.1 (EIS) states: "The freeboard will be based on peak water levels occurring within the spillway during the occurrence of the inflow design flood (IDF). The IDF will be based on the hazard potential classification (HPC) as identified by the Canadian Dam Association (CDA) guidelines and also the OMNRF Best Management Practices." A Hazard Potential Classification (HPC), even if preliminary, is required to report the Dam Break Analysis, Inflow Design Flood, Spillway Capacity, and Maximum Design Earthquake within the EIS. To establish the HPC two scenarios must be analyzed: one under normal operation (sunny day break), and one under flood conditions. The HPC is established as the worst of the two cases. Refer to Classification and Inflow Design Flood Criteria Technical Bulletin August 2011 (Lakes and Rivers Improvement Act – Administrative Guideline, Technical Bulletins, and Best Management Practices 2011- Classification and Inflow Design Flood Criteria Technical Bulletin, August 2011). Section 7.1.2 of the EIS Guidelines states that the EIS will describe the safeguards that have been established to protect against tailings storage facility dam failure.

Information Request:

1. Provide the Hazard Potential Classification (HPC) (even if preliminary).
2. Provide a revised Dam Break Analysis, Inflow Design Flood, Spillway Capacity, and Maximum Design Earthquake, taking into account the HPC.
3. Using the revised Inflow Design Flood, revise Breach scenario 2 involving the overtopping failure caused by the local 100-year storm event inflow.

IR-1 Reference #: AM(1)-06
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Surface Water Quality; Accidents and Malfunctions
Reference to EIS Guidelines: Section 5.6 and 7.1.2
Reference to EIS: EIS Section 3.7.5
Summary of Comment/Rationale: Tailings spills can occur from pipeline breaks. Environmental damage increases with the length of time that a spill goes undetected. Pipeline routing should be designed to avoid environmentally sensitive areas, such as waterbodies and wetlands. Fortifying the pipeline in these areas to reduce the risk of a pipeline break is also an option.

Information Request:

1. Describe what will be used for a tailings spill detection system (e.g. monitor for pressure drops within the tailings pipeline).
2. Identify what, if any, pipeline routing and design features have been incorporated to reduce the risk and severity of impacts associated with pipeline breaks in any environmentally sensitive areas (e.g. waterbodies).

IR-1 Reference #: AM(1)-07
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Terrain and Soils; Accidents and Malfunctions; Effects of the Environment on the Project
Reference to EIS Guidelines: Sections 7.1.2, 7.1.3
Reference to EIS: EIS, sections 3.0, 5.0; Appendix D; Section 6.5; Appendix HH
Summary of Comment/Rationale: According to Figures 5.5.3.to 5.5.5 (EIS) and section 3.3.1 (EIS), the overburden thickness varies from about 0-2 m to 10-15 m North and South of the proposed open pit area, respectively. As the overburden consists mainly of soft glaciolacustrine clays (Appendix D, section 6.5), landslides could be triggered by excavation operations during the opening of the pit. There are at least three documented cases of large landslides (earthflows) that were triggered by mining or excavation operations in similar deposits. These landslides involved either glaciolacustrine clays in western Quebec (Eden, 1964; NRCan, 2011), or sensitive Champlain Sea clays (MTQ, 2014). All resulted in casualties. References: -Eden, WJ (1964). Earthflows at the Beattie Mine Quebec, Canada. Canadian Geotechnical Journal, 1(2): 104-114. -NRCan (2011). List of major landslide disasters in Canada – Belmoral Mine earthflow. -MTQ (2014). Glissement de terrain du 29 janvier 2013 à la carrière Maskimo de l'Épiphanie. Rapport présenté à la Commission de la santé et de la sécurité du travail (CSST), Transports Québec, 211 p.

Information Request:

1. Document the physical and mechanical properties of the glaciolacustrine clays (e.g. liquidity index to assess the capacity of these soils to flow once mobilized by a failure; piezocone tests to obtain a more detailed stratigraphy and more representative strength parameters).
2. Provide information of the possibility that down-hill progressive landslides (e.g. Bernander, 2008) could be induced by the weight of the two storage areas (Waste Rock Storage Area and the Overburden Storage Area, e.g. Fig. 3.01 (EIS).
3. Provide results of slope stability analyses and mitigation measures if required in (Appendix HH). Reference: Bernander, S. (2008). Down-hill progressive landslides in soft clays. Research Report, Lulea University of Technology, Lulea, Sweden, 120 p.

IR-1 Reference #: AM(1)-08
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Terrain and Soils; Accidents and Malfunctions; Effects of the Environment on the Project
Reference to EIS Guidelines: 9.1.2
Reference to EIS: EIS Section 5.4.1; EIS Appendix D Figure 1.1
Summary of Comment/Rationale: No contour information appears on Figure 1.1 (Appendix D), which is referenced in EIS Section 5.4.1 as evidence that the project area is one of relatively low relief and support for the assertion that landslides, slope erosion, and potential for instability is limited in the project area.

Information Request:

1. Provide a revised Figure 1.1 (Appendix D) with contour information.

CUMULATIVE ENVIRONMENTAL EFFECTS

IR-1 Reference #: CE(1)-01
Links to Annexes A3 and A4: AC(1)-242; AC(1)-358; AC(1)-293
s.5 Effect/Valued Component/EA Item: Cumulative Environmental Effects
Reference to EIS Guidelines: Section 12.1.2
Reference to EIS: EIS Sections 7.0, 7.2.1, 7.3.6
Summary of Comment/Rationale: The methodology for the cumulative effects assessment must be clearly described in order for reviewers of the EIS to examine how the analysis was conducted and what rationale supports the conclusions reached. Section 7.0 (EIS) describes the definition of cumulative effects, scope, and the results of the assessment; however, it does not describe the methodology used in conducting the cumulative effects assessment. The spatial and temporal boundaries of cumulative environmental effects must be justified clearly.

Information Request:

1. Clearly describe the methodology used to predict cumulative environmental effects, including a description of how an effects rating criteria was applied and the method by which criteria were combined and weighted.
2. Provide justification for choosing the three spatial scales (LSA, RSA and 40km radius centered on the Project pit).
3. Provide a map that clearly defines the spatial boundaries that encompass the potential environmental effects on the selected valued components of the Project in combination with other physical activities that have been or will be carried out, including the additional projects listed in CE(1)-02.
4. Provide justification for choosing the temporal boundary of 10 years.

IR-1 Reference #: CE(1)-02
Links to Annexes A3 and A4: AC(1)-351; PC(1)-66; AC(1)-49; AC(1)-240; AC(1)-287; AC(1)-380; AC(1)-434
s.5 Effect/Valued Component/EA Item: Cumulative Environmental Effects
Reference to EIS Guidelines: Section 12.1.2
Reference to EIS: EIS Sections 7.0, 7.2.3, 7.2.3.1
Summary of Comment/Rationale: Section 7.2.3.1 (EIS) states that "due to the lack of existing or planned mining projects within the cumulative effects study areas, mining and exploration projects are not expected to contribute to cumulative effects in the foreseeable future". However, Treasury Metals Inc. announced, on February 12, 2015, the addition of a second diamond drill to accelerate Phase II of the exploration program at its Goliath Gold Project. Table 1.5.1 (EIS, page 1-20) also shows anticipated provincial permits required for a 1-5 MW power generation facility constructed by a power supplier to support the Project. Despite these activities occurring or proposed at the project site, they were not included in the cumulative effects analysis. Information on the environmental effects of these activities will assist in the understanding of cumulative environmental effects on fish and fish habitat, migratory birds, Aboriginal health and current use of lands and resources for traditional purposes. In addition, the following past, existing and reasonably foreseeable future projects within the cumulative effect study areas needs to be included in the cumulative effects assessment: Highway 17; Canadian Pacific Rail; Forestry operations by Dryden Forest Management Company; Domtar Corp.'s Dryden Pulp Mill; Proposed 1-5 MW power generation facility; Proposed Energy East Pipeline; Proposed Josephine Cone Mine Project; Aggregate pits or quarries; The mining claim #: 3017940 overlays Aggregate Permit #: 46764, permitted to D&D Contracting as a commercial operation. Aggregate extraction occurs in the Local Study Area and should be taken into consideration in the cumulative effects assessment. The proponent's characterization of cumulative effects for air and surface water quality are unclear. Statements in the EIS contain a number of assumptions that do not appear to be based on actual numerical data. For example, section 3.2 (Appendix J) and section 5.2.1.1 (EIS) contradict each other in terms of the potential for existing projects to contribute to baseline air quality at the project site and within the LSA. The EIS does not assess the potential effects to recreational and commercial, trapping, hunting and/or fishing. Due to the potential for certain project activities requiring other federal approvals to have indirect effects on human health and socio-economic conditions not tied to Aboriginal peoples, these effects need to be assessed. Furthermore, section 7.0 (EIS) does not address the potential cumulative effects of the Project in combination with other activities, such as recreational and commercial, trapping, hunting and/or fishing. This analysis is necessary to examine whether the proposed project, in combination with other activities could result in the overexploitation of resources during the life of the proposed project. Sections 7.2.3.3 and 7.2.3.4 (EIS) note that none of the major projects of the Northern Highways Program slated for 2015-2017 construction and completion or the Hydro One transmission system projects fall within the cumulative effects study areas. The locations of these major projects and transmission system projects would assist in substantiating this claim. Section 7.2.3.4 (EIS) states that Wataynikaneyap Power is proposing a 300-km long 230-kV transmission line from south of Dinorwic to Pickle Lake, Ontario. The proposed project falls within the defined spatial boundaries of the cumulative effects study area. The potential effects of the proposed alternative routes of the 230kV transmission line need to be considered to assist in the understanding of cumulative effects assessment. The Operational Policy Statement (http://www.ceaa-acee.gc.ca/default.asp?lang=En&n=1DA9E048-1) states that potential cumulative environmental effects should be considered in the analysis even when there is little supporting data or there is predictive uncertainty. Section 7.2.3.5 (EIS) states that the development of local infrastructure and minor road upgrades are expected in communities within the cumulative effects study area (i.e., Dryden and Wabigoon). The locations, descriptions and the potential effects of the physical activities noted above are required to assist in the understanding of cumulative effects assessment.

Information Request:

1. Provide a revised cumulative effect assessment that includes an analysis of the potential environmental effects of the Project in combination with the following projects: Treasury Metals Inc. exploration program, Highway 17, Canadian Pacific rail line, forestry operations by Dryden Forest Management Company, Domtar Corp.'s Dryden Pulp Mill, proposed 1-5 MW power generation facility, Energy East pipeline, Josephine Cone Mine Project, aggregate pits or quarries, the 230kV transmission line proposed by Wataynikaneyap Power and the development of local infrastructure and minor road upgrades in Dryden and Wabigoon. Provide clear rationale for the exclusion of projects from the cumulative effect assessment, if applicable. Provide detailed descriptions of the projects listed above.
2. Revise the cumulative effects assessment to include an analysis of the potential environmental effects of the Project in combination with other ongoing activities such as, but not limited to, hunting, trapping and fishing.
3. Provide a map that shows the Project and all the locations of the past, existing, certain and reasonably foreseeable physical activities identified in section 7.2.3 (EIS) and those listed above in comments A and B.

IR-1 Reference #: CE(1)-03
Links to Annexes A3 and A4: AC(1)-313
s.5 Effect/Valued Component/EA Item: Surface Water Quality; Cumulative Environmental Effects
Reference to EIS Guidelines: Section 8.1
Reference to EIS: EIS Sections 3.4, 7.2.3
Summary of Comment/Rationale: The proponent indicated that the underground mining resource is not well defined, and there may be a larger resource body that will not be confirmed until mine operations have been underway. Given that the waste rock and tailings are potentially acid generating (PAG) and the limited space presently available to the proponent for its management, increases in the volumes of these materials beyond the capacity of the mine waste management plans that have been proposed could lead to adverse water quality impacts. According to the Agency's draft cumulative effects technical guidance (http://www.ceaa-acee.gc.ca/Content/B/8/2/B82352FF-95F5-45F4-B7E2-B4ED27D809CB/Cumulative_Environmental_Effects-Technical_Guidance-Dec2014-eng.pdf), "a future physical activity would be considered reasonably foreseeable and should be included in the cumulative effects assessment if. the completion of the project would facilitate or enable the future development and the economic feasibility of the project is contingent upon the future development." It would appear that the additional mining of the larger resource body and exploration activities fall under these criteria and would need to be included in the cumulative effects assessment.

Information Request:

1. Identify the measures that could be put in place to ensure mining of the additional larger resource body will not lead to cumulative impacts to water quality given that these materials are PAG.
2. Provide a revised cumulative effect assessment that includes an analysis of the potential environmental effects of the Project in combination with the addition mining activities for the larger resource body and related exploration activities.

IR-1 Reference #: CE(1)-04
Links to Annexes A3 and A4: AC(1)-293
s.5 Effect/Valued Component/EA Item: Cumulative Environmental Effects
Reference to EIS Guidelines: Section 12.1.2
Reference to EIS: EIS Sections 7.0, 7.3
Summary of Comment/Rationale: Data collection and/or generation are important components of a cumulative environmental effects assessment. The conclusions of the cumulative effects assessment in section 7.3 (EIS) are not based on quantitative analysis, which makes it difficult for reviewers of the EIS to replicate.

Information Request:

1. Provide quantitative data and analysis to substantiate the conclusions of the assessment of cumulative effects in combination with other past, present and reasonably foreseeable projects and activities in the study areas. If no quantitative data is available provide a rationale clearly explaining the reasons why the data is not readily available and, provide a qualitative assessment to substantiate the conclusions.

IR-1 Reference #: CE(1)-05
Links to Annexes A3 and A4: AC(1)-48; AC(1)-293
s.5 Effect/Valued Component/EA Item: Cumulative Environmental Effects
Reference to EIS Guidelines: Section 12.1.2
Reference to EIS: Appendix GG, Section 3.3.4; EIS, Sections 4.3.2.3, 6.4.1.12
Summary of Comment/Rationale: The response to information request AM(1)-04 is relevant to determining cumulative effects of a potential dam breach on subsistence, commercial, and recreational fisheries that already have fish consumption advisories with respect to mercury.

Information Request:

1. Revise the cumulative effects assessment to include consideration of how the tailings storage facility failure could affect the existing fish consumption advisory.
2. Describe contingency and emergency response procedures for the potential effects noted above in the improbable event of a catastrophic failure of the tailings storage facility.

IR-1 Reference #: CE(1)-06
Links to Annexes A3 and A4: AC(1)-293
s.5 Effect/Valued Component/EA Item: Cumulative Environmental Effects; Accidents and Malfunctions
Reference to EIS Guidelines: Section 7.1.2
Reference to EIS: Appendix GG
Summary of Comment/Rationale: The cumulative effects assessment also needs to assess the potential effects from accidents and malfunctions of the project in combination with other physical activities that have been or will be carried out; including, but not limited to, the following projects: Treasury Metals Inc. exploration program, Highway 17, Canadian Pacific rail line, forestry operations by Dryden Forest Management Company, Domtar Corp.'s Dryden Pulp Mill, proposed 1-5 MW power generation facility, Energy East pipeline, Josephine Cone Mine Project, aggregate pits or quarries, the 230kV transmission line proposed by Wataynikaneyap Power and the development of local infrastructure and minor road upgrades in Dryden and Wabigoon.

Information Request:

1. Provide a map that clearly defines the spatial boundaries that encompass the potential effects from accidents and malfunctions of the project in combination with other physical activities that have been or will be carried out, including the additional projects listed in CE(1)-02.
2. Provide a revised cumulative effect assessment that includes an analysis of the potential environmental effects from accidents and malfunctions of the project in combination with other physical activities or projects that have been or will be carried out, including the additional projects listed in CE(1)-02.

IR-1 Reference #: CE(1)-07
Links to Annexes A3 and A4: AC(1)-47; AC(1)-115
s.5 Effect/Valued Component/EA Item: Cumulative Environmental Effects; Human Environment
Reference to EIS Guidelines: Sections 9.1.3, 10.1.3
Reference to EIS: EIS Table 7.3.2
Summary of Comment/Rationale: The potential cumulative effects listed under Aboriginal People in Table 7.3.2 (EIS, page 7-20) are not clearly described. For example, in the "Potential Effect" column "fishing" is listed without any detail to describe what the impact to fishing is (e.g. reduced fish numbers, less access to fishing locations, contaminated fish). Additional detail is needed to describe how the potential effects of fishing, hunting and trapping, gathering of country foods, and water quality and health effects will impact Aboriginal peoples.

Information Request:

1. Provide detail in Table 7.3.2 to describe the potential cumulative effects of water quality and health effects, gathering of country foods, hunting and trapping, and fishing.

EFFECTS OF THE ENVIRONMENT ON THE PROJECT

IR-1 Reference #: EE(1)-01
Links to Annexes A3 and A4: PC(1)-11; PC(1)-70
s.5 Effect/Valued Component/EA Item: Effects of the Environment on the Project
Reference to EIS Guidelines: Section 7.1.3
Reference to EIS: EIS Section 4.4.1
Summary of Comment/Rationale: Section 4.4.1 (EIS) discusses the environmental impact of extreme floods on the tailings storage facility but does not assess the potential impact from extreme floods on the seepage collection system including the ditches around the infrastructure, the collection and polishing ponds, the Blackwater Creek Tributary 2 realignment and the Tree Nursery Road culvert on the project site. Section 7.1.3 of the EIS Guidelines states: "The EIS will take into account how local conditions and natural hazards, such as severe and/or extreme weather conditions and external events (e.g., flooding, ice jams, landslides, avalanches, erosion, subsidence, fire, outflow conditions and seismic events) could adversely affect the project and how this in turn could result in impacts to the environment." and "The EIS will provide details of a number of planning, design and construction strategies intended to minimize the potential environmental effects of the environment on the project".

Information Request:

1. Assess the effects of extreme flood events (5-year vs. 100-year vs. 1000-year flood) on the seepage collection system including the ditches around the infrastructure, the collection and polishing ponds, the Blackwater Creek Tributary 2 realignment and the Tree Nursery Road culvert on the project site and how this in turn could result in impacts to the environment.
2. Provide details on a number of planning, design and construction strategies intended to minimize the potential effects from extreme flood events on the seepage collection system including the ditches around the infrastructure, the collection and polishing ponds, the Blackwater Creek Tributary 2 realignment and the Tree Nursery Road culvert on the project site.

IR-1 Reference #: EE(1)-02
Links to Annexes A3 and A4: PC(1)-50
s.5 Effect/Valued Component/EA Item: Effects of the Environment on the Project
Reference to EIS Guidelines: Section 7.1.3
Reference to EIS: EIS Section 4.4.2
Summary of Comment/Rationale: Section 4.4.2 (EIS) states that "the transmission line remains the most vulnerable Project component to fire." However, there is no mention of natural fires could affect the explosives storage facility and process plant.

Information Request:

1. Provide an assessment of the risk and effects of natural fires on the explosives storage facility and process plant and how this in turn could result in impacts to the environment.
2. Provide details on a number of planning, design and construction strategies intended to minimize the potential environmental effects from natural fires on the explosives storage facility and process plant.
3. Describe the fire suppression system and where and how the water used for putting out fires will be collected.

IR-1 Reference #: EE(1)-03
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Effects of the Environment on the Project
Reference to EIS Guidelines: Section 7.1.3
Reference to EIS: EIS Section 4.4.3
Summary of Comment/Rationale: Section 4.4.3 (EIS) states: "The TSF dam will be designed to withstand the maximum earthquake in accordance with the latest version (2007) of the Canadian Dam Association Dam Safety Guidelines, the Ministry of Natural Resources and Forestry Best Management Practices (2011) and the Provincial Lakes and Rivers Improvement Act." However, there is no mention of how earthquakes could affect the ore, overburden and waste rock stockpiles and the open pit.

Information Request:

1. Provide an assessment of the risk and effect of earthquakes on the ore, overburden and waste rock stockpiles and the open pit, using local seismic stability data, and how this in turn could result in impacts to the environment.
2. Provide details on a number of planning, design and construction strategies intended to minimize the potential environmental effects from earthquakes on the ore, overburden and waste rock stockpiles and the open pit.

IR-1 Reference #: EE(1)-04
Links to Annexes A3 and A4: AC(1)-53
s.5 Effect/Valued Component/EA Item: Effects of the Environment on the Project
Reference to EIS Guidelines: Section 7.1.3
Reference to EIS: EIS Sections 3.7, 4.4.4
Summary of Comment/Rationale: Section 4.4.4 (EIS) states: "Project components and infrastructure are being designed as per best engineering practices to ensure safe operation. Personnel will be trained to take emergency measures as part of the emergency and spill response plan in the unlikely event a tornado or other wind event occurs at the Project site." It is not clear which project components and infrastructure were considered. In addition, section 3.7 (EIS) states that a water cover over the tailings beach is proposed to be maintained to minimize potential acid generation of the tailings solids during operations. Wave run-up and wave overtopping the dam embankments may result from high wind or tornado events.

Information Request:

1. Identify the project components and infrastructure that may be affected by tornadoes or high-wind events. Assess the effect of tornadoes and high-wind events on these project components and infrastructure and how this in turn could result in impacts to the environment.
2. Assess the effect of tornadoes and high-wind events on the water cover in the tailings storage facility during operations and the environmental effects from potential wave run-up and overtopping.
3. Provide details on a number of planning, design and construction strategies intended to minimize the potential environmental effects from tornadoes and high-wind events on project components and infrastructure, including the water cover in the tailings storage facility during operations.

IR-1 Reference #: EE(1)-05
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Effects of the Environment on the Project
Reference to EIS Guidelines: Section 7.1.3
Reference to EIS: EIS Section 4
Summary of Comment/Rationale: Section 4 (EIS) does not describe the effects of drought on the Project. It is not clear whether drought conditions could impact the tree nursery ponds which in turn may impact the amount of water required for mine processing. Drought conditions may also have an impact on ability to release treated effluent into Blackwater Creek.

Information Request:

1. Assess the effect of drought conditions on water availability for mine processing and the ability to discharge treated effluent into Blackwater Creek and how this in turn could result in impacts to the environment. Explain the actions to be executed. If alternative water sources will be considered, describe the proposed alternatives.

IR-1 Reference #: EE(1)-06
Links to Annexes A3 and A4: PC(1)-53; PC(1)-71; AC(1)-114; AC(1)-260; AC(1)-303; AC(1)-314; AC(1)-364
s.5 Effect/Valued Component/EA Item: Effects of the Environment on the Project
Reference to EIS Guidelines: Section 7.1.3
Reference to EIS: EIS Section 4.4.5
Summary of Comment/Rationale: Section 4.4.5 (EIS) states that "various climate change assessments have been developed for northern Ontario. These statements predict an increase in temperature, stable to increasing precipitation, more episodic precipitation and an increased risk of natural fires." Also "due to the short nature of the Project and historical and reference documentation it would therefore appear that the runoff and water regimes of the area are likely to remain close to the current levels". Section 7.1.3 of the EIS Guidelines states that "longer-term effects of climate change will also be discussed up to the projected post-closure phase of the project. This discussion will include a description of climate data used".

Information Request:

1. Provide quantitative information from the climate change assessments developed for northern Ontario, including historical and reference documentation and climate predictions for the area, specifically for temperature and precipitation, in order to substantiate the provided predictions. Using this information, describe in more detail the potential longer-term effects of climate change on the project.

IR-1 Reference #: EE(1)-07
Links to Annexes A3 and A4: AC(1)-85; AC(1)-08
s.5 Effect/Valued Component/EA Item: Effects of the Environment on the Project; Current Use of Lands and Resources; Section 5(2) Effects
Reference to EIS Guidelines: Sections 7.1.3, 16
Reference to EIS: EIS Section 5.9.4; EIS Summary Section 4.2.2; Appendix G Section 8.5.4.2.1.5
Summary of Comment/Rationale: Section 5.9.4 (EIS) indicates that beaver dams and lodges are frequent on Blackwater Creek and Hughes Creek and their tributaries. The Project may be impacted by the potential for Blackwater Creek to be dammed by beavers and the year round increase of flow during operations. As Aboriginal groups expressed that beavers are an important species that is traditionally hunted and commercially trapped, the effects on Aboriginal peoples of managing and monitoring beavers and the removal of beaver dams for project operations need to be assessed as part of the environmental assessment. Measures to mitigate these effects need to consider views and participation of Aboriginal peoples and need to be developed in a culturally sensitive manner. The proponent should work with local trappers to achieve this.

Information Request:

1. Provide details on how beavers and beaver dams will be monitored and managed, taking into consideration the importance of beavers from an Aboriginal perspective and including any plans to engage Aboriginal peoples in the design and implementation of beaver monitoring and management.

BENEFITS OF THE PROJECT

IR-1 Reference #: PB(1)-1
Links to Annexes A3 and A4:
s.5 Effect/Valued Component/EA Item: Benefits to Canadians
Reference to EIS Guidelines: Section 15
Reference to EIS: Section 10
Summary of Comment/Rationale: Table 10.1.1 (EIS, pages 10-1 to 10-4) lists changes to the project and their benefits. It is unclear what effects to Aboriginal peoples, the public, and the environment are potentially reduced by the changes. Also, Section 10.2 (EIS) only describes predicted economic benefits; there is no discussion on environmental or social benefits of the Project. Section 15 of the EIS Guidelines requires the proponent to summarize how the environment, Aboriginal peoples and the public benefit from the changes to the Project and describe the predicted environmental, economic and social benefits of the Project.

Information Request:

1. Describe the effects to Aboriginal peoples, the public, and the environment that are potentially reduced, which are linked to the changes in the Project since initially proposed.
2. Provide details on predicted environmental and social benefits of the Project.

IR-1 Annex A2

Annex A2 - Other Government Comments on the April 2015 Environmental Impact Statement for the Goliath Gold Project

Table 1 - Regulatory Comments and Supplementary Actions for Consideration by the Proponent

Reference Number: RG(1)-01
Source Reference #: EC-26
s.5 Effect/Valued Component/EA Item: Fish Habitat
Reference to EIS Guidelines: EIS Table 12.4.2 (p. 12-9)
Summary of Comment/Rationale: The proponent specifies that fish tissue analysis will be conducted for areas affected by stream realignments and referenced areas. Under the MMER a mine is required to conduct a study respecting fish tissue (downstream of project discharge and reference area) if during effluent characterization a concentration of total mercury in the effluent is ≥ 0.10 µg/L.

Corrections or Suggestions:

1. Table 12.4.2 should reflect the requirements of the MMER as described in the summary comment.

Reference Number: RG(1)-02
Source Reference #: EC-48
s.5 Effect/Valued Component/EA Item: Fish Habitat
Reference to EIS Guidelines: Appendix II
Summary of Comment/Rationale: The proponent has not provided estimated costs for the Fish Habitat Compensation Strategy. The estimated costs associated with the development, implementation and monitoring of the proposed strategy, a key mitigation measure for the project, should be presented to regulators and stakeholders for consideration during the EA. This is a requirement of the "Streamlining the Approvals Process for Metal Mines with Tailings Impoundment Areas" (https://www.ec.gc.ca/pollution/default.asp?lang=En&n=EFAD32D1-1).

Corrections or Suggestions:

1. Provide the estimated costs for the development, implementation and monitoring of the Fish Habitat Compensation Plan.

Reference Number: RG(1)-03
Source Reference #: EC-58
s.5 Effect/Valued Component/EA Item: Fish Habitat
Reference to EIS Guidelines: Appendix II
Summary of Comment/Rationale: Appendix II states: "No current locations for in-kind offset habitat locations have been selected due to non-finalized Project design, and lack of First Nation and public input into the design of the NNLP." Without this information the impacts of the proposed mine waste disposal alternatives cannot be fully understood, and therefore it cannot be determined if the proposed mitigation measures are appropriate.

Corrections or Suggestions:

1. Provide an executive summary of the Fish Habitat Compensation Plan for consultation purposes.

Reference Number: RG(1)-04
Source Reference #: EC-54
s.5 Effect/Valued Component/EA Item: Alternatives Assessment
Reference to EIS Guidelines: Appendix D; EIS Section 2
Summary of Comment/Rationale: It is not clear whether or not the sensitivity analysis provided in the Alternatives Assessment Report (Appendix D) incorporates feedback from stakeholders as set forth in the EIS Guidelines.

Corrections or Suggestions:

1. Provide rationale for the selection of various developed scenarios.

Reference Number: RG(1)-05
Source Reference #: EC-55
s.5 Effect/Valued Component/EA Item: Alternatives Assessment
Reference to EIS Guidelines: Appendix D; EIS Section 2
Summary of Comment/Rationale: It is not clear that the pre-screening criterion 5 in the Alternatives Assessment Report (Appendix D) would result in a "fatal-flaw" for a given alternative. Alternatives may be excluded based on distance if the distance between the mill/mine complex and the tailings impoundment area becomes too great to ensure a positive economic outcome to the project. It is unclear how exceeding a "practical" distance would result in a "fatal-flaw" for a given alternative.

Corrections or Suggestions:

1. Provide an explanation as to what would constitute a disposal site that exceeds a practical distance from the mill and why it would be a "fatal flaw" for an alternative.
2. Provide details as to what distance is deemed economically unviable (i.e., would result in negative overall project economics) and why.

Reference Number: RG(1)-06
Source Reference #: EC-65
s.5 Effect/Valued Component/EA Item: Alternatives Assessment
Reference to EIS Guidelines: Appendix D, Tables 4.3-4.4; EIS Section 2
Summary of Comment/Rationale: The indicator quantity assigned to Alternatives 1C and 6C in Table 4.4. (Appendix D), and throughout the multiple account analysis, for the indicator Pipeline/Access Road Requirements are in question. According to Table 4.3 (Appendix D), existing road infrastructure can be used to haul tailings for these alternatives. Therefore, it is unclear what (and why) additional length of infrastructure would be required.

Corrections or Suggestions:

1. Clarify Pipeline/Access Road Requirements for the referenced alternatives and explain how this will affect the outcome of the value-based-decision process.

Reference Number: RG(1)-07
Source Reference #: EC-66
s.5 Effect/Valued Component/EA Item: Alternatives Assessment
Reference to EIS Guidelines: Appendix D, Tables 4.3-4.4
Summary of Comment/Rationale: - The rankings assigned in Table 4.4 (Appendix D) for the following indicators do not correspond to those assigned in Table 4.3 (Appendix D) for the same respective indicators: Sensitivity to Climate Variability, Risk to Worker Safety, Economic Benefits to Regional Communities, Regional Job Creation, and Diversity

Corrections or Suggestions:

1. Clarify and, if necessary, revise the discrepancy between the information presented in Tables 4.3 and 4.4 (Appendix D) and explain how this will affect the outcome of the value-based-decision process.

Reference Number: RG(1)-08
Source Reference #: EC-53
s.5 Effect/Valued Component/EA Item: Alternatives Assessment
Reference to EIS Guidelines: Appendix D Tables 4.6, 4.7; EIS Section 2
Summary of Comment/Rationale: The quantitative analysis in the Alternatives Assessment (AA) Report (Appendix D) has not been completed according to current guidance: http://ec.gc.ca/pollution/default.asp?lang=En&n=125349F7-1 According to the guidance, a weighting factor is applied to each indicator based on input from stakeholders. Instead, it appears that in Table 4.6 of the AA (under the "Indicator Weight" column), the proponent has assigned to the ‘indicators' weightings that are recommended by Environment Canada for ‘accounts' under section 2.6.2 of the Guidelines, i.e., Environment – 6, Technical – 3, Project Economics 1.5, and Socio-Economic – 3. This is also the case for sub-account weightings in Table 4.7.

Corrections or Suggestions:

1. Assign, for each indicator, a weighting factor (usually between 1 and 6), with appropriate input from the Aboriginal groups and stakeholders in Table 4.6.
2. Assign sub-account weightings (under the "Sub-Account Weight" column) for each ‘sub-account' based on input from the stakeholders. Each weighting factor should have a value between 1 and 6.

Reference Number: RG(1)-09
Source Reference #: EC-57
s.5 Effect/Valued Component/EA Item: Mine Waste; Surface Water
Reference to EIS Guidelines: Appendix D
Summary of Comment/Rationale: Additional information is required in order for the Crown to conduct effective regulatory consultations regarding proposed amendments to Schedule 2 of the MMER.
Corrections or Suggestions: Provide the following information which is required for Government of Canada consultations as well as the development of the proposal seeking approval to amend Schedule 2 of the MMER: the name and location of the water bodies that will be potentially impacted (water bodies to be listed in Schedule 2 of MMER in order to get authorization); the overall TIA footprint and the size of the water bodies that will be overprinted; an estimate of the volume of waste to be disposed and stored (after recycling and discharge); and assumptions used in its quantification; and an Executive Summary of the AA in plain language that can be distributed during consultations; and which includes: a summary of the above information; an overview of key environmental effects associated with the TIA and technical and economical mitigation measures proposed (FHSCP +Sec 4.3.2 of the EIS, TMF risk management); and Reference to the location of the complete document in the EIS (Appendix D).

Reference Number: RG(1)-10
Source Reference #: EC-45
s.5 Effect/Valued Component/EA Item: ARD
Reference to EIS Guidelines: EIS Section 11
Summary of Comment/Rationale: Pyrites contained in tailings are a significant contributor to acid rock drainage (ARD). A flotation circuit can be employed to remove pyrites within the tailings. This measure could help reduce the potential for ARD even if the overburden cap loses its effectiveness over time and allows water and oxygen to penetrate into the tailings.

Corrections or Suggestions:

1. Consider assessing the benefits of pyrite removal from the tailings as a measure to reduce the potential for ARD over the long-term in the abandonment phase of the Project.

Reference Number: RG(1)-11
Source Reference #: DFO-10
s.5 Effect/Valued Component/EA Item: Fish Habitat
Reference to EIS Guidelines: EIS Summary Sections 12.4.2, 12.4.2.12
Summary of Comment/Rationale: The EIS states that changes to water quality due to release of a deleterious substances into a watercourse could affect fish habitat during operations and that habitat compensation will be provided as per the Fisheries Act. The deposit of a deleterious substance into fish frequented waters is prohibited under subsection 36(3) of the Fisheries Act. A proponent cannot provide compensation (offsetting) in response to a deposit of a deleterious substance, this is an offense under the Fisheries Act, would have to be reported to DFO, and investigated in order to bring the proponent into compliance with the Act. Subsection 38(5) of the Fisheries Act states that should a deleterious substance be deposited or there is the potential for such an incident, the proponent has the duty to notify DFO. Subsection 38(6) requires the proponent of any reported incident to take all reasonable corrective measures to prevent this occurrence or mitigate and remedy any adverse effects.
Corrections or Suggestions: Clarify if this reference to a deposit or release is with regards to the tailings impoundment area.

Reference Number: RG(1)-12
Source Reference #: MNRF-21
s.5 Effect/Valued Component/EA Item:
Reference to EIS Guidelines: EIS Section 1.2.3
Summary of Comment/Rationale: Section 1.2.3 (EIS) states: "Additional land deals are being negotiated as of the time of the submission of the environmental assessment (EA)."

Corrections or Suggestions:

1. Land ownership/disposition is required to be finalized prior to commencement of any operations.

Reference Number: RG(1)-13
Source Reference #: MNRF-19
s.5 Effect/Valued Component/EA Item:
Reference to EIS Guidelines: EIS Table: 1.5.1
Summary of Comment/Rationale: Table 1.5.1 (EIS, page 1-20) does not include the Ministry of Natural Resources and Forestry's aggregate permit issued under the Aggregate Resources Act (ARA) as a potential permit. The requirement for a permit depends on where the aggregate is obtained. If aggregate is to be obtained from a new source on Crown land, this will require an aggregate permit. If non-acid generating waste rock from the mining operations is used as aggregate, this will not require a permit.

Corrections or Suggestions:

1. Be aware of the potential requirement for an aggregate permit under the Aggregate Resources Act and include this in future documentation of permits that may be required.

Reference Number: RG(1)-14
Source Reference #: MNRF-20
s.5 Effect/Valued Component/EA Item:
Reference to EIS Guidelines: EIS Section 3.14.5
Summary of Comment/Rationale: Section 3.14.5 (EIS) speaks about the possible development of quarries or pits and reclaimed according to provincial standards. Any pits or quarries developed on Crown land, or Crown leases will require an aggregate permit issued under the Aggregate Resources Act.

Corrections or Suggestions:

1. Be aware of the potential requirement for an aggregate permit under the Aggregate Resources Act and include this in future documentation of permits that may be required.

Reference Number: RG(1)-15
Source Reference #: MNRF-44
s.5 Effect/Valued Component/EA Item:
Reference to EIS Guidelines: EIS Section 6.4.5.2
Summary of Comment/Rationale: "Therefore, based on the private land holdings and the SLRA it has been determined that the Project will have no significant effect to hunting and trapping activities within the LSA. Regionally hunting and trapping can continue as per the limits imposed by the OMNRF. No follow-up activities are required." Under hunting and trapping section the line "Regionally hunting and trapping can continue as per the limits imposed by the OMNRF" is incorrect as MNRF does not impose limits on Aboriginal subsistence harvest.

Corrections or Suggestions:

1. Consider amending or removing line in this section.

Reference Number: RG(1)-16
Source Reference #: MNRF-07
s.5 Effect/Valued Component/EA Item:
Reference to EIS Guidelines: Appendix G Section 8.5.4.2.1.5
Summary of Comment/Rationale: "Beaver dams and lodges are frequent on Blackwater Creek and Hughes Creek and their tributaries." Due to the year round increase of flow in Blackwater creek, a monitoring plan should be put in plan to ensure Blackwater Creek is not impacted (dammed) by beavers.

Corrections or Suggestions:

1. Trapping and killing of the existing beaver and destruction of any beaver dams or beaver lodges should be arranged with the local trappers through the local trapper's council. If arrangements are not made with the local trappers, authorizations will be required through the Ministry of Natural Resources and Forestry.

Reference Number: RG(1)-17
Source Reference #: MNRF-13
s.5 Effect/Valued Component/EA Item:
Reference to EIS Guidelines: Appendix G section 9.3.6.1; Appendix F of Appendix M Figure 1.
Summary of Comment/Rationale: Section 9.3.6.1 (Appendix G) states: "Lola Lake Park likely provides the area with significant ecological functions such as groundwater discharge, wildlife habitat and carbon storage (Harris pers. comm. 2011).The presence of iron precipitates (Appendix VII-2, Plate 11) and rich minerotrophic indicators including sticky tofieldia (Triantha glutinosa), tufted clubrush (Trichophorum cespitosum), and creeping juniper (Juniperus horizontalis) indicate that there is a strong flow of nutrient rich ground water from the peatland (NE to SW) into the ponds at the tree nursery grounds and eventually into Thunder Lake." The hydrogeology of the project area as shown in Figure 1 (Appendix F of Appendix M) includes a portion of Lola Lake Provincial Park, which is an extensive wetland area. It is likely that groundwater flows impact the hydrology of Lola Lake Park and the associated biology. Groundwater is likely to be a factor in Lola Lake Park's hydrology; therefore, the hydrological changes caused by the dewatering of the mine may change the wetland ecosystem. The management direction for this Park requires that the ecosystem be preserved. There is also a high potential for plant and insect species that are rare or Species at Risk to be identified in this Park. MNRF's Mandate: The Lola Lake Provincial Park "Management Statement states: Maintenance of ecological integrity shall be the first priority and the restoration of ecological integrity shall be considered (PPCRA). Restrictions on recreational activities (Section IV) and commercial activities (Section V), as noted above, are expected to provide adequate protection to the life science features. If any unforeseen threats to the preservation of these features arise, appropriate measures and/or restrictions will be implemented through planning." The risk of altering the wetland ecosystem and plant communities within the Park is high. A greater study of the hydrology in Lola Lake Park and adjacent to the Park (the north section of the map in Figure 1) to better determine the impacts to the Park ecology should be done. Also, fen inventories, vegetation, and SAR surveys should be conducted to determine a baseline for this Park before water level changes occur.

Corrections or Suggestions:

1. A greater study of the hydrology in Lola Lake Park and adjacent to the Park (the north section of the map in Figure 1) to better determine the impacts to the Park ecology should be done. Fen inventories, vegetation, and SAR surveys should also be done to determine a baseline for this park before water level changes occur.
2. The risk is high of altering the wetland ecosystem and plant communities within the Park. Therefore it is strongly suggested that fen inventories and hydrology studies of Lola Lake Provincial Park are conducted to better determine the impact and baseline conditions with an acceptable consultant. If hydrology is determined to be an issue to the long term sustainability of Lola Lake Provincial Park then mitigation measures will need to be considered from a design and operational perspective of the mine site.

Reference Number: RG(1)-18
Source Reference #: MNRF-13
s.5 Effect/Valued Component/EA Item: Species at Risk
Reference to EIS Guidelines: Appendix G Section 9.3.6.1; Appendix F of Appendix M Figure 1.
Summary of Comment/Rationale: Section 9.3.6.1 (Appendix G) states: "Lola Lake Park likely provides the area with significant ecological functions such as groundwater discharge, wildlife habitat and carbon storage (Harris pers. comm. 2011).The presence of iron precipitates (Appendix VII-2, Plate 11) and rich minerotrophic indicators including sticky tofieldia (Triantha glutinosa), tufted clubrush (Trichophorum cespitosum), and creeping juniper (Juniperus horizontalis) indicate that there is a strong flow of nutrient rich ground water from the peatland (NE to SW) into the ponds at the tree nursery grounds and eventually into Thunder Lake." The hydrogeology of the project area as shown in Figure 1 (Appendix F of Appendix M) includes a portion of Lola Lake Provincial Park, which is an extensive wetland area. It is likely that groundwater flows impact the hydrology of Lola Lake Park and the associated biology. Groundwater is likely to be a factor in Lola Lake Park's hydrology; therefore, the hydrological changes caused by the dewatering of the mine may change the wetland ecosystem. The proponent also intends to take mine processing water from irrigation ponds fed by tributaries flowing out of Lola Lake Park. There is high potential for plant, reptile, amphibian and insect species that are rare or species at risk to be identified in this park.

Corrections or Suggestions:

1. Conduct fen inventories, vegetation, and SAR surveys to determine a baseline for Lola Lake Park before water level changes occur.
2. Describe mitigation measures to ensure long term sustainability of Lola Lake Park's wetland ecosystem.

Reference Number: RG(1)-19
Source Reference #: MNRF-03
s.5 Effect/Valued Component/EA Item: Species at Risk
Reference to EIS Guidelines: Appendix G; EIS Section 11.3.5
Summary of Comment/Rationale: Barn swallows are migratory birds that are listed as threatened on the Species at Risk List of Ontario and receive species and habitat protection under Ontario's Endangered Species Act. As such, barn swallow surveys should be conducted in accordance with MNRF protocols and recommended procedures.
Corrections or Suggestions: Complete an Information Gathering Form to provide information on any potential effects to barn swallows on the project site. This includes nesting barn swallows within the old tree nursery buildings, as well as any other nest locations that may be found. In addition, the abandoned structure located at UTM: 528132 E, 5511704 N would be considered high potential habitat for barn swallow.

Reference Number: RG(1)-20
Source Reference #: MOECC-GW-02; MOECC-GW-03
s.5 Effect/Valued Component/EA Item: Mine Waste
Reference to EIS Guidelines: EIS Sections 2.3.12, 2.3.14
Summary of Comment/Rationale: Section 2.3.12 (EIS) states that the preferred option for the disposal of non-hazardous waste is trucking the waste to the Dryden landfill facilities, but it was only assumed that the landfills have capacity to serve the project for the life of the mine. Section 2.3.14 (EIS) states that the preferred option for the disposal of domestic sewage is offsite treatment, and that it was assumed that this option provides no capacity constraints. Please note that an Environmental Compliance Approval (ECA) will be required for any onsite treatment facility. It may also be necessary to amend the ECA of the offsite sewage facility.

Corrections or Suggestions:

1. Provide evidence that the Dryden landfill facilities have the capacity to serve the Project for the life of the mine, that the mine is located within the approved service area of the landfill facilities, and that the City of Dryden is willing to enter into a waste disposal contract.
2. Provide evidence that appropriate domestic sewage facilities exist and have adequate capacity to serve the Project for the life of the mine, or until onsite treatment can be established.

Reference Number: RG(1)-21
Source Reference #: MOECC-ABATE-01
s.5 Effect/Valued Component/EA Item: Human Environment
Reference to EIS Guidelines: EIS Summary; Section 4.8
Summary of Comment/Rationale: Section 4.8 (EIS Summary) states: "All fuel and chemical waste will be stored on site in appropriate collection tanks and bins and disposed of in an appropriate off-site facility." The guidelines of the Ministry of the Environment and Climate Change (MOECC) for environmental protection measures at chemical and waste storage facilities (MOECC May 2007) is intended for use by owners/operator/designers of chemical and waste storage facilities and the MOECC. This document will aid the proponent in assessing the necessary environmental protection measures for chemical and waste storage areas and protection measures for human health. This document can be used as a resource during planning of upgrades to existing storage areas and for the design and operation of new facilities. The above mentioned document is what the MOECC expects the proponent to set as the minimum level of protection at chemical and waste storage facilities.

Corrections or Suggestions:

1. The proponent is encouraged to go beyond the minimum MOECC standard for environmental protection measures at chemical and waste storage facilities (MOECC May 2007).

Reference Number: RG(1)-22
Source Reference #: MOECC-ABATE-02; MNO-58
s.5 Effect/Valued Component/EA Item: Human Environment
Reference to EIS Guidelines: EIS Summary; Section 4.8; EIS Section 2.3.12
Summary of Comment/Rationale: Section 4.9 (EIS Summary) states: "Non-hazardous solid waste, such as food scraps, refuse, fabric, metal tins, scrap metal, glass, plastic, wood, paper, and similar materials, will be stored temporarily for subsequent transport to an existing off-site landfill facility. The City of Dryden landfill currently has the capacity to support the future Goliath non-hazardous waste requirements." The following are unclear: whether the City of Dryden is capable of handling solid non-hazardous waste from the site according to the City's environmental compliance approval, what pressures will this proposed mine site have on existing waste management infrastructure i.e. landfill life expectancy, and whether the City of Dryden confirmed its willingness to accept solid non-hazardous waste from the Project. If answers to the above suggest the proposed non-hazardous waste management option is not viable, then the proponent should investigate other options in accordance with provincial requirements.

Corrections or Suggestions:

1. Ensure the city of Dryden is capable of handling solid non-hazardous waste from the site according to the City's environmental compliance approval.
2. Identify and report the pressures this proposed mine site will have on existing waste management infrastructure (i.e. landfill life expectancy).
3. Confirm the city of Dryden is willing to accept solid non-hazardous waste from the Project.
4. If the proposed non-hazardous waste management option is not viable, then identify an alternative in accordance with the requirements of the province of Ontario.

Reference Number: RG(1)-23
Source Reference #: MOECC-ABATE-03; AC(1)-129
s.5 Effect/Valued Component/EA Item: Project Description
Reference to EIS Guidelines: EIS Summary; Section 4.11
Summary of Comment/Rationale: Section 4.11 (EIS Summary) states: "The plant shall be supplied from the Hydro One 115 kV power line circuit M2D via one 138 kV 600 A motorized disconnect switch 270-DS-001 in series with one 1200 A, SF₆ circuit breaker 270-CB-001." Based on the size of the proposed transformer, it is unclear whether the Project will be subject to a Ministry of the Environment and Climate Change (MOECC) Class Environmental Assessment.

Corrections or Suggestions:

1. Confirm whether or not the Project would be subject to a MOECC Class Environmental Assessment and provide the rationale.

Reference Number: RG(1)-24
Source Reference #: MOECC-ABATE-04
s.5 Effect/Valued Component/EA Item: Air Quality; Cumulative Environmental Effects
Reference to EIS Guidelines: EIS Summary; Section 6.2
Summary of Comment/Rationale: Section 6.2 (EIS Summary) indicates there are no anthropogenic sources of air emissions located proximal to the development.
Corrections or Suggestions: Do not dismiss the potential impact that other emitters (such as Domtar Inc. in Dryden) may have on local air quality. No evidence to discount the impact from local sources, such as the Domtar Inc. Dryden mill, was provided. This may be considered for MOECC permits and approvals.

Reference Number: RG(1)-25
Source Reference #: MOECC-GW-15
s.5 Effect/Valued Component/EA Item: Groundwater Quality
Reference to EIS Guidelines: EIS Section 13.1.4
Summary of Comment/Rationale: Laboratory analyses for various chemical parameters were not discussed in section 13.1.4 (EIS), some of which are required for a mine's groundwater quality monitoring program under Ontario Regulation (O. Reg.) 240/00—Mine Development and Closure Under Part VII of the Act. The parameters in question include, but are not limited to, pH, conductivity, TSS, hardness, and ammonium. Complete details of the groundwater quality monitoring program will be required for the Provincial permitting phase.
Corrections or Suggestions: Analyze the parameters referred to in the comments section of this IR and add them to the groundwater quality monitoring program.

Reference Number: RG(1)-26
Source Reference #: MOECC-GW-14; MOECC-GW-36
s.5 Effect/Valued Component/EA Item: Groundwater Quality
Reference to EIS Guidelines: EIS Section 13.1.2; Figures 13.1.1, 3.5.1, 3.5.2
Summary of Comment/Rationale: The proponent will be required to comply with Guideline B-7 ("Incorporation of the Reasonable Use Concept into MOEE Groundwater Management Activities", dated April 1994, as amended) at all property boundaries. It is noted that the low grade ore (LGO) stockpile is located adjacent to a property boundary. This location may require detailed groundwater control measures and monitoring, the need for which should be identified in the EIS, and the specifics of which will be expected during Provincial permitting. The current groundwater monitoring locations are not likely to be sufficient, and a monitoring program that includes additional wells will be expected during provincial permitting. Specific areas where wells will be required include, but need not be limited to, the LGO area and east of Thunder Lake. Figures 3.5.1 and 3.5.2 (EIS, pages 3-14 and 3-15) show the property boundary immediately adjacent to the overburden stockpile, the waste rock stockpile, and the pit. It appears that the property boundary has been extended in these areas, but it cannot be confirmed. The Ministry of the Environment and Climate Change (MOECC) recommends [for the purpose of provincial regulatory requirements] that the monitoring network be finalized with the MOECC, the wells installed as soon as reasonably possible, the proposed groundwater level monitoring program initiated as soon as reasonably possible, and the proposed groundwater quality monitoring program initiated as soon as reasonably possible. The details of the groundwater monitoring program [as required by the MOECC] will be finalized during the provincial permitting phase; however, it is beneficial to have as much monitoring data as possible prior to the construction phase of the Project and monitoring should be initiated as proposed, with the inclusion of any modifications herein, as soon as reasonably possible.

Corrections or Suggestions:

1. Additional groundwater monitoring wells will be required in the groundwater monitoring network during the provincial permitting phase.
2. Compliance with Guideline B-7 is required at all property boundaries and there must be appropriate monitoring and contingency plans in place before any Environmental Compliance Approvals (ECAs) can be issued for these facilities.
3. Confirm that the property boundary has been extended away from the main mine facilities and is not as depicted in Figures 3.5.1 and 3.5.2 of the EIS.

Reference Number: RG(1)-27
Source Reference #: MOECC-GW-18
s.5 Effect/Valued Component/EA Item: Surface Water Quality and Quantity
Reference to EIS Guidelines: Appendix D Section 3.4
Summary of Comment/Rationale: While it is known that the stormwater management plan will develop as the Project develops, additional, and more accurate, information will be required for permitting.
Corrections or Suggestions: Keep in mind that when applying for provincial permits, more comprehensive information regarding stormwater management will be required.

Reference Number: RG(1)-28
Source Reference #: MOECC-GW-21
s.5 Effect/Valued Component/EA Item: Groundwater Quality
Reference to EIS Guidelines: Appendix D Section 5.8
Summary of Comment/Rationale: Section 5.8 (Appendix D) states: "it is recommended that the boreholes be constructed before commissioning the tailings storage facility to accumulate baseline data specific to the storage location." The Ministry of the Environment and Climate Change concurs with this statement as this baseline data will be important during the provincial permitting process and during the life of the mine.
Corrections or Suggestions: It is recommended that boreholes/wells be constructed and groundwater monitoring commence as early as possible in the 2015 season.

Reference Number: RG(1)-29
Source Reference #: MOECC-GW-35
s.5 Effect/Valued Component/EA Item: Groundwater Quality
Reference to EIS Guidelines: Appendix L
Summary of Comment/Rationale: There does not appear to be any modeling associated with Appendix L. Water quality assessment associated with geochemical modelling is an important step in helping to assess effects of the Project on the environment. The required information will also be necessary in full detail for the provincial permitting phase.
Corrections or Suggestions: Provide details of the geochemical modelling conducted and how it relates to the water quality assessment.

Reference Number: RG(1)-30
Source Reference #: MOECC-GW-38
s.5 Effect/Valued Component/EA Item: Groundwater Quality
Reference to EIS Guidelines: Appendix M Section 5.3.3
Summary of Comment/Rationale: Since there are domestic use wells near the property boundaries of the Project, there are risks associated with the proposed dewatering of the mine workings.
Corrections or Suggestions: During provincial permitting, it will be required that these risks be adequately mitigated and that adequate monitoring and contingencies be in place to protect the reasonable use of groundwater.

Reference Number: RG(1)-31
Source Reference #: MOECC-SW-08
s.5 Effect/Valued Component/EA Item: Surface Water Quality
Reference to EIS Guidelines: Appendix F
Summary of Comment/Rationale: The total fresh water requirement for the process plant is estimated to be 600 m³/day. Recycled effluent will account for approximately 450 m³/day, with the remaining 150 m³/day taken from the former tree nursery irrigation ponds. The former tree nursery ponds are situated on Thunder Lake Tributary #3. In order to meet the fresh water demand, the EIS states that 26% of the Thunder Lake Tributary #3 flow would be required. There is no discussion on the potential impacts of dewatering these ponds on either Thunder Lake Tributary #3 or associated wetlands.

Corrections or Suggestions:

1. Provide further information in relation to the potential environmental effects of water taking on the valued components. A more detailed assessment of hydrological changes and potential water taking impacts will be required by the Ministry of the Environment and Climate Change at the permitting phase of the Project. Monitoring and contingency plans will be required as part of a provincial Permit to Take Water, in conjunction with appropriate trigger mechanisms.

Reference Number: RG(1)-32
Source Reference #: MOECC-SW-04
s.5 Effect/Valued Component/EA Item: Surface Water Quality
Reference to EIS Guidelines: Appendix F
Summary of Comment/Rationale: Although the proponent has committed to a collection system for their seepage, there will be a percentage of seepage that cannot be collected and will discharge to the watershed. Anticipated seepage water quality indicates that some contaminants of concern will exceed Provincial Water Quality Objectives (PWQO) in the seepage from some mine facilities. Because the small tributaries within the project area have no assimilative capacity, seepage will be required to meet very stringent criteria at the point of discharge to surface waters (i.e., PWQO or background concentrations). The proponent will need to provide expected receiver loading calculations. Updated source concentrations and calculated discharge loadings to surface water receivers will need to be incorporated into the assessment to evaluate the impact to surface waters.

Corrections or Suggestions:

1. For provincial permitting, provide the following:
   1. Quantification of potential seepage;
   2. Predicted loadings of contaminants of concern from seepage;
   3. Assessment of potential impacts from discharge of seepage to surface water receivers;
2. Discharge criteria and treatment options will be considered during the provincial permitting process and will reflect the assimilative capacity of the surface water receivers. A monitoring program will be defined in the provincial environmental compliance approval (ECA) for the site. A contingency plan will be required and the potential contingencies will be identified in the ECA, along with mitigation triggers.
3. During operations, closure and post-closure, the Ministry of Northern Development and Mines and Ministry of the Environment and Climate Change (MOECC) will work together in the provincial closure plan and approvals processes. MOECC will identify additional requirements outside of the closure plan to address seepage, if necessary, which would be applied through an ECA (e.g., collection, treatment and discharge).

Reference Number: RG(1)-33
Source Reference #: MOECC-SW-10
s.5 Effect/Valued Component/EA Item: Surface Water Quality
Reference to EIS Guidelines: Appendix F; Section 3.2.1
Summary of Comment/Rationale: Meeting MMER discharge limits for cyanide will not be adequate for discharge to the environment as site specific discharge limits will be determined in discussion with the Province. The natural attenuation and additional water treatment in the treatment plant may be necessary to achieve provincial permit effluent limits. Complete details of the TSF water budget and anticipated effluent concentrations to, and from, the TSF will be required for the provincial permitting phase.

Corrections or Suggestions:

1. Provide an estimate of the retention time of TSF water as it relates to natural attenuation of cyanide for the purposes of a contingency for the cyanide destruction circuit and ensuring compliance with Provincial permit effluent limit requirements.
2. Provide complete details of the TSF water budget and anticipated effluent concentrations to, and from, the TSF.

Reference Number: RG(1)-34
Source Reference #: MOECC-SW-06
s.5 Effect/Valued Component/EA Item: Surface Water Quality
Reference to EIS Guidelines: Appendix F; Section 11
Summary of Comment/Rationale: The expected pit lake and tailings storage facility (TSF) closure scenarios predict that concentrations of contaminants of concern (COCs) will exceed Provincial Water Quality Objectives (PWQO). The pit and TSF will both discharge passively to a tributary of Blackwater Creek. Because Blackwater Creek has no assimilative capacity, pit lake and TSF discharges will be required to meet very stringent discharge criteria at the point of discharge to the receiver (PWQO or background). In order to assess potential impacts to Blackwater Creek, an estimation of the contaminant loadings to the watershed and an assessment of potential long term impacts associated with these discharges are necessary.

Corrections or Suggestions:

1. Discharge criteria and treatment options will be considered during the provincial permitting process and will reflect the assimilative capacity of Blackwater Creek to receive discharge. The provincial environmental compliance approval (ECA) for the site will require a monitoring program and a contingency plan, which must include trigger criteria and feasible mitigation and remediation measures.
2. During operations, closure and post-closure, the Ministry of Northern Development and Mines and Ministry of the Environment and Climate Change (MOECC) will work together in the provincial closure plan and approvals processes. MOECC will identify additional requirements outside of the closure plan to address pit and TSF discharge, if necessary, which would be applied through an ECA (e.g., collection, treatment and discharge).

Reference Number: RG(1)-35
Source Reference #: MOECC-SW-02
s.5 Effect/Valued Component/EA Item: Surface Water Quantity
Reference to EIS Guidelines: Appendix F; Appendix N; Appendix O
Summary of Comment/Rationale: The site water balance is based on a conceptual model. Ongoing validation of this model will be required, both prior to provincial permitting and during mine operations, in order to confirm assumptions and/or update water balance predictions as necessary. As additional hydrology data becomes available, MOECC recommends that the Water Management Plan be reviewed and refined to reflect additional water balance information. This may include modifications or alterations of operational designs based on updated water balance modeling. Contingencies may be identified in the provincial permits, in conjunction with appropriate trigger mechanisms.
Corrections or Suggestions: A more detailed assessment of hydrological changes will be required by the MOECC at the provincial permitting phase. In order to address uncertainty in hydrology modeling, further flow monitoring will be required during provincial permitting, construction and operations to verify predictions and to develop a robust hydrograph for the potentially impacted watersheds.

Reference Number: RG(1)-36
Source Reference #: MOECC-SW-03
s.5 Effect/Valued Component/EA Item: Surface Water Quality
Reference to EIS Guidelines: Appendix G; Appendix N; Appendix P; Appendix Q; Appendix S
Summary of Comment/Rationale: Adequate baseline data will be required as part of the provincial permitting process. The purpose of baseline studies is to characterize the physical, chemical, and biological aspects of watersheds that may be potentially impacted by mining activities. The design of the baseline surface water monitoring program needs to include multi-year seasonal sampling to identify temporal variability associated with the collected data and to identify trends over time. Monitoring programs must be designed to statistically detect changes from baseline conditions. Surface water, sediment, benthic, fish community and fish tissue samples should be collected from all locations within the predicted zone of influence of the project including direct discharge locations, surface drainage locations, areas of water taking, and areas that may be influenced by groundwater seepage. The following needs to be considered when selecting sampling locations: adequacy to produce high quality samples that can be replicated; effectiveness of the location to define baseline conditions; use of the location for long term evaluation of potential effects of the project; and development of a reference condition for the watershed to facilitate comparisons with non-impacted watersheds and to evaluate watershed changes.
Corrections or Suggestions: Aquatic surveys will be a requirement of the provincial ECA and will include analysis of water and sediment chemistry, assessments of benthic macroinvertebrate and fish communities, and fish tissue analyses, in order to detect potential changes in the watershed.

Reference Number: RG(1)-37
Source Reference #: MOECC-ABATE-06
s.5 Effect/Valued Component/EA Item: Noise
Reference to EIS Guidelines: Appendix H
Summary of Comment/Rationale: Section 3 – Noise Source Summary (Appendix H) states: "Details regarding types of equipment used during the operations phase were limited at the time of this assessment. Best-available data regarding noise sources for future construction, operations, and decommissioning were collected from Treasury Metals, and used to predict sound levels for the Project. The significant sources were identified from drawings and the project description provided to RWDI by Treasury."
Corrections or Suggestions: Provincial approvals issued under Section 9 of the Environmental Protection Act concerning noise emissions will not be granted without a complete and detailed listing and assessment of all stationary noise sources associated with this project, including the points of reception and impacts on noise-sensitive land uses (as defined in NPC-300). This may be considered for MOECC permits and approvals.

Reference Number: RG(1)-38
Source Reference #: MOECC-ABATE-07
s.5 Effect/Valued Component/EA Item: Noise
Reference to EIS Guidelines: Appendix H
Summary of Comment/Rationale: Section 3.3 - Identifiable Source Characteristics (Appendix H) states: "Sources that have characteristics considered to be particularly annoying receive additional consideration in accordance with NPC-104 guidelines (MOE, 1978). The adjustment is based on assessment at the point of reception, as described in Publication NPC-103. No sources were identified to exhibit annoying sound emissions." Publication NPC 104 Sound Level Adjustments describes when sound level adjustments to NPC-300/NPC-232 are required. The adjustments are required for any tonal, cyclical or quasi-steady impulsive sounds. The operations of fans, electrical motors, generators, drills, etc. at the site may generate these types of sounds and therefore warrant a sound level adjustment as described in NPC-104. This has not been considered in the noise assessment.
Corrections or Suggestions: Sound characteristics described in Table 1: Noise Source Summary may need to be adjusted accordingly to account for sound level adjustments. This may be considered for MOECC permits and approvals.

Reference Number: RG(1)-39
Source Reference #: MOECC-ABATE-06
s.5 Effect/Valued Component/EA Item: Noise
Reference to EIS Guidelines: Appendix H
Summary of Comment/Rationale: Section 3 – Noise Source Summary (Appendix H) states: "Details regarding types of equipment used during the operations phase were limited at the time of this assessment. Best-available data regarding noise sources for future construction, operations, and decommissioning were collected from Treasury Metals, and used to predict sound levels for the Project. The significant sources were identified from drawings and the project description provided to RWDI by Treasury."
Corrections or Suggestions: Provincial approvals issued under Section 9 of the Environmental Protection Act concerning noise emissions will not be granted without a complete and detailed listing and assessment of all stationary noise sources associated with this project, including their points of reception and impacts on noise-sensitive land uses (as defined in NPC-300). This may be considered for MOECC permits and approvals.

Reference Number: RG(1)-40
Source Reference #: MOECC-ABATE-05
s.5 Effect/Valued Component/EA Item: Noise
Reference to EIS Guidelines: Appendix H
Summary of Comment/Rationale: Appendix H indicates noise sources were assessed on the basis of the worst case scenario as required by Section A.4 of NPC-233 (Annex to Publication NPC-232). Section 1 (Appendix H) states: "This assessment focuses on sound levels due to the Project at surrounding worst-case sensitive receptors. Sources at the facility include: ventilation equipment, building exhausts, on site vehicle traffic, and rock crushing equipment."

Corrections or Suggestions:

1. The worst case scenario presented did not include any sound level adjustments that would have lowered the allowable limits at sensitive receptors. This may be considered for MOECC permits and approvals.

Table 2 - Sundry Comments

Reference Number: SD(1)-01
Source Reference #:
s.5 Effect/Valued Component/EA Item: Surface Water; Groundwater
Reference to EIS Guidelines: EIS Sections 3, 5
Summary of Comment/Rationale: Hydrogeological Pre-Feasibility/EA Support Study Goliath Project, AMEC Environment & Infrastructure, August, 2014 is referred to in the text frequently but not included (or if it is included not referenced) in the appendices.
Corrections or Suggestions: A) Include or provide reference to Pre-Feasibility/EA Support Study Goliath Project, AMEC Environment & Infrastructure, August 2014 in the appendices.

Reference Number: SD(1)-02
Source Reference #:
s.5 Effect/Valued Component/EA Item: Species at Risk
Reference to EIS Guidelines: EIS Sections 3, 5, 5.10.3, 5.10.3.1, Table 1.10.1; Appendix S Section 3
Summary of Comment/Rationale: There are a number of inconsistencies between sections of the EIS document/appendices. Some of these include: No Plant species at risk (SAR) were identified in the project description presented in Chapter 3 (EIS). The proponent then goes on to identify Marsh Marigold in Section 5.10.3 (EIS). There are inconsistencies between the plant species listed on Tables 5.10.1 (EIS) and section 3.1 (Appendix S). Marsh marigold, the only identified plant SAR in the local study area, was not included in the wetland baseline study (Appendix S). Yellow birch (Betula alleghaniensis), bur oak (Quercus macrocarpa) and white elm (Ulmus laevis) were included in Table 5.10.1 (EIS) but not Table 3.1 (Appendix S). Beach-Heather (Hudsonia tormentosa) was included in Appendix S but not the EIS. Section 5.10.3.1 (EIS) refers to wild rice, which is not a SAR.

Corrections or Suggestions:

1. Revise sections referenced in the comments section of this IR to correct for inconsistencies between EIS sections and appendices.
2. Explain why some plant SAR were discussed in the EIS but not included in the study presented in appendix S and vice versa.
3. Remove wild rice from SAR discussion(s) in the EIS.

Reference Number: SD(1)-03
Source Reference #:
s.5 Effect/Valued Component/EA Item: Noise
Reference to EIS Guidelines: EIS Sections 3, 6, 13; Appendix H
Summary of Comment/Rationale: NPC-300 has replaced NPC-232. The proponent refers to both documents intermittently throughout the EIS and appendices.
Corrections or Suggestions: A) Revise the EIS and appendices to refer to the most recent guidelines.

Reference Number: SD(1)-04
Source Reference #: EC-15
s.5 Effect/Valued Component/EA Item: Surface Water Quality
Reference to EIS Guidelines: EIS Section 5.8.1, Table 5.8.1
Summary of Comment/Rationale: Note 1 and the explanation for the asterisk and double asterisks are missing in this table. Furthermore, the table only shows 8 locations added during the 2012/2013 sampling program but Section 5.8.1 (EIS) indicated that there were nine locations.

Corrections or Suggestions:

1. Provide Note 1 and the explanations for the asterisks in Table 5.8.1. Clarify whether there were 8 or 9 locations added during the 2012/2013 sampling program.

Reference Number: SD(1)-05
Source Reference #: MNRF-61
s.5 Effect/Valued Component/EA Item: Species at Risk
Reference to EIS Guidelines: EIS Section 5.9.4
Summary of Comment/Rationale: The bats that were detected include little brown bat, and northern long-eared bat, which are both endangered species under the Species at Risk in Ontario list.

Corrections or Suggestions:

1. This classification should be corrected.

Reference Number: SD(1)-06
Source Reference #: MNRF-59
s.5 Effect/Valued Component/EA Item: Species at Risk
Reference to EIS Guidelines: EIS Table 5.9.5
Summary of Comment/Rationale: In Table 5.9.5 (EIS, page 5-95) the "Provincially Significant" species are actually provincial species at risk (special concern) under the Species at Risk in Ontario list.

Corrections or Suggestions:

1. This classification should be corrected.

Reference Number: SD(1)-07
Source Reference #: MNRF-59
s.5 Effect/Valued Component/EA Item: Species at Risk
Reference to EIS Guidelines: EIS Table 5.9.5
Summary of Comment/Rationale: In Table 5.9.5 (EIS, page 5-95) the "Provincially Significant" species are actually provincial species at risk (special concern) under the Species at Risk in Ontario list.

Corrections or Suggestions:

1. This classification should be corrected.

Reference Number: SD(1)-08
Source Reference #: MNRF-60
s.5 Effect/Valued Component/EA Item: Species at Risk
Reference to EIS Guidelines: EIS Section 5.9.5
Summary of Comment/Rationale: The barn swallow is listed as having active nests on buildings on the grounds of the former tree nursery. It should be noted that barn swallows are listed as threatened under the Species at Risk in Ontario list.

Corrections or Suggestions:

1. This classification should be corrected.

Reference Number: SD(1)-09
Source Reference #:
s.5 Effect/Valued Component/EA Item: Fish and fish Habitat
Reference to EIS Guidelines: EIS Section 6.2.1.12
Summary of Comment/Rationale: Section 6.2.1.12 states that "Makeup water may be required for operation of the processing plant and may be obtained from groundwater wells or via pipeline from the old tree nursery irrigation ponds located on the Hoffstrom's Bay tributary on the Treasury offices site which has potential to reduce water quantity and, indirectly, habitat quality".

Corrections or Suggestions:

1. Confirm that the tree nursery ponds are located on the Unnamed Thunder Lake Tributary 2.

Reference Number: SD(1)-10
Source Reference #: MNRF-37
s.5 Effect/Valued Component/EA Item: Human Environment
Reference to EIS Guidelines: EIS Section 5.11, Table 5.11.1
Summary of Comment/Rationale: Thunder Bay has 2 post-secondary institutions that are not included in Table 5.11.1.

Corrections or Suggestions:

1. Consider including Lakehead University and Confederation College to the table.

Reference Number: SD(1)-11
Source Reference #: MNRF-62
s.5 Effect/Valued Component/EA Item: Species at Risk
Reference to EIS Guidelines: EIS Table 5.10.2
Summary of Comment/Rationale: There are several errors in Table 5.10.2 (EIS, pages 5-103 and 5-104). For example, under SARO, common nighthawk should be listed as special concern, barn swallow is threatened, and Canada warbler is special concern.
Corrections or Suggestions: It is recommended that these errors are corrected and that all species in the table are checked for accurate representation of how they are listed under SARA, COSEWIC, and SARO.

Reference Number: SD(1)-12
Source Reference #: DFO-09
s.5 Effect/Valued Component/EA Item: Fish Habitat
Reference to EIS Guidelines: EIS Section 12.4.2; Executive Summary; 12.4.2.12
Summary of Comment/Rationale: The EIS states that fish habitat compensation or habitat compensation will be provided as per the Fisheries Act authorization requirements. To be clear, the Fisheries Act amended in 2013 refers to habitat compensation now as offsetting. The Metal Mining Effluent Regulations were not amended and the compensation plan is referred to still as that. Though seemingly unimportant it can be confusing when the language is altered in other sections of the document.

Corrections or Suggestions:

1. No question.

Reference Number: SD(1)-13
Source Reference #: MNRF-23
s.5 Effect/Valued Component/EA Item: Project Description
Reference to EIS Guidelines: Appendix AA Section 1.2.3
Summary of Comment/Rationale: Section 1.2.3 Land Ownership indicates "a detailed summary of present claims and patents can be found in Appendix AA" however Appendix AA only provides a Claim list but no list of Patent properties. Appendix AA should also include list of Lease properties.

Corrections or Suggestions:

1. Add the list of Patent and Lease properties to Appendix AA.

Reference Number: SD(1)-14
Source Reference #: MNRF-27
s.5 Effect/Valued Component/EA Item: Human Environment
Reference to EIS Guidelines: Appendix E; Section 4.1; Figure 4
Summary of Comment/Rationale: Information in this section in the referenced figure is dated. The illustration is of the original mine site plan and does not include the new preferred processing plan location.

Corrections or Suggestions:

1. Replace the out of date figure with one that includes the preferred layout and orientation for the latest processing plan.

Reference Number: SD(1)-15
Source Reference #: MNRF-57
s.5 Effect/Valued Component/EA Item: Current Use of Lands and Resources for Traditional Purposes
Reference to EIS Guidelines: Appendix EE; Section 5.2.3
Summary of Comment/Rationale: "Regionally hunting and trapping can continue as per the limits imposed by the OMNRF. Current numbers for active hunters within the region are detailed in Table 5.5 and Table 5.6." Inaccuracy – OMNRF does not set limits for subsistence (Aboriginal treaty right country food) harvest. Table 5.5 and 5.6 includes information for the recreational hunt but subsistence hunting numbers could be quite different. The section on hunting and trapping is technical, could there be a reference to the appendix where the human health assessment is covered?

Corrections or Suggestions:

1. Revise wording.

Reference Number: SD(1)-16
Source Reference #: MNRF-58
s.5 Effect/Valued Component/EA Item: Human Environment
Reference to EIS Guidelines: Appendix EE Section 6
Summary of Comment/Rationale: The Tetra Tech human health assessment is referenced several times throughout Appendix EE but it is not listed in the references. It is unclear where that assessment/report is housed.

Corrections or Suggestions:

1. Include a clear reference to this document.

Reference Number: SD(1)-17
Source Reference #: HC-A16; HC-A17
s.5 Effect/Valued Component/EA Item: Noise
Reference to EIS Guidelines: Appendix H; Section 4.2.1
Summary of Comment/Rationale: Section 4.2.1 (Appendix H) refers to the "Guidance for Evaluating Human Health Impacts in Environmental Assessment: Noise (HC, 2011)". This DRAFT document is not supported by Health Canada (HC) and should not be cited. For current HC guidance on noise, refer to the "Useful Information for Environmental Assessments" publication: http://www.hc-sc.gc.ca/ewh-semt/pubs/eval/environ_assess-eval/index-eng.php Further, section 4.2.1.1 (Appendix H) states the noise sensitive receptor locations are identified using the Ministry of Environment and Climate Change (MOECC) definition of noise sensitive receptor and the locations for both the MOECC assessment and the HC assessment are the same. Given the DRAFT HC 2011 document is not supported by HC, it is appropriate to revise this section.

Corrections or Suggestions:

1. Revise Section 4.2.1 to reflect the appropriate guidance on noise.
2. Revise the statement in question and provide a reference for the appropriate MOECC document discussing receptor locations.
3. Include the definition used by MOECC to determine noise sensitive receptor locations in the EIS.

Reference Number: SD(1)-18
Source Reference #: HC-A16; HC-A17
s.5 Effect/Valued Component/EA Item: Noise
Reference to EIS Guidelines: Appendix H; Section 4.2.1
Summary of Comment/Rationale: Section 4.2.1 (Appendix H) refers to the "Guidance for Evaluating Human Health Impacts in Environmental Assessment: Noise (HC, 2011)". This DRAFT document is not supported by Health Canada (HC) and should not be cited. For current HC guidance on noise, refer to the "Useful Information for Environmental Assessments" publication: http://www.hc-sc.gc.ca/ewh-semt/pubs/eval/environ_assess-eval/index-eng.php Further, section 4.2.1.1 (Appendix H) states the noise sensitive receptor locations are identified using the Ministry of Environment and Climate Change (MOECC) definition of noise sensitive receptor and the locations for both the MOECC assessment and the HC assessment are the same. Given the DRAFT HC 2011 document is not supported by HC, it is appropriate to revise this section.

Corrections or Suggestions:

1. Revise Section 4.2.1 to reflect the appropriate guidance on noise.
2. Revise the statement in question and provide a reference for the appropriate MOECC document discussing receptor locations.
3. Include the definition used by MOECC to determine noise sensitive receptor locations in the EIS.

Reference Number: SD(1)-19
Source Reference #: HC-A20
s.5 Effect/Valued Component/EA Item: Noise
Reference to EIS Guidelines: Appendix H; Section 9
Summary of Comment/Rationale: The general statement of "a 3 dBA increase or decrease would be considered imperceptible to humans" is misleading. Humans may perceive and respond to changes in sound characteristics other than loudness (magnitude). Examples of these include frequency, sound modulation, impulsiveness and tonality.

Corrections or Suggestions:

1. Remove the statement regarding perception of sound as it is misleading.

Reference Number: SD(1)-20
Source Reference #: HC-B5
s.5 Effect/Valued Component/EA Item: Aboriginal Health and Socio-economic Conditions
Reference to EIS Guidelines: Appendix W; Table 3
Summary of Comment/Rationale: "MOE POI limits" of 50 µg/m³ for PM₁₀ and 27 µg/m³ for PM_2.5 are provided in Table 3. Note that the PM₁₀ standard is in fact an interim AAQC (MOE 2012b) and the PM_2.5 is a CAAQS (CCME 2012) - they are not MOE POI limits.

Corrections or Suggestions:

1. Provide correct references for the PM₁₀ and PM_2.5 air screening criteria.

Reference Number: SD(1)-21
Source Reference #: HC-B6
s.5 Effect/Valued Component/EA Item: Aboriginal Health and Socio-economic Conditions
Reference to EIS Guidelines: Appendix W Table 3
Summary of Comment/Rationale: Several analytes had no screening criteria identified (e.g., gold, bismuth, gallium, etc.) and were not retained in the HHRA with the following rationale provided: "No guideline, do not retain". While these specific substances would not normally be expected to be toxic when present at very low levels (based on low relative toxicity), the lack of guideline(s) is an inadequate rationale for their exclusion.

Corrections or Suggestions:

1. Expand the rationale for the substances without guidelines to further justify excluding them.

Reference Number: SD(1)-22
Source Reference #: HC-B2
s.5 Effect/Valued Component/EA Item: Aboriginal Health and Socio-economic Conditions
Reference to EIS Guidelines: Appendix W; Section 4.4.2
Summary of Comment/Rationale: The toxicological reference values (TRVs) provided for mercury and lead in Table M ("Human Health COC and Key Toxicological Effects") are indicated to be in units of "µg/kg-bw/day". However, the values provided in fact appear to be in mg/kg-bw/day.

Corrections or Suggestions:

1. Correct the units for the lead and mercury TRVs in Table M and in risk calculations.

Reference Number: SD(1)-23
Source Reference #: HC-B7
s.5 Effect/Valued Component/EA Item: Aboriginal Health and Socio-economic Conditions
Reference to EIS Guidelines: Appendix W; Table 5
Summary of Comment/Rationale: A CDWQG of 10 µg/L was provided for selenium, based on Health Canada (2012a). Note that the CDWQG for selenium was updated in 2014, and is now 50 µg/L (Health Canada 2014).

Corrections or Suggestions:

1. Update the selenium CDWQG to the current value.

Reference Number: SD(1)-24
Source Reference #: HC-B10
s.5 Effect/Valued Component/EA Item: Aboriginal Health and Socio-economic Conditions
Reference to EIS Guidelines: Appendix W; Sections6.4, 7.1
Summary of Comment/Rationale: Section 6.4 indicates that human health risk estimates were only generated for dust exposures from soil, and not for ingestion of food such as fish and wild game. Section 7.1 indicates that only dust exposures were quantitatively considered for the HHRA (Operational phase) and no risk estimates were generated for the Post-Closure phase. However, risk estimates for country food for lead and mercury (for both phases of the project) were presented in section 4.5.8 "Risk Estimate Results". These differences create uncertainties in how the exposure routes were actually incorporated into the country foods risk estimates.

Corrections or Suggestions:

1. Update sections 6.4 and 7.1 to reflect that risk estimates were generated for the country foods assessment (including the post-closure phase).

IR-1 Annex A3

Annex A3 - Comments on the April 2015 Environmental Impact Statement for the Goliath Gold Project from Aboriginal Communities and Groups

Table 1 includes a summary of comments received from Aboriginal People of Wabigoon, Eagle Lake First Nation, Grassy Narrows First Nation, Métis Nation of Ontario, Naotkamegwanning First Nation, Wabauskang First Nation, Wabigoon Lake Ojibway Nation, and Grand Council of Treaty # 3 during:

• meetings held before the submission of the environmental impact statement (EIS);
• emails, phone calls, and letters received by the Canadian Environmental Assessment Agency (the Agency) pre-EIS submission;
• emails, phone calls, and letters received by the Agency during the EIS review; and
• meetings held during the comment period on the EIS.

Note that no comments have been received from Lac Seul First Nation. Additional written submissions received by the Agency during the EIS review from Eagle Lake First Nation, Métis Nation of Ontario, and Naotkamegwanning First Nation are included in Tables 2, 3, 4 and 5, as follows:

• Table 2 – Agency Disposition of Written Comments Submitted by the Métis Nation of Ontario (MNO) on the Environmental Impact Statement (Report prepared by Calliou Group);
• Table 3 - Agency Disposition of Written Comments Submitted by Eagle Lake First Nation on the Environmental Impact Statement (Report prepared by ICA Associates Inc.);
• Table 4 – Agency Disposition of Written Comments Submitted by Eagle Lake First Nation on the Environmental Impact Statement (Report by Maclean Environmental Consulting); and
• Table 5 - Agency Disposition of Written Comments Submitted by Naotkamegwanning First Nation on the Environmental Impact Statement.

Table 1 - Summary of Comments Received from Aboriginal Groups

Fish and Fish Habitat

IR-1 Reference #: AC(1)-04
Community /Group:
Eagle Lake First Nation
Naotkamegwanning First Nation
Wabauskang First Nation
Wabigoon Lake Ojibway Nation
Summary of Comment: Shared information about baseline fish and fish habitat conditions:

• Thunder Lake is cold water trout habitat;
• fish spawning area around Christie Island. Two waterways drain into this fish spawning area;
• minnows and shiners can be found in almost every creek;
• baitfish have been found in the irrigation ponds, other ponds in the area, and along creeks;  
• suckers have also been found on the site;
• Thunder Lake is clear and spring water fed, and flows into Wabigoon Lake. The water flows through the water bodies in the region in a counterclockwise direction;
• spawning areas in Thunder Creek and Nugget Creek (walleye), Blackwater Creek (sucker), and along the shoreline of Wabigoon Lake (northern pike); and
• Blackwater Creek has one main bed that branches off into at least 10 other creeks, then into bogs.

Identified baseline conditions are not adequately described in the EIS. More detailed mapping of potentially affected habitat is needed, including a scaled figure delineating the potentially affected watershed. The EIS is missing fishing areas in Wabigoon Lake and within the project area. Requested that mitigation measures for prevention of contamination of water bodies and impacts on fish and fish habitat be described.
Link to Annex A1: FH(1)-06
FH(1)-10

IR-1 Reference #: AC(1)-05
Community /Group: Eagle Lake First Nation
Summary of Comment: Asked questions about what impacts to fish in Wabigoon and Thunder Lake will be. Concerned about the relocation of fish from waterbodies within the project area.
Link to Annex A1: FH(1)-13
FH(1)-17
FH(1)-19

IR-1 Reference #: AC(1)-06
Community /Group: Wabauskang First Nation
Summary of Comment: Concerns with adequacy of potential impacts and mitigation measures to fish and fish habitat identified by the proponent.
Link to Annex A1: FH(1)-06

IR-1 Reference #: AC(1)-07
Community /Group: Wabigoon Lake Ojibway Nation
Summary of Comment: Identified potential water quantity impacts to Lola Lake wetlands from the Project. The wetlands drain down into irrigation ponds on Treasury Metals Inc. (TMI) property that will supply water for the Project. Asked for clarification if TMI will also use the irrigation pond in the north of the site as a water source.
Link to Annex A1: GW(1)-21

IR-1 Reference #: AC(1)-08
Community /Group: Wabigoon Lake Ojibway Nation
Summary of Comment: Identified beavers frequently dam Blackwater Creek, and asked how TMI will manage the issue of flow restriction due to beaver ponds located along the creek (i.e., how will beavers be managed).
Link to Annex A1: EE(1)-07

IR-1 Reference #: AC(1)-09
Community /Group: Wabigoon Lake Ojibway Nation
Summary of Comment: Identified that water from water processing plant may not be safe for fish. Asked how water will be re-mineralized after the reverse osmosis treatment process to support aquatic life.
Link to Annex A1: SW(1)-18

Migratory Birds

IR-1 Reference #: AC(1)-10
Community /Group:
Eagle Lake First Nation
Wabigoon Lake Ojibway Nation
Naotkamegwanning First Nation
Summary of Comment: Shared information about baseline migratory bird and bird habitat conditions, including:

• owls (barn and long horn), wild turkeys and robins observed in the project area;
• project area is a fly through area for migratory birds that may be impacted by the Project;
• migratory bird nesting area located to the north of the site; and
• blueberry areas attract robins and other birds.
  Link to Annex A1: EA(1)-01

IR-1 Reference #: AC(1)-11
Community /Group: Naotkamegwanning First Nation
Wabigoon Lake Ojibway Nation
Summary of Comment: It is impossible to monitor the movement of birds and material. Raised concern that if birds access tailings it will be difficult to monitor effects.
Link to Annex A1: WL(1)-05

Human Health and Socio-economic Conditions

IR-1 Reference #: AC(1)-12
Community /Group: Eagle Lake First Nation**
Summary of Comment: Comments and questions about potential human health effects from air quality impacts from the Project, including:

• what will be in air emissions from the site, including smoke;
• will toxins, including fungus (e.g., blastomycosis dermatitis), be released into the air as soil and rocks are extracted from the open pit;
• concerns about increased lung disorders and cancer rates; and
• what will be done to mitigate impacts and protect air quality for current and future generations.

Link to Annex A1:
AE(1)-01
AE(1)-08

IR-1 Reference #: AC(1)-13
Community /Group: Wabigoon Lake Ojibway Nation
Summary of Comment: Concerned about close proximity of mine to residents, including community members. Community member owns private lands adjacent to open pit and waste rock. Asked if there are exceptions to the provincial air quality requirements that would allow exceedances that could affect nearby residents. Identified potential winter dust impacts on nearby residents, and asked how impacts will be mitigated, particularly with northwest wind in the Village of Wabigoon.
Link to Annex A1:
HE(1)-36
AE(1)-13

IR-1 Reference #: AC(1)-14
Community /Group: Wabigoon Lake Ojibway Nation
Aboriginal People of Wabigoon
Summary of Comment: Provided comments about potential effects to groundwater quantity and the information presented in the EIS:

• concerns with data in the EIS, including gaps in seasonal flow measurements in Thunder Creek;
• ground and surface water interactions in Blackwater Creek, may result in contamination of groundwater from effluent discharge;
• Identified private and artesian wells located in the vicinity of the Project that are not identified in the EIS.
• Asked how TMI will manage additional water if artesian wells are hit during drilling, as pit will overflow if water is not managed
• Asked if TMI can identify the depth at which the artesian wells flow;
• Shared that community member's artesian well runs at 55g/min. The water comes out at 47 degrees.

Link to Annex A1:
GW(1)-03
GW(1)-15
SW(1)-09

IR-1 Reference #: AC(1)-15
Community /Group: Eagle Lake First Nation
Wabigoon Lake Ojibway Nation
Summary of Comment: Identified concerns about potential impacts to water level in local wells and the information provided in the EIS:

• water table is high near Wabigoon, and therefore have concerns about watershed impacts to community and to nearby lakes due to dewatering of the open pit;
• mitigation measures for impacts to wells are not adequate;
• asked how community members will get their water back if wells are drained by the Project during operation or post-closure period; and
• asked if TMI has dug new wells on site and if they have been monitoring the wells. ,
  Link to Annex A1: GW(1)-15

IR-1 Reference #: AC(1)-16
Community /Group: Eagle Lake First Nation
Summary of Comment: Asked how the water will be treated and discharged, the amount of cyanide that will be used, the contaminants and transportation methods for cyanide.
Link to Annex A1: SW(1)-23

IR-1 Reference #: AC(1)-17
Community /Group: Eagle Lake First Nation
Wabigoon Lake Ojibway Nation
Summary of Comment: EIS shows there will be mercury in the seepage and discharge from the mine. Concerns about mercury contamination and potential impacts to Grassy Narrows First Nation.
Link to Annex A1: SW(1)-22

IR-1 Reference #: AC(1)-18
Community /Group: Eagle Lake First Nation
Wabigoon Lake Ojibway Nation
Summary of Comment: Identified concerns that lakes and wells will be contaminated, and asked questions about how tailings and water will be managed at the site, including:

• Limited consideration of groundwater flow in TSF design;
• What will the tailings storage facility be lined with;
• How long the water will be retained in the tailings storage facility;
• The amount of water that will be used at the mine site;
• The amount of discharge into the tailings storage facility; and
• The source(s) of the water supply.

Can water quality be guaranteed following closure of the mine? Identify the measures to be taken to control water quality impacts to the local watersheds.
Link to Annex A1: SW(1)-26

IR-1 Reference #: AC(1)-19
Community /Group: Wabigoon Lake Ojibway Nation
Eagle Lake First Nation
Summary of Comment: Concerns of acid generating potential and over flow of pit during closure. No detailed analysis of open pit water contamination, overflow potential and containment of potential acid generating material. Impacts to groundwater and contamination are a concern.
Link to Annex A1:
FH(1)-13
SW(1)-17

IR-1 Reference #: AC(1)-20
Community /Group: Eagle Lake First Nation
Summary of Comment: Describe the protocols to be followed to secure and verify proper sampling, analysis, and reporting are done. Indicate any opportunities to involve First Nations as monitors in the monitoring program as well as clarify who will be responsible for monitoring tailing ponds for the next 100 years.
Link to Annex A1:
EA(1)-06
HE(1)-46

IR-1 Reference #: AC(1)-21
Community /Group: Eagle Lake First Nation
Wabigoon Lake Ojibway Nation
Summary of Comment: Potential contamination of food sources (e.g., fish, moose, deer, wild rice, rabbit) from effluent discharge.
Link to Annex A1: HE(1)-01
HE(1)-05

IR-1 Reference #: AC(1)-22
Community /Group: Wabigoon Lake Ojibway Nation
Summary of Comment: Identified potential impacts to community economic conditions including:

• Potential impacts to tourism, including businesses offering temporary accommodation, guiding, fishing, and hunting outposts. Some local businesses are owned by community members, and many community members guide for hunting and fishing;
• Potential impacts to wild rice. Identified wild rice is important for community economic development and that wild rice grows in Thunder Creek and Blackwater Creek;
• Potential impacts to chanterelles. Chanterelles are located throughout the area and have high economic value.

Also asked TMI to describe the socio-economic benefits to the community from the Project.
Link to Annex A1:
HE(1)-33
HE(1)-35

IR-1 Reference #: AC(1)-23
Community /Group: Naotkamegwanning First Nation
Summary of Comment: Identified potential impacts to water quality, and perception of contamination may affect sales from commercial fishing licenses in Thunder Lake, Butler Lake, Wabigoon Lake and other lakes in the area (approximately 23 licenses in total). The economic development from these fisheries is important to the community.
Link to Annex A1:
HE(1)-33
HE(1)-35

IR-1 Reference #: AC(1)-24
Community /Group: Eagle Lake First Nation
Summary of Comment: Identified that Lola Lake is in close proximity to the Project and asked how the park may be impacted.
Link to Annex A1:
AA(1)-08,
HE(1)-35
HE(1)-45
FH(1)-11
WL(1)-03
GW(1)-21
SW(1)-25

IR-1 Reference #: AC(1)-25
Community /Group: Wabigoon Lake Ojibway Nation
Summary of Comment: Identified that Butler Park (across Wabigoon Lake) is nearby and asked if potential impacts to the park had been evaluated.
Link to Annex A1:
HE(1)-35
HE(1)-45

IR-1 Reference #: AC(1)-26
Community /Group: Wabigoon Lake Ojibway Nation
Summary of Comment: Identified concerns regarding the scope of the effects assessment for potential effects to Aboriginal peoples is limited to arrowheads, subsistence land uses, and impacts on reserve only. Population of Village of Wabigoon is 75% Aboriginal peoples.
Link to Annex A1:
HE(1)-33

Physical and Cultural Heritage, and Structures, Sites, or Things of Archaeological, Architectural, Historical or Paleontological Significance

IR-1 Reference #: AC(1)-27
Community /Group: Naotkamegwanning First Nation
Summary of Comment: Identified sacred aspects of the environment in the Project area, including turtles, frogs, rocks and boulders, and that there are sacred sites south of Wabigoon. The community has a strong connection to the land, and the community cannot relocate if there are impacts from the Project to the environment.
Link to Annex A1:
HE(1)-47

IR-1 Reference #: AC(1)-28
Community /Group: Wabigoon Lake Ojibway Nation
Summary of Comment: Identified sites of physical and cultural heritage value that may be affected by the Project, and provided comments on the assessment provided in the EIS:

• assessment should consider both reserve and non-reserve lands and not focus solely on archaeological artifacts and sites;
• Thunder Lake was used as a traditional canoe route to Rice Lake. Elders camped throughout on the sandy beaches. Travel routes identified from Wabigoon to Thunder Lake to Ghost Lake to Rice Lake to gather wild rice;  
• ceremonial sites in the area are not identified in the EIS, including stone circles found on residential properties around the project site;
• view of Thunder Lake has cultural importance to the elders;
• Wabigoon Lake is the biggest wild rice area in Canada and is used as a spiritual and teaching area; and
• Spiritual values should be considered its own human environment component - just as important to elders as water.

Link to Annex A1:
HE(1)-47

IR-1 Reference #: AC(1)-29
Community /Group: Wabigoon Lake Ojibway Nation
Summary of Comment: Identified potential archaeological sites in the vicinity of the Project, and provided comments on the assessment provided in the EIS:

• Archaeological sites in Thunder Lake and Wabigoon Lake could be underwater. Spring fed ponds has been identified near ceremonial sites on community member's property which is in close proximity to the site; 
• Inaccuracies/contradictions in archaeology section of EIS. Thunder Lake is identified as historical hunting/fishing area, but the EIS then states that First Nations were never in the area;
• EIS also identifies no cultural resources were found in Aaron Park – this is inaccurate;
• Two grave sites in project site. Letters were written to TMI identifying sites in 2008;
• Concern about how archaeological resources will be managed. Elders say archeological sites and objects should stay where they are; and
• Burial ground and fishing camp have been identified on Christie Island.

Link to Annex A1:
HE(1)-47
HE(1)-48

Current Use of Lands and Resources

IR-1 Reference #: AC(1)-30
Community /Group: Wabigoon Lake Ojibway Nation
Summary of Comment: Treaty 3 is quoted and interpreted in EIS Appendix DD section 2.1. Treaty interpretation should not be part of EIS.
Link to Annex A1: HE(1)-38

IR-1 Reference #: AC(1)-31
Community /Group: Eagle Lake First Nation
Summary of Comment: The Great Earth Law is very important. Connections between every aspect of the environment must be recognized. Describe what will be done to mitigate impacts and protect the environment for current and future generations and wildlife. Anishawbe people want to protect environment, especially water, for future generations. The preservation of land is a key concern over economic benefits of the Project.
Link to Annex A1: HE(1)-43

IR-1 Reference #: AC(1)-32
Community /Group: Eagle Lake First Nation
Wabigoon Lake Ojibway Nation
Naotkamegwanning First Nation
Summary of Comment: Shared information about wildlife baseline conditions:

• characterized soils as sandy northeast of Thunder Lake, including the proposed location for the tailings storage facility;
• blueberries grow in sand areas and are known to move, the entire area should be identified as blueberry habitat;
• denning habitat for fox in the area of the proposed tailings storage facility;
• project area includes bear denning habitat. Dens have been identified along first gate to the tree nursery, property line to tree nursery, and the proposed tailings storage facility location; and
• moose population near Blackwater Creek and up the site.

Link to Annex A1: HE(1)-45

IR-1 Reference #: AC(1)-33
Community /Group: Eagle Lake First Nation
Wabigoon Lake Ojibway Nation
Summary of Comment: Identified potential impacts to wildlife in the area and asked how impacts would be mitigated, including impacts to:

• moose and moose habitat;
• furbearers (e.g., beaver and muskrat);
• water animals; and
• other wildlife (i.e. chipmunks, mice, and squirrels).

Identified that wildlife have large ranges so impacts will not be confined to project site, in particular if wildlife is exposed to tailings. Asked if the pit and tailings storage facility will be fenced in to prevent access by animals.
Link to Annex A1:
EA(1)-02
EA(1)-08
AE(1)-30
WL(1)-05
HE(1)-45

IR-1 Reference #: AC(1)-34
Community /Group: Wabigoon Lake Ojibway Nation
Summary of Comment: Historically, and while the tree nursery was in operation, the community used to have open access to the site for land use. During the tree nursery operation access to hunting trails and the rest of the site was available 5 days a week. Identified community members' access to lands and resources has been affected by the Project in recent years, and also identified additional impacts that may occur, including:

• hunting trails and roads throughout the project area (currently not included in the EIS);
• Project may restrict access to Thunder Lake and areas north of the proposed tailings storage facility;
• plant harvesting, including blueberries, stump mushrooms, chanterelles, medicinal plants and other berries. Low bush cranberries, snowbush berry, Labrador Tea, low bush hemlock/ ground hemlock are known medicines in the area.
• peat resources in the area are used by the community;
• baitfishing;
• hunting;
• cutting wood for subsistence and economic purposes; and
• trapping (Aboriginal community members from Eagle Lake First Nation and Wabigoon Lake Ojibway Nation hold the trapline licenses for the three trapline areas which are directly affected by the Project).

Link to Annex A1:
HE(1)-45
HE(1)-44
HE(1)-43
HE(1)-38

IR-1 Reference #: AC(1)-35
Community /Group: Wabigoon Lake Ojibway Nation
Summary of Comment: Wabigoon Lake is the biggest wild rice area in Canada and is used as a spiritual and teaching area. Concerns about effluent flowing into Wabigoon Lake through Blackwater Creek. Wild rice is important to lifestyle and culture. Concerns about the impacts to health and quality of life due to taking away food source.
Link to Annex A1:
HE(1)-01
HE(1)-38
HE(1)-45
HE(1)-47

IR-1 Reference #: AC(1)-36
Community /Group: Eagle Lake First Nation
Summary of Comment: Elder identified he picks blueberries at the area where the tailings storage facility will be located. Identified Aboriginal land use in Wabigoon and Thunder Lakes includes fishing (two commercial licenses), as well as wild rice harvesting. The EIS does not include any information about impacts on Rice, Sandy, Gardner, Mud and Turtle Lake, which are also used by Aboriginal peoples.
Link to Annex A1:
HE(1)-35
HE(1)-45

IR-1 Reference #: AC(1)-37
Community /Group: Wabauskang First Nation
Summary of Comment: Identified gaps in understanding of current use of lands and resources for traditional purposes and the need for a traditional land use study. There is hunting in the area (e.g., moose, rabbit, and partridge). Concerns with adequacy of potential impacts and mitigation measures to Aboriginal peoples identified by the proponent.
Link to Annex A1: HE(1)-38

IR-1 Reference #: AC(1)-38
Community /Group: Wabauskang First Nation
Aboriginal People of Wabigoon
Summary of Comment: The proposed Project will infringe upon Aboriginal and Treaty Rights.
Link to Annex A1: HE(1)-38
HE(1)-43

IR-1 Reference #: AC(1)-39
Community /Group: Aboriginal People of Wabigoon
Summary of Comment: Community's traditional trapping, fishing, hunting, berry and medicinal plant collecting, timber harvesting, and potential land claims are being impacted. Mitigation measures must be identified to protect or remunerate for potential damaging effects.
Link to Annex A1: HE(1)-38
HE(1)-43

IR-1 Reference #: AC(1)-40
Community /Group: Grassy Narrows First Nation
Summary of Comment: Since time immemorial, we have occupied, used, and possessed land waters in the vicinity of the Project. Because this Project stands to impact our First Nation, our direct participation in the development and assessment of any mitigation measures, monitoring programs, or compensation plans is essential before this Project can be permitted to proceed.
Link to Annex A1: AC(1)-01
HE(1)-38
HE(1)-43

IR-1 Reference #: AC(1)-41
Community /Group: Grand Council Treaty # 3
Grassy Narrows First Nation
Eagle Lake First Nation
Métis Nation of Ontario Naotkamegwanning First Nation Wabigoon Lake Ojibway Nation
Wabauskang First Nation
Summary of Comment: Identified the need for a traditional knowledge/ traditional land use study to understand potential impacts to community members. Request for funding for comprehensive traditional knowledge and land use studies in project area directed to groups/communities likely to be impacted by the Project.
Link to Annex A1: EA(1)-01
Ac(1)-01
HE(1)-38

IR-1 Reference #: AC(1)-42
Community /Group: Naotkamegwanning First Nation
Summary of Comment: Identified that the Dryden area is part of the community's traditional hunting (e.g., moose and deer), trapping and fishing area. The community holds traditional ecological knowledge for the area, but need elder approval to share this knowledge as part of the EA.
Link to Annex A1: HE(1)-38
EA(1)-01

IR-1 Reference #: AC(1)-43
Community /Group: Eagle Lake First Nation
Naotkamegwanning First Nation
Wabigoon Lake Ojibway Nation
Summary of Comment: With respect to the decommissioning and abandonment phases of the project site, describe how the site will compare to pre-treaty conditions (i.e. state of pit), plans for abandoning site and possible land access and uses during the abandonment phase.
Link to Annex A1: HE(1)-43
Accidents and Malfunctions

IR-1 Reference #: AC(1)-44
Community /Group: Métis Nation of Ontario
Eagle Lake First Nation
Wabigoon Lake Ojibway Nation
Naotkamegwanning First Nation
Summary of Comment: Concerned about potential for tailings spill (like Mount Polley). Concerns that the tailing dam may be weak, and that there may be seepage into Wabigoon Lake. Request that TMI demonstrate that funds are being used to ensure the efficacy and safety of design, and describe the safeguards proposed to protect against a tailings breach, including justification that a twenty metre dam will be able to retain the volume of water.

In the event of a spill, would communities will be compensated as individuals or as whole? Clarify if TMI's insurance covers accidents similar to Mount Polley. Describe the mitigation measures that will be put in place to reduce potential impacts on fish and fish habitat in the event of an accident. Outline the provisions to demonstrate there will be sufficient funds for an emergency and unanticipated clean up. Provide the contingency and response plans that will apply, including the evacuation plan details, such as:

• response times;
• monitoring and impacts;
• details on how the broader community will be informed; and
• plans for transportation and the housing of people.

Identified that the railway passage over Wabigoon Lake is very low and could easily be washed out if there was an influx of water.
Link to Annex A1: AM(1)-04

IR-1 Reference #: AC(1)-45
Community /Group: Eagle Lake First Nation
Summary of Comment: Clarify who runs the models of risk assessment.

IR-1 Reference #: AC(1)-46
Community /Group: Eagle Lake First Nation
Summary of Comment: Describe the safeguards and the response plans in the event of water contamination during the transport and handling of cyanide.
Link to Annex A1: AM(1)-01

Cumulative Effects

IR-1 Reference #: AC(1)-47
Community /Group: Eagle Lake First Nation
Summary of Comment: Concerns about cumulative impacts to human health (i.e. cancer, asthma, lung disorder and stillborn babies). Examples include E.coli in Thunder Lake and increased cancer rates near the mill.
Link to Annex A1: CE(1)-07

IR-1 Reference #: AC(1)-48
Community /Group: Wabigoon Lake Ojibway Nation
Summary of Comment: Identified that contaminants in sport fish (e.g., walleye) in Wabigoon Lake are high already. Concerned about cumulative effects to wildlife and people if additional contaminants are put into the watershed.
Link to Annex A1: CE(1)-05

IR-1 Reference #: AC(1)-49
Community /Group: Wabigoon Lake Ojibway Nation
Summary of Comment: Potential cumulative effects on wildlife (moose), and the community from forestry and mining in the region. Moose populations have dropped because of forestry and mining.
Link to Annex A1: CE(1)-02

Evaluation of Alternatives

IR-1 Reference #: AC(1)-50
Community /Group: Eagle Lake First Nation
Summary of Comment: Concerns about location of waste rock site.
Link to Annex A1: AA(1)-07

IR-1 Reference #: AC(1)-51
Community /Group: Wabigoon Lake Ojibway Nation
Summary of Comment: Comments and questions about the design of the tailings storage facility, including:

• Clarify if the community is able to influence the engineering of the tailings storage facility. There is seepage with the proposed design. Identify if the tailings area can be lined;
• Clarify if the tailing storage facility has to be on private land. Community member lives right next to tailings pond; and
• Concerns about tailings storage and why dry stack storage is not considered. Feel that the choices being made are economically cheapest.

Link to Annex A1: AA(1)-01

IR-1 Reference #: AC(1)-52
Community /Group: Eagle Lake First Nation
Summary of Comment: Clarify if an open pit or a shaft is safer. State if the use of an open pit is favored by all.

Effects of the Environment on Project

IR-1 Reference #: AC(1)-53
Community /Group: Eagle Lake First Nation
Summary of Comment: Identify the impacts to the mine in the event of a tornado.
Link to Annex A1: EE(1)-04
Project Description

IR-1 Reference #: AC(1)-54
Community /Group: Wabigoon Lake Ojibway Nation
Summary of Comment: There are inconsistencies in distances describing the project location in the EIS.

IR-1 Reference #: AC(1)-55
Community /Group: Wabigoon Lake Ojibway Nation
Summary of Comment: State the height of the tailings dam.

IR-1 Reference #: AC(1)-56
Community /Group: Wabigoon Lake Ojibway Nation
Summary of Comment: State the capacity of the mill facility, minimum threshold per day and the depth of the underground pit.

IR-1 Reference #: AC(1)-57
Community /Group: Eagle Lake First Nation
Summary of Comment: How much water will be used over time?

IR-1 Reference #: AC(1)-58
Community /Group: Eagle Lake First Nation
Summary of Comment: Asked what safety standards are being met by the Project (i.e., ISO #?).

Aboriginal Consultation

IR-1 Reference #: AC(1)-60
Community /Group: Eagle Lake First Nation
Summary of Comment: Request opportunity to tour the project site.

IR-1 Reference #: AC(1)-61
Community /Group: Grand Council Treaty # 3
Grassy Narrows First Nation
Eagle Lake First Nation
Naotkamegwanning First Nation Wabigoon Lake Ojibway Nation
Wabauskang First Nation
Summary of Comment: Request sufficient time to: (I) adequately review the Environmental Impact Statement; (2) complete traditional knowledge and traditional land use studies; and (3) determine how the Project will impact Aboriginal and Treaty rights to identify mitigation to these impacts.
Link to Annex A1: EA(1)-01
AC(1)-01

IR-1 Reference #: AC(1)-62
Community /Group: Grand Council Treaty # 3
Grassy Narrows First Nation
Eagle Lake First Nation
Métis Nation of Ontario
Wabigoon Lake Ojibway Nation
Wabauskang First Nation Naotkamegwanning First Nation
Summary of Comment: Concerns with level of consultation completed by proponent, including absence of consultation on the following topics:

• valued components;
• baseline studies;
• traditional knowledge and traditional land use;
• potential impacts to Aboriginal and Treaty rights;
• potential environmental effects;
• mitigation measures; and
• monitoring program.

Link to Annex A1: AC(1)-01

IR-1 Reference #: AC(1)-63
Community /Group: Métis Nation of Ontario
Summary of Comment: Identified requirements of EIS Guidelines were not met, including deficiencies in the following areas:

• early Aboriginal engagement to identify potential impacts to potential or established Aboriginal and Treaty rights and related interests;
• opportunity for Aboriginal groups to participate in or influence the results of the baseline studies;
• opportunity to review draft VCs, to comment on the VCs, or to contribute to the selection of VCs;
• discussion of why specific VCs were included/excluded in the EIS;
• Information on the establishment of assessment boundaries for each VC (spatial, temporal, technical and administrative);
• Information on the scope of the assessment, including potential effects, measurable parameters and a significance threshold, traditional knowledge and traditional use information, and information on the influence of consultation on the assessment;
• overall lack of Aboriginal traditional knowledge;
• effects assessment methodology; including definition of temporal and spatial boundaries, description of analytical methods, assumptions and conservative approach;
• sufficient description of potential effects, potential mitigation, characterization and determination of significance of residual effects of residual effects (not completed with scientific rigor), and details of confidence and risk; and
• Outline of follow-up monitoring.

Sufficient information is needed to understand the entire project, potential impacts, mitigation measures, residual effects and significance conclusions. Cannot proceed with a collaborative consultation process until significant and systematic failings within the EIS are addressed. If this is not done, any future consultation will ultimately be meaningless and superficial because of the underlying deficiencies within the EIS.
Link to Annex A1: EA(1)-01
EA(1)-02
EA(1)-03
EA(1)-04
EA(1)-05
EA(1)-06
EA(1)-07
EA(1)-08
EA(1)-09
AC(1)-01

IR-1 Reference #: AC(1)-64
Community /Group: Eagle Lake First Nation
Summary of Comment: No current Traditional Environmental Knowledge incorporated in the report or within the valued components
Link to Annex A1: EA(1)-01

IR-1 Reference #: AC(1)-65
Community /Group: Eagle Lake First Nation
Grand Council Treaty # 3
Grassy Narrows First Nation
Métis Nation of Ontario Naotkamegwanning First Nation
Wabauskang First Nation
Wabigoon Lake Ojibway Nation
Summary of Comment: Lack of funding from the proponent for technical review, consultation, collection of traditional knowledge and traditional land use information. Request funding for capacity and resources to complete traditional knowledge and land use studies and provide adequate technical review of EIS, including proposed mitigation measures.
IR-1 Reference #: AC(1)-66
Community /Group: Grassy Narrows First Nation
Summary of Comment: An appropriate consultation process is required to enable our First Nation's participation and to provide:

1. A fair opportunity analyze and examine the impacts associated with Treasury Metals' planned planned projects and activities;
2. Real participation in the development of appropriate mitigation strategies;
3. A respectful means of engaging in internal consultation with band members;
4. Equitable terms that ensures First Nation support for the project and the sharing benefits and business opportunities; and
5. A coordinated and on-going forum to ensure meaningful input the planned projects and activities that will impact our lands, waters, members, resources, and rights

Link to Annex A1: AC(1)-01

IR-1 Reference #: AC(1)-67
Community /Group: Eagle Lake First Nation
Summary of Comment: The community's concerns have yet to be fully addressed and at this point there is no consent for the project by the community.
Link to Annex A1: AC(1)-01

IR-1 Reference #: AC(1)-68
Community /Group: Wabigoon Lake Ojibway Nation
Summary of Comment: Concerns identified regarding adequacy and documentation of proponent-led Aboriginal consultation. Identified that the community has not received responses to questions that have been asked. For example, asked TMI for clarification on impacts to water on March 28, 2013 and did not receive a response. Identified the need for cultural sensitivity training. Also identified consistency and factual errors throughout the EIS and are concerned the documents are leading people to believe the Project has been approved.
Link to Annex A1: AC(1)-01
EA(1)-01

IR-1 Reference #: AC(1)-69
Community /Group: Grassy Narrows First Nation
Summary of Comment: Concerns regarding documentation of engagement in the EIS. Identified that there has been no engagement with the community to date, and that the assumptions in the EIS, including the generalizations and assumptions regarding rights, habitat and histories of Treaty 3 First Nations, lack foundation. Assertions in EIS that the project will only occupy 55 hectares of the 142,450 square kilometers of Treaty 3 lands are demonstrative of the lack of meaningful engagement with First Nations.
Link to Annex A1: AC(1)-01
HE(1)-38
HE(1)-43

IR-1 Reference #: AC(1)-70
Community /Group: Eagle Lake First Nation
Grand Council Treaty # 3
Summary of Comment: Identified that TMI should engage the Grand Council of Treaty 3 to identify potentially affected communities, as per the process defined in Manito Aki Inakonigaawin. The objectives of engagement under Manito Aki lnakonigaawin are to:

1. Understand potential effects of the Project on the environment in Treaty #3 territory; and
2. Understand potential effects of the Project on our treaty and aboriginal rights and interests;
3. Determine whether the Anishinaabe Nation will provide its consent to the Project and, if so, the conditions of such authorization; and
4. If authorization is granted, to provide a basis for negotiating agreements between Treasury Metals and the Anishinaabe Nation to establish a mutually beneficial relationship.

Link to Annex A1: EA(1)-01

IR-1 Reference #: AC(1)-71
Community /Group: Wabauskang First Nation
Summary of Comment: Consultation and Accommodation Protocol has been provided to the proponent, and should be followed. Do not have the capacity to engage with the proponent nor has there been any agreement on an engagement process. The proposed Project will infringe upon Aboriginal and Treaty rights.
Link to Annex A1: EA(1)-01
AC(1)-01
Other Comments

IR-1 Reference #: AC(1)-72
Community /Group: Eagle Lake First Nation
Summary of Comment: Why are the First Nations not involved in the Mining Act development process?

IR-1 Reference #: AC(1)-73
Community /Group: Eagle Lake First Nation
Wabigoon Lake Ojibway Nation
Summary of Comment: No detailed closure plan available for review or any financial assurance for perpetual care of the site. Provide draft closure plan to communities for review before the final is submitted to the Ministry of Northern Development and Mines.

IR-1 Reference #: AC(1)-74
Community /Group: Eagle Lake First Nation
Wabigoon Lake Ojibway Nation

Summary of Comment: Concerns about funding for rehabilitation and mine closure such as clean-up costs/rehabilitation costs. What happens to the area after the mine ceases to operate is important to the community. The following concerns need to be addressed:

• clarify if clean-up costs are calculated at today's prices;
• identify what will happen when funds run out; and
• Identify impacts to community after mine closure.

IR-1 Reference #: AC(1)-75
Community /Group: Eagle Lake First Nation
Summary of Comment: Improvements to MMER regulations are proposed. What will be done to meet these new regulations in two years?

IR-1 Reference #: AC(1)-76
Community /Group: Wabigoon Lake Ojibway Nation
Summary of Comment: TMI drained beaver ponds when drilling and blasting.

IR-1 Reference #: AC(1)-77
Community /Group: Wabigoon Lake Ojibway Nation
Summary of Comment: Heard from a worker that a ceremonial site was found on the site and disturbed by TMI.

IR-1 Reference #: AC(1)-78
Community /Group: Eagle Lake First Nation
Community /Group: Wabigoon Lake Ojibway Nation
Summary of Comment: Weak financial profile of the company at 38 cents a share (TSX), market capitalization of 29 million and less than 145 million net profit is expected. There are concerns with economics of the Project. Revenue proposed by the Project ($144 Million) would not cover a disaster.

IR-1 Reference #: AC(1)-79
Community /Group: Eagle Lake First Nation
Wabigoon Lake Ojibway Nation
Summary of Comment: Concerns about cover-ups to make financial gains. Worried about honesty of company.

IR-1 Reference #: AC(1)-80
Community /Group: Wabigoon Lake Ojibway Nation
Summary of Comment: Identified a potential conflict of interest as the VP of TMI is also a councillor for the City of Dryden. The City of Dryden and MNRF jointly manage Arron Park, which may be affected by the Project.

IR-1 Reference #: AC(1)-81
Community /Group: Wabigoon Lake Ojibway Nation
Summary of Comment: Does the proponent plan to expand the project (i.e., expand the pit physically, or increase ore production) or accept ore from other mines for processing at the mill?

Table 2 – Agency Disposition of Written Comments Submitted by the Métis Nation of Ontario (MNO) on the Environmental Impact Statement (Report prepared by Calliou Group)

IR-1 Reference #: AC(1)-82
MNO#: 1, 47

Aboriginal Consultation for the Project

EA Section or other technical document: Environmental Impact Statement Executive Summary
Section 2.0 Participants in Environmental Assessment
Section 9.0 Aboriginal Engagement
Section 9.1 Potential Effects on Water Resources, Water Quality and Water Bodies
9.2 Effects on Fishing
9.3 Potential Effects on Hunting and Trapping
EIS, Section 2.2.1.2 Alternatives Assessment Approach
Comment: The executive summary does not include a disaggregated listing of participants in the environmental assessment.
Section 9.0, 9.1, 9.2, 9.3 of the EIS Summary outlines information in an aggregated format. MNO requires disaggregated information in order to adequately assess whether MNO involvement was adequate.
Section 2.2.1.2 (EIS) states that "The alternatives assessment was accomplished with consideration of any comments received to date from Aboriginal communities…" Please provide specific detail on the type of comment received from MNO in relation to the alternatives assessment. Further, please provide the information in a disaggregated format to allow for proper consideration of each Aboriginal communities specific issues and concerns.
CEAA has previously requested proponents provide disaggregated information for consideration.
Specifically, as part of the correspondence in reference to the Pacific NorthWest LNG Ltd. Assessment (Reference Number 80032) CEAA specified that "Without the benefit of disaggregating by each Aboriginal group, for each factor considered under 5(1)(c), including related baseline information, it is difficult for the Agency to determine if enough detail exists to effectively assess the potential for significant adverse environmental effect that could potentially impact Aboriginal peoples. In other words, the conclusions regarding impacts on 5(1)(c) and Aboriginal rights contained in the EIS cannot be confidently relied upon without the benefit of a thorough understanding of the information used to support the conclusion."
Without a disaggregation of information, MNO cannot accurately identify information from MNO, if any; accurately review the conclusions of the report; and review any potential mitigation.
Link to Annex A1: AC(1)-01

IR-1 Reference #: AC(1)-83
MNO#: 2
EA Section or other technical document: Environmental Impact Statement Executive Summary
2.1.5 Aboriginal Groups
Comment: MNO requires additional information on the "Direction from the Provincial Crown (Ministry of Northern Development and Mines)" that was provided to identify the Aboriginal Groups engaged.
MNO requires information on the level of consultation recommended by the Crown for a Class EA as well as any other specific direction provided by the Ministry of Northern Development and Mines.
MNO understands that the Project is not subject to a provincial environmental assessment and is instead subject to a Class EA.

IR-1 Reference #: AC(1)-84
MNO#: 3
EA Section or other technical document: Environmental Impact Statement Executive Summary
4.1.4 Railway
Comment: MNO requires additional detail on the potential socio-economic effects of using the Dryden rail facility for material arriving by rail.

IR-1 Reference #: AC(1)-85
MNO#: 4
EA Section or other technical document: Environmental Impact Statement Executive Summary
4.2.2 Surface and Mine Water Management
Comment: MNO requires additional detail on the beaver dams within the Project footprint which will be removed during dewatering activities.
Beaver is an important species to MNO that is traditionally hunted and commercially trapped. The executive summary does not contain enough information on the removal of the dams as currently written.
Link to Annex A1: EE(1)-07

IR-1 Reference #: AC(1)-86
MNO#: 5
EA Section or other technical document: Environmental Impact Statement Executive Summary
4.5.2 Pipelines
Comment: MNO requires additional detail related to the proposed natural gas pipeline that is currently being discussed, including the type of regulatory application that will be required and level of consultation undertaken.

IR-1 Reference #: AC(1)-87
MNO#: 6
EA Section or other technical document: Environmental Impact Statement Executive Summary
4.13.3 Stockpiles
Comment: MNO requires additional information on the specific progressive rehabilitation that is proposed for the mine rock and overburden piles.
Link to Annex A1: WL(1)-06

IR-1 Reference #: AC(1)-88
MNO#: 7
EA Section or other technical document: Environmental Impact Statement Executive Summary
4.13.8 Roads, Pipelines and Power Distribution
Comment: The statement that "[l]ocal vegetation will be transplanted at selected sites if practical" is largely permissive.
Suggest rewording to "local vegetation will be transplanted on roads, pipeline and power distribution sites."
Link to Annex A1: HE(1)-43
AC(1)-01

IR-1 Reference #: AC(1)-89
MNO#: 8
EIS Guidelines: 11.2 Measures to address impacts on Aboriginal Rights
"This section will describe the measures identified to mitigate the potential adverse impacts of the project described in section 10.2 on the potential or established Aboriginal and Treaty rights and related interests identified in section 9.2. These measures will be written as specific commitments that clearly describe how the proponent."
EA Section or other technical document: Environmental Impact Statement Executive Summary
4.14 In-Design Mitigation
Comment: MNO was not involved in the development of in-design mitigation features, to date.
MNO requires consultation on the developed in-design mitigation and involvement in further mitigation that is proposed to be incorporated into the design of the Project.
Link to Annex A1: AC(1)-01

IR-1 Reference #: AC(1)-90
MNO#: 9
EA Section or other technical document: Environmental Impact Statement Executive Summary
4.14.1 Private Land Use
Comment: The application specifies that "The project as currently designed is 71% held in these land parcels. This limits encroachment on crown land parcels and mitigates loss of traditional treaty lands."
Please provide specific detail on the assessment and subsequent process for identification of mitigation related to the use of private land in mitigating the loss of traditional lands.
MNO requires more specific information related to the assessment of potential effect related to the encroachment on crown land and the subsequent steps in developing the mitigation referenced.
Link to Annex A1: HE(1)-38
HE(1)-43

IR-1 Reference #: AC(1)-91
MNO#: 10
EIS Guidelines: 11.2 Measures to address impacts on Aboriginal Rights
"This section will describe the measures identified to mitigate the potential adverse impacts of the project described in section 10.2 on the potential or established Aboriginal and Treaty rights and related interests identified in section 9.2. These measures will be written as specific commitments that clearly describe how the proponent."
EA Section or other technical document: Environmental Impact Statement Executive Summary
4.14.3 Air Quality and Noise Mitigation
Comment: MNO was not involved in the development of air quality and noise mitigation as outlined in the executive summary. Therefore the suggested mitigation cannot be expected to address the potential adverse impacts of the Project on MNOs established Aboriginal rights and related interest.
Link to Annex A1: HE(1)-43
AC(1)-01

IR-1 Reference #: AC(1)-92
MNO#: 11
EA Section or other technical document: Environmental Impact Statement Executive Summary
5.2.1 Site Preparation Phase, 5.2.2 Construction Phase
Comment: MNO requires consultation on the establishment and implementation of environmental protection and monitoring plans referenced in these sections.

IR-1 Reference #: AC(1)-93
MNO#: 12
EA Section or other technical document: Environmental Impact Statement Executive Summary
5.2.4 Closure and Post Closure Phase
Comment: MNO requires consultation on any developed closure plan prior to the filing of such a plan with the regulator.

IR-1 Reference #: AC(1)-94
MNO#: 13
EIS Guidelines: 9.1.2 Biophysical Environment
"The EIS will describe the following: … Existing ambient light levels at the project site and at any other areas where project activities could have an effect on light levels. The EIS will describe night-time illumination levels during different weather conditions and seasons."
EA Section or other technical document: Environmental Impact Statement Executive Summary
6.0 Description of the Environment
Comment: This section does not include a description of the existing ambient light levels at the project site or night-time illumination levels during different weather conditions and seasons.
Link to Annex A1: AE(1)-17

IR-1 Reference #: AC(1)-95
MNO#: 14
EA Section or other technical document: Environmental Impact Statement Executive Summary
6.0 Description of the Environment
Comment: Section is largely inconsistent with the reporting of effects and mitigation appearing for some components of the environment while not being described at all for others.
MNO suggests rewriting this entire section to have a consistent template and flow.

IR-1 Reference #: AC(1)-96
MNO#: 15
EIS Guidelines: 9.1.2 Biophysical Environment
"The EIS will describe the following: … ambient air quality in the project areas…"
EA Section or other technical document: Environmental Impact Statement Executive Summary
6.2 Air Quality, Noise, and Vibration
Comment: While the use of the Ministry of the Environment and Climate Change stations near Thunder Bay provides a conservative analysis of future background conditions, it does not provide the necessary information on the current baseline conditions of the Project study area.
MNO requires additional information is collected on the current baseline conditions for air quality.
Link to Annex A1: AE(1)-01

IR-1 Reference #: AC(1)-97
MNO#: 16
EIS Guidelines: 9.2 Potential or established Aboriginal and Treaty rights and Related Interests
"At minimum, the EIS will summarize available information on the potential or established Aboriginal and Treaty rights and related interests of the named Aboriginal groups that have potential to be adversely impacted by the project."
EA Section or other technical document: Environmental Impact Statement Executive Summary
6.2 Air Quality, Noise, and Vibration
Comment: MNO has not completed a Traditional Land Use Study to date nor has Treasury engaged MNO in consultation related to this topic.
Therefore, the referenced receptors for vibration levels cannot include information from MNO and is likely deficient.
Link to Annex A1: HE(1)-38
AC(1)-01

IR-1 Reference #: AC(1)-98
MNO#: 17
EIS Guidelines: 11.1.1 Methodology
"The EIS will then describe mitigation measures that are specific to each environmental effect identified in section 10.1. Measures will be written as specific commitments that clearly describe how the proponent intends to implement them."
EA Section or other technical document: Environmental Impact Statement Executive Summary
6.4 Geochemistry
Comment: The statement that "Mitigation strategies will likely be required to manage mine rock and tailing and to prevent acidic drainage and negative effects on downstream water quality at the site post closure and potentially during operations" does not provide sufficient detail.
MNO requires mitigation strategies be developed and proposed as part of the application development process in order to allow for rigorous review of the same.
Link to Annex A1:
MW(1)-07
MW(1)-14

IR-1 Reference #: AC(1)-99
MNO#: 18
EA Section or other technical document: Environmental Impact Statement Executive Summary
Comment: The statement "The closest water wells outside of the company's property are those on Thunder Lake, approximately 1.5 km from the proposed pit. Otherwise, there are no wells within 2 km of the proposed pit…" does not make sense.
There are, in fact, wells within 1.5 km of the proposed pit. The fact that there are no other wells within 2 km is irrelevant. Please clarify the statement.

IR-1 Reference #: AC(1)-100
MNO#: 19
EIS Guidelines: 9.1.2 Biophysical Environment
"The species selected within each biotic VC should include those of importance to … the current use of land and resources for traditional purposes by Aboriginal persons."
EA Section or other technical document: Environmental Impact Statement Executive Summary
6.7 Vegetation
Comment: MNO has not completed a Traditional Land Use Study to date nor has Treasury engaged MNO in consultation related to this topic. Therefore, of the 270 species identified in the LSA during the course of field survey activities, none can be confirmed to be used by MNO in the current use of lands and resources for traditional purposes by MNO.
MNO requires Treasury to consult with MNO on critical species used by MNO in the exercise of their Aboriginal rights both in advance of and through the execution of a TLUS.
Link to Annex A1:
HE(1)-38
AC(1)-01

IR-1 Reference #: AC(1)-101
MNO#: 20
EIS Guidelines: 9.1.2 Biophysical Environment
"The species selected within each biotic VC should include those of importance to … the current use of land and resources for traditional purposes by Aboriginal persons."
EA Section or other technical document: Environmental Impact Statement Executive Summary
6.8 Wildlife
Comment: MNO has not completed a Traditional Land Use Study to date nor has Treasury engaged MNO in consultation related to this topic. Therefore, of the species identified in the LSA during the course of field survey activities, none can be confirmed to be used by MNO in the current use of lands and resources for traditional purposes by MNO.
MNO requires Treasury to consult with MNO on critical species used by MNO in the exercise of their Aboriginal rights both in advance of and through the execution of a TLUS.
Link to Annex A1:
HE(1)-38
AC(1)-01

IR-1 Reference #: AC(1)-102
MNO#: 21
EIS Guidelines: 9.1.2 Biophysical Environment
"The species selected within each biotic VC should include those of importance to … the current use of land and resources for traditional purposes by Aboriginal persons."
EA Section or other technical document: Environmental Impact Statement Executive Summary
6.9 Aquatic Biology
Comment: MNO has not completed a Traditional Land Use Study to date nor has Treasury engaged MNO in consultation related to this topic. Therefore, of the thirty-six species identified during a review of historical records and thirty-one identified in the LSA during the course of field survey activities, none can be confirmed to be used by MNO in the current use of lands and resources for traditional purposes by MNO.
MNO requires Treasury to consult with MNO on critical species used by MNO in the exercise of their Aboriginal rights both in advance of and through the execution of a TLUS.
Link to Annex A1:
HE(1)-38
AC(1)-01

IR-1 Reference #: AC(1)-103
MNO#: 22
EIS Guidelines: 2.3 Aboriginal consultation
"The proponent will make reasonable efforts to integrate "traditional Aboriginal knowledge" that will contribute to the assessment of environmental impacts"
EA Section or other technical document: Environmental Impact Statement Executive Summary
6.10 Land and Resource Use, Traditional Knowledge and Land Use
Comment: The statement in this section that states "Traditional land uses, and traditional knowledge related to the Project area from … Métis Nation of Ontario has not been received" does not provide sufficient detail of the ongoing process to complete the referenced study.
Further, the description of traditional food uses, hunting practices, and fish species traditional use is deficient as MNO information has yet to be collected and incorporated into the EIS.
Link to Annex A1:
HE(1)-38
AC(1)-01

IR-1 Reference #: AC(1)-104
MNO#: 23
EIS Guidelines: 8.0 Alternative Means of Carrying out the Project
"The proponent will complete the following procedural steps for addressing alternative means: … Identify the effects of each alternative means. – The effects referred to above include both environmental and potential adverse impacts on potential or established Aboriginal and Treaty rights and related interests."
EA Section or other technical document: Environmental Impact Statement Executive Summary
7.2 Project Alternative
Comment: This section of the executive summary contains no detail related to the potential effects of each alternative means on potential or established Aboriginal rights and related interests.
Please update to include.
Link to Annex A1: AA(1)-02

IR-1 Reference #: AC(1)-105
MNO#: 24
EIS Guidelines: 9.1.3 Human Environment
"In describing the socio-economic environment, the proponent will provide information on the functioning and health of the socio-economic environment, encompassing a broad range of matters that affect communities and Aboriginal peoples…"      
EA Section or other technical document: Environmental Impact Statement Executive Summary
6.14 Socio-economics
Comment: This section of the executive summary contains no reference to matters that affect the MNO as part of the socio-economic assessment.
Please update the section to include matters of importance to the MNO.
Link to Annex A1: HE(1)-33

IR-1 Reference #: AC(1)-106
MNO#: 25
EIS Guidelines: 10.1.3 Effects of changes to the environment
"The EIS will describe the effects of any changes the project may cause to the environment, with respect to Aboriginal peoples, on health and socio-economic conditions, physical and cultural heritage, the current use of lands and resources for traditional purposes, or any structure, site or thing that is of historical, archaeological, paleontological or architectural significance."
EA Section or other technical document: Environmental Impact Statement Executive Summary
9.0 Aboriginal Engagement
Comment: The EIS states that "The goal of consultation for the Project is to provide Aboriginal communities with information and gather their feedback about: … anticipated environmental effects and management strategies…"
This approach is wholly inappropriate. MNO is not responsible for the identification of anticipated environmental effects or management strategies.
Instead, MNO can assist Treasury through the collection of necessary baseline information (namely the TLUS) and can collaboratively work with Treasury to identify impacts.
Link to Annex A1: AC(1)-01

IR-1 Reference #: AC(1)-107
MNO#: 27
EA Section or other technical document: Environmental Impact Statement Executive Summary
9.1 Potential Effects on Water Resources, Water Quality and Water Bodies
Comment: MNO requires specific detail on whether fisheries offset plans are required for the loss of fish habitat within the area within adjacent lakes, or streams in order to maintain fish populations.
Should a fisheries offset plan be required, MNO further requires consultation on the offset plan prior to submission of the plan to the regulator.
Link to Annex A1: FH(1)-06

IR-1 Reference #: AC(1)-108
MNO#: 31
EA Section or other technical document: Environmental Impact Statement Executive Summary
9.3 Potential Effects on Hunting and Trapping
Comment: The EIS states that "…no issues relating to hunting, fishing or gathering have been identified that are specific to the Project area."
MNO objects to the characterization as MNO has identified their Aboriginal rights in the project vicinity on numerous occasions and has requested capacity to document information related to these rights, to no avail.
Treasury has willfully and knowingly proceeded with its project development without the collection of MNO TLUS and has proceeded with the Project application without fulsome consultation with the MNO.
Link to Annex A1: HE(1)-38
AC(1)-01

IR-1 Reference #: AC(1)-109
MNO#: 32
EIS Guidelines: 7.2.1 Spatial Boundaries
"Spatial boundaries will be defined taking into account as applicable the appropriate scale and spatial extent of potential environmental effects, community and Aboriginal traditional knowledge, current land and resource use by Aboriginal groups, ecological, technical and social and cultural considerations."
EA Section or other technical document: Environmental Impact Statement Executive Summary
9.3 Potential Effects on Hunting and Trapping
Comment: While much of the Project is located on private land, this does not, in and of itself, reduce the impact to hunting. The Project effects extend beyond the Project footprint to a Local and Regional Study area which must be assessed and considered.
Link to Annex A1: HE(1)-38
HE(1)-44

IR-1 Reference #: AC(1)-110
MNO#: 33
EA Section or other technical document: Environmental Impact Statement Executive Summary
9.3 Potential Effects on Hunting and Trapping
Comment: Additional detail is required to support the claim that "Trapping on Crown lands in the vicinity of the Project site will not be altered as a result of the development of the Goliath Gold Mine."
What assessment was undertaken to reach this conclusion? What information from MNO was used in the determination?
Link to Annex A1: HE(1)-38
HE(1)-43

IR-1 Reference #: AC(1)-111
MNO#: 34, 128
EA Section or other technical document: Environmental Impact Statement Executive Summary
9.4 Gathering Plants and Berries
Environmental Impact Statement
5.11.5.1 Vegetation
Comment: The determination that "…although the gathering of plants and berries may be ongoing from year to year, the specific area where gathering may take place can change within a very short time." Is wholly inappropriate.
Firstly, this determination was made without sufficient credible information from the MNO. It is also a generalization that lacks credible back-up or foundation in fact.
Indeed, while berry patches can change from time to time. There are often established areas for gathering which reoccur from year to year which has not been considered or identified by Treasury.
Link to Annex A1: HE(1)-45
HE(1)-38
HE(1)-43

IR-1 Reference #: AC(1)-112
MNO#: 35
EA Section or other technical document: Environmental Impact Statement Executive Summary
9.4 Gathering Plants and Berries
Comment: The EIS states that "Blueberries are one type of berry known to be of interest to First Nations and other Aboriginal people. No specific areas associated with the Project have been identified as areas from which blueberries have been gathered."
This is inappropriate.
Blueberries, while potentially representative of some berry types, cannot be used as a substitute for all berry types within the vicinity of the Project. MNO gathers many varieties of berries and their exclusion from consideration in the assessment highlights the deficiency of the report.
Link to Annex A1: HE(1)-38

IR-1 Reference #: AC(1)-113
MNO#: 36
EA Section or other technical document: Environmental Impact Statement Executive Summary
9.4 Gathering Plants and Berries
Comment: It is interesting to note that while blueberries may change locales "within a very short time" they are specifically located within the Dryden Forest, of which the proponent suggests as an alternative locale for berry gathering very close to the Project.
Link to Annex A1: HE(1)-43

IR-1 Reference #: AC(1)-114
MNO#: 37
EA Section or other technical document: Environmental Impact Statement Executive Summary
9.5 Flooding and Weather Related Disasters
Comment: The EIS states that "Treasury does not have the expertise to comment on the causes of climate change and weather patterns." However, it is Treasury's responsibility to procure the necessary expertise to address all issues and concerns raised as part of the EIS application process.
Not having the expertise does not remove the issue.
Link to Annex A1: EE(1)-06

IR-1 Reference #: AC(1)-115
MNO#: 38
EA Section or other technical document: Environmental Impact Statement Executive Summary
9.6 Cumulative Loss of Section 35 Harvesting Rights
Comment: This section is largely cursory and does not delve into the specific aspects of section 35 rights. Aboriginal rights are varied and include a holistic approach to the environment which must be considered.
Relating these rights only to the small amount of land impacted in the vicinity of the Project shows an impoverished view of these rights and minimizes them.
Link to Annex A1: CE(1)-07

IR-1 Reference #: AC(1)-116
MNO#: 39
EA Section or other technical document: Environmental Impact Statement Executive Summary
9.7 Access Restrictions
Comment: As MNO has not completed a TLUS, the scope and extent of their trails and travelways cannot be quantified in the Project area. This section does not consider this or make provisions for the potential information. Overreaching
Link to Annex A1: HE(1)-38

IR-1 Reference #: AC(1)-117
MNO#: 40
EA Section or other technical document: Environmental Impact Statement Executive Summary
9.10 Mine Closure
Comment: MNO requires involvement in the development and implementation of any Project closure plan developed by Treasury.

IR-1 Reference #: AC(1)-117b
MNO#: 41
EA Section or other technical document: Environmental Impact Statement Executive Summary
9.12 Potential Effects on Noise Quality, Air Quality, and Light Quality
Comment: While this section references high level information on noise and air quality, it totally ignores light quality.
Please provide a summary of the concerns raised by Aboriginal groups, information on the potential impacts and proposed mitigation for light quality.
Further, information should be provided on the summary of concerns raised by Aboriginal groups related to air quality and noise as well.
Link to Annex A1: AE(1)-16

IR-1 Reference #: AC(1)-118
MNO#: 42
EA Section or other technical document: Environmental Impact Statement Executive Summary
9.13 Visual Aesthetics
Comment: This section is largely cursory and does not provide the necessary detail to understand the Aboriginal concerns related to visual aesthetics, the potential project impacts or information on mitigation.
Link to Annex A1: HE(1)-36
HE(1)-47

IR-1 Reference #: AC(1)-119
MNO#: 43
EA Section or other technical document: Environmental Impact Statement Executive Summary
10.0 Human Health and Ecological Risk Assessment
Comment: The species listed as part of the SLRA were not consulted on with MNO and cannot be verified as species of importance to MNO.
MNO requires consultation on the species included in the SLRA to ensure they capture a representative sample of species harvested by MNO in the exercise of their rights.
Link to Annex A1: AC(1)-01
HE(1)-45

IR-1 Reference #: AC(1)-120
MNO#: 44
EIS Guidelines: 7.1.1 Valued Components
"Valued Components (VCs) refer to attributes associated with the project that have been identified to be of concern by the proponent, government agencies, Aboriginal peoples and/or the public."
EA Section or other technical document: Environmental Impact Statement Executive Summary
12.1 Effects Assessment Process
Comment: The definition given for Valued Components in this section differs from the definition provided in the EIS Guidelines. Specifically, it does not mention Aboriginal peoples, which is of concern to MNO.

IR-1 Reference #: AC(1)-121
MNO#: 45
EA Section or other technical document: Environmental Impact Statement Executive Summary
12.2.2.5 Aboriginal Peoples
Comment: This section is largely cursory and does not contain the necessary detail to evaluate the application.
Specifically, this section contains no information on potential effects or mitigation.
Link to Annex A1: HE(1)-43

IR-1 Reference #: AC(1)-122
MNO#: 46
EIS Guidelines: 8.0 Alternative Means of Carrying out the Project
"The proponent will complete the following procedural steps for addressing alternative means: … Identify the effects of each alternative means. – The effects referred to above include both environmental and potential adverse impacts on potential or established Aboriginal and Treaty rights and related interests."
EA Section or other technical document: Environmental Impact Statement
2.0 Assessment of Alternatives
Comment: The proponent has not completed an identification of effects for each alternative means which takes into account potential or established Aboriginal and treaty rights.
This shows the lack of consideration given to Aboriginal interests in the EIS and lack of information provided on this topic.
Link to Annex A1: AA(1)-02
AC(1)-01

IR-1 Reference #: AC(1)-123
MNO#: 48,49,50,51,53,54,56,57,59
EIS Guidelines: 8.0 Alternative Means of Carrying out the Project
"The proponent will complete the following procedural steps for addressing alternative means: … Identify the effects of each alternative means. – The effects referred to above include both environmental and potential adverse impacts on potential or established Aboriginal and Treaty rights and related interests."
EA Section or other technical document: Environmental Impact Statement
2.3.1 Mining
2.3.2 Minewater Management
2.3.3 Mine Rock and Overburden Management
2.3.5 Process Effluent Treatment
2.3.7 Water Supply
2.3.8 Water Discharge Location
2.3.9 Watercourse Realignments
2.3.10 Infrastructure and Buildings
2.3.12 Non-hazardous Solid Waste Management
Comment: This alternative does not include information related to First Nation Reserves and Communities or Traditional Land Use as per the Environmental criteria for the alternative assessment.
Link to Annex A1: AA(1)-02

IR-1 Reference #: AC(1)-124
MNO#: 52
EA Section or other technical document: Environmental Impact Statement
2.3.5.4 In-Plant Cyanide Destruction Followed by Natural Degradation Followed by Effluent Treatment
Comment: This section specifies that "This method ensures that wildlife, including waterfowl and aquatic life, are protected." But lacks the necessary detail to back up this conclusion.
Please provide specific detail around how this method will ensure that wildlife and aquatic life are protected.
Link to Annex A1: SW(1)-14
WL(1)-05

IR-1 Reference #: AC(1)-125
MNO#: 55
EA Section or other technical document: Environmental Impact Statement
2.3.8 Water Discharge Location
Comment: The preferred water discharge location still presents a number of issues of concern to MNO which have not been reflected in the alternatives assessment. Specifically, the discharge into Blackwater Creek and eventually discharge into Wabigoon Lake, the source of drinking water for the City of Dryden.
Wabigoon Lake is a key waterbody used by MNO in the exercise of their Aboriginal rights and interests.
MNO lacks confidence in the proposed ongoing environmental impact monitoring proposed as well as other uncertainties outlined in this section.
Link to Annex A1: AA(1)-09
AC(1)-01

IR-1 Reference #: AC(1)-126
MNO#: 58
EIS Guidelines: 8.0 Alternative Means of Carrying out the Project
"The EIS will identify and consider the effects of alternative means of carrying out the project that are technically and economically feasible."                              
EA Section or other technical document: Environmental Impact Statement
2.3.12 Non-hazardous Solid Waste Management
Comment: This section contains no consideration of alternatives for non-hazardous solid waste management.
Please provide alternatives assessment or remove from assessment altogether.

IR-1 Reference #: AC(1)-127
MNO#: 60
EIS Guidelines: 8.0 Alternative Means of Carrying out the Project
"The EIS will identify and consider the effects of alternative means of carrying out the project that are technically and economically feasible."
EA Section or other technical document: Environmental Impact Statement
2.3.13 Hazardous Solid Waste Management
Comment: This section contains no consideration of alternatives for hazardous solid waste management.
The justification that "…the potential negative effects on the physical, biological and human environment are unacceptable when compared to transporting the material to an existing licenced [sic] facility." Is inappropriate and clearly is at cross purposes with the intended outcome of an alternatives assessment. Instead the alternatives should have been outlined, including the potential negative effects to allow for a comparison of effects.
Please provide an alternative assessment for hazardous waste management.

IR-1 Reference #: AC(1)-128
MNO#: 61,62.63.
EIS Guidelines: 8.0 Alternative Means of Carrying out the Project
"The proponent will complete the following procedural steps for addressing alternative means: … Identify the effects of each alternative means. – The effects referred to above include both environmental and potential adverse impacts on potential or established Aboriginal and Treaty rights and related interests."
EA Section or other technical document: Environmental Impact Statement
EA Section or other technical document: 2.3.13 Hazardous Solid Waste Management
2.3.14 Domestic Sewage Management
2.3.15 Explosives Storage Facility
Comment: This alternative does not include information related to First Nation Reserves and Communities or Traditional Land Use as per the Environmental criteria for the alternative assessment.
Link to Annex A1: AA(1)-02

IR-1 Reference #: AC(1)-129
MNO#: 64
EIS Guidelines: 8.0 Alternative Means of Carrying out the Project
"In its alternative means analysis, the proponent will address, as a minimum, the following project components: … Energy sources for the mine complex operation … related piping and power infrastructure as appropriate (i.e. under the proponent's control)."
EA Section or other technical document: Environmental Impact Statement
Multiple Sections within Section 2.3
Comment: This section specifies that the "[p]ower supply will be taken directly from the existing 115 kV Hydro One M2D with an on-site substation … Treasury sees no benefits in creating a separate power source and no other options have been assessed."
This misses the point of an alternatives assessment and does not fulfill the CEAA requirements of the EIS Guidelines.
Further, there is no discussion of related piping and power infrastructure as part of the alternatives assessment.
Please provide additional information related to these components.
Link to Annex A1: AA(1)-05
RG(1)-23

IR-1 Reference #: AC(1)-130
MNO#: 65
EA Section or other technical document: Environmental Impact Statement
2.4 Project Alternatives – Closure
Comment: MNO requires confirmation that they will be consulted prior to the submission of a detailed certified Closure Plan as well as throughout the applicable comment period as no consultation on the conceptual closure plan has been undertaken to date.

IR-1 Reference #: AC(1)-131
MNO#: 66, 68, 69, 71, 72, 74, 75, 76
EIS Guidelines: 8.0 Alternative Means of Carrying out the Project
"The proponent will complete the following procedural steps for addressing alternative means: … Identify the effects of each alternative means. – The effects referred to above include both environmental and potential adverse impacts on potential or established Aboriginal and Treaty rights
EA Section or other technical document: Environmental Impact Statement
2.4.1 Open Pit Closure
2.4.2 Underground Closure
2.4.3 Waste Rock Storage Area Closure
2.4.4 Minewater Management System Closure
2.4.5 Tailings Storage Facility Closure
2.4.6 Buildings and Equipment Closure
2.4.7 Infrastructure Closure
2.4.8 Drainage Closure
Comment: Sections 2.4.1 to 2.4.8 (EIS) outlines closure alternatives but do not include information related to First Nation Reserves and Communities or Traditional Land Use as per the Environmental criteria for the alternative assessment.
Link to Annex A1: AA(1)-02

IR-1 Reference #: AC(1)-132
MNO#: 67
EIS Guidelines: 8.0 Alternative Means of Carrying out the Project
"The EIS will identify and consider the effects of alternative means of carrying out the project that are technically and economically feasible."
EA Section or other technical document: Environmental Impact Statement
2.4.2 Underground Closure
Comment: The EIS references Ontario Regulation 240/00, amended O. Reg. 307/12, and the Code of the Ontario Mining Act. Section 24(2) of the Regulation and indicated that "Due to the nature of these regulations, no alternatives were considered as part of the EIS.
While these regulations guide the underground closure procedure, they do not offer specific direction on the process for mine closure. Therefore, reliance on the information in the Regulation should not preclude Treasury from conducting an assessment of alternatives.
Please provide an assessment of alternatives.

IR-1 Reference #: AC(1)-133
MNO#: 70
EIS Guidelines: 8.0 Alternative Means of Carrying out the Project
"The EIS will identify and consider the effects of alternative means of carrying out the project that are technically and economically feasible."
EA Section or other technical document: Environmental Impact Statement
2.4.3 Waste Rock Storage Area Closure
Comment: This section contains no assessment of alternatives for the waste rock storage area closure. Instead, it is just a description of the preferred method.
Please provide an assessment of alternatives.
Link to Annex A1: AA(1)-11
AA(1)-07

IR-1 Reference #: AC(1)-134
MNO#: 73
EIS Guidelines: 8.0 Alternative Means of Carrying out the Project
"The EIS will identify and consider the effects of alternative means of carrying out the project that are technically and economically feasible."
EA Section or other technical document: Environmental Impact Statement
2.4.6 Buildings and Equipment Closure
Comment: This section contains no assessment of alternatives for the Buildings and Equipment Closure. Instead, it is just a description of the preferred method.
Please provide an assessment of alternatives.

IR-1 Reference #: AC(1)-135
MNO#: 77

EA Section or other technical document: Environmental Impact Statement
2.5 Summary of Alternatives
Comment: This table outlined project elements and whether they were assessed in the EA or not. All elements are indicated that they were assessed even when this is not the case. Specifically, the following elements were not assessed:

• Buildings and Equipment Closure
• Waste Rock Storage Area Closure
• Underground Closure
• Hazardous Solid Waste Management
• Non-hazardous Solid Waste Management

Please update the table to reflect the actual content of the EIS.

IR-1 Reference #: AC(1)-136
MNO#: 78
EIS Guidelines: 9.1.1 Methodology
"…the proponent will take an ecosystems approach that considers both scientific and traditional knowledge and perspectives regarding ecosystems health and integrity."
EA Section or other technical document: Environmental Impact Statement
Comment: The existing environment's air quality does not take an ecosystem approach and consider traditional knowledge. In fact, the entire section related to air quality does not mention traditional knowledge at all.
Please revise this section to include an ecosystem approach and include traditional knowledge of the MNO.

IR-1 Reference #: AC(1)-137
MNO#: 79
EIS Guidelines: 9.1.2 Biophysical Environment
"The EIS will describe the following: Ambient air quality in the project area…"
EA Section or other technical document: Environmental Impact Statement
Comment: The existing baseline for ambient air quality was estimated using data from two MOE monitoring stations in Thunder Bay which cannot provide an accurate estimation of the current baseline conditions from which to assess potential effects.
Instead, this would provide a higher level of air emissions from which the effects assessment would be conducted.
The EIS states that the data would represent an overestimate of typical concentrations of contaminants of concern; however, this is not a positive outcome.
In order to complete an accurate baseline assessment of air quality it would be more prudent to under estimate the concentrations of contaminants of concern instead. This only works if the proponent assesses air effects in an additive manner.
MNO requires reassessment of air quality baseline with specific air quality receptors on the project site.
Link to Annex A1: AE(1)-04

IR-1 Reference #: AC(1)-138
MNO#: 80,82,84
EIS Guidelines: 7.2.1 Spatial Boundaries
"Spatial boundaries will be defined taking into account as applicable the appropriate scale and spatial extent of potential environmental effects … Aboriginal traditional knowledge, current land and resource use by Aboriginal groups…"
EA Section or other technical document: Environmental Impact Statement
5.2.1.1 Study Area
5.3.1.1 Study Area
5.3.2.1 Study Area
5.8.4.1 Study Areas & Included Waterbodies
Comment: The study area did not take into account Aboriginal traditional knowledge or current land and resource use by MNO.
In fact, there is no mention of consideration of any traditional knowledge or current land and resource use by any Aboriginal group.
Link to Annex A1: EA(1)-01
AC(1)-01
HE(1)-38

IR-1 Reference #: AC(1)-139
MNO#: 81
EIS Guidelines: 9.1.2 Biophysical Environment
"The EIS will describe the following: … including the following contaminants: …VOCs, CO, NH3, ground level ozone…"
EA Section or other technical document: Environmental Impact Statement
Table 5.2.1
Comment: This table does not display results for VOCs or ground level ozone. Please update to show information on VOCs and ground level ozone.
Link to Annex A1: AE(1)-03

IR-1 Reference #: AC(1)-140
MNO#: 83
EIS Guidelines: 9.1.2 Biophysical Environment
"The EIS will describe the following: … Information on typical sound sources, geographic extent and temporal variations will be included…"
EA Section or other technical document: Environmental Impact Statement
5.3.1.3 Existing Noise Levels
Comment: The baseline conditions do not include information on the geographic extent of noise levels.
Please include.
Link to Annex A1: AE(1)-21

IR-1 Reference #: AC(1)-141
MNO#: 84
EIS Guidelines: 9.1.1 Methodology
"…the proponent will take an ecosystems approach that considers both scientific and traditional knowledge and perspectives regarding ecosystems health and integrity…"
EA Section or other technical document: Environnemental Impact Statement
5.3.1 Baseline Noise Levels
Comment: The baseline noise quality section does not take an ecosystem approach and consider traditional knowledge. In fact, the entire section related to noise levels does not mention traditional knowledge at all.
Please revise this section to include an ecosystem approach and include traditional knowledge of the MNO.
Link to Annex A1: EA(1)-01
AC(1)-01

IR-1 Reference #: AC(1)-142
MNO#: 86
EIS Guidelines: 9.1.2 Biophysical Environment
"The EIS will describe the following: … night-time illumination levels during different weather conditions and seasons."
EA Section or other technical document: Environmental Impact Statement
5.3.2.3 Existing Light Levels
Comment: This section of the EIS does not contain a description of night-time illumination levels and does not contain information on how these light levels are affected by different weather conditions and seasons.
Please provide.
Link to Annex A1: AE(1)-17

IR-1 Reference #: AC(1)-143
MNO#: 87
EIS Guidelines: 9.1.1 Methodology
"…the proponent will take an ecosystems approach that considers both scientific and traditional knowledge and perspectives regarding ecosystems health and integrity…"
EA Section or other technical document: Environmental Impact Statement
5.3.1 Baseline Light Levels
Comment: The baseline light levels section does not take an ecosystem approach and consider traditional knowledge. In fact, the entire section related to light levels does not mention traditional knowledge at all.
Please revise this section to include an ecosystem approach and include traditional knowledge of the MNO.
Link to Annex A1: EA(1)-01
AC(1)-01

IR-1 Reference #: AC(1)-144
MNO#: 88
EA Section or other technical document: Environmental Impact Statement
Figure 5.5.2, 5.8.2, 5.9.2, 5.9.3
Comment: Why does the local study area on each of the referenced maps not encompass the entire property boundary?

IR-1 Reference #: AC(1)-145
MNO#: 89, 91
EIS Guidelines: 9.1.1 Methodology
"…the proponent will take an ecosystems approach that considers both scientific and traditional knowledge and perspectives regarding ecosystems health and integrity…"
EA Section or other technical document: Environmental Impact Statement
5.8.4 Fish and Fish Habitat
5.8.4.2 Fish Presence
Comment: The baseline fish and fish habitat section does not take an ecosystem approach and consider traditional knowledge. In fact, the entire section related to fish and fish habitat does not mention traditional knowledge at all.
This section specifies that "Appendix G and Appendix Q contain lists [sic] of all fish species identified within the Project area, including those identified in historical records and those caught in field surveys." However, there is no indication if the listing of fish species was influenced by traditional knowledge.
MNO requires reevaluation of the listing of fish species to include traditional knowledge and revision of the EIS to state this explicitly.
Please revise this section to include an ecosystem approach and include traditional knowledge of the MNO.
Link to Annex A1: EA(1)-01
AC(1)-01

IR-1 Reference #: AC(1)-146
MNO#: 92
EIS Guidelines: 7.2.1 Spatial Boundaries
"Spatial boundaries will be defined taking into account as applicable the appropriate scale and spatial extent of potential environmental effects … Aboriginal traditional knowledge, current land and resource use by Aboriginal groups…"
EA Section or other technical document: Environmental Impact Statement
5.8.4 Fish and Fish Habitat
Comment: No spatial boundary is identified for Fish and Fish Habitat in this section of the EIS. While a general spatial study area was defined in Appendix G, Environmental Baseline Study, it must be referenced and reiterated in this section of the EIS.
Further, it must take into account Aboriginal traditional knowledge or current land and resource use by MNO.
Link to Annex A1: FH(1)-20
EA(1)-01
AC(1)-01

IR-1 Reference #: AC(1)-147
MNO#: 93
EIS Guidelines: 9.1.2 Biophysical Environment
"Furthermore, the EIS will describe the following: … Identify any potential waterbodies and fish habitat sites that could be rehabilitated for possible habitat gains to offset losses from the project."
EA Section or other technical document: Environmental Impact Statement
5.8.4.7 Habitat Rehabilitation Opportunities
Comment: More information is required in relation to the statement that "The Ontario Ministry of Natural Resources and Forestry has identified Crown shore stabilization on Wabigoon Lake as an effective way to benefit fish and fish habitat and offset potential losses from the Project development."
As it is currently worded, it implies that the MNR has proposed a project offset. If this is the case, more information is required.
Link to Annex A1: FH(1)-06

IR-1 Reference #: AC(1)-148
MNO#: 94
EIS Guidelines: 9.1.2 Biophysical Environment
"The following information sources on species at risk and species of conservation concern should be consulted:

• SARA (www.sararegistry.gc.ca);
• COSEWIC;
• Relevant Government agencies;
• Local naturalist and interest groups; and
• Aboriginal groups and First Nations."

EA Section or other technical document: Environmental Impact Statement
5.8.4.8 Species at Risk and Species of Management Concern
Comment: SARA, Relevant Government agencies, local naturalist and interest groups and Aboriginal groups and First Nations were not consulted in determining the presence of Species at Risk within the RSA.
Link to Annex A1: FH(1)-22
AC(1)-03

IR-1 Reference #: AC(1)-149
MNO#: 95
EIS Guidelines: 9.1.2 Biophysical Environment
"The following information sources on species at risk and species of conservation concern should be consulted:

• SARA (www.sararegistry.gc.ca);
• COSEWIC;
• Relevant Government agencies;
• Local naturalist and interest groups; and
• Aboriginal groups and First Nations."

EA Section or other technical document: Environmental Impact Statement
5.8.4.8 Species at Risk and Species of Management Concern
Comment: No detail is provided on the sources of information used to compile the Fish Species of Management Concern in the RSA.
Please update this information.
While this information is missing, it can be assumed from the MNO's current consultation records that no consultation occurred with MNO on species of conservation concern. Therefore the EIS is subsequently deficient.
Link to Annex A1: FH(1)-22

IR-1 Reference #: AC(1)-150
MNO#: 96, 98
EIS Guidelines: 7.2.1 Spatial Boundaries
"Spatial boundaries will be defined taking into account as applicable the appropriate scale and spatial extent of potential environmental effects … Aboriginal traditional knowledge, current land and resource use by Aboriginal groups…"
9.1.1 Methodology
"…the proponent will take an ecosystems approach that considers both scientific and traditional knowledge and perspectives regarding ecosystems health and integrity…"
EA Section or other technical document: Environmental Impact Statement
5.9.2 Vegetation
Comment: No spatial boundary is identified for Vegetation in this section of the EIS. While a general spatial study area was defined in Appendix G, Environmental Baseline Study, it must be referenced and reiterated in this section of the EIS. Further, it must take into account Aboriginal traditional knowledge or current land and resource use by MNO.
The baseline vegetation section does not take an ecosystem approach and consider traditional knowledge. In fact, the entire section related to vegetation does not mention traditional knowledge at all.
Please revise this section to include an ecosystem approach and include traditional knowledge of the MNO.
Link to Annex A1: HE(1)-45
EA(1)-01
AC(1)-01
WL(1)-01
WL(1)-02

IR-1 Reference #: AC(1)-151
MNO#: 97
EIS Guidelines: 9.2.1 Biophysical Environment
"The species selected within each biotic VC should include those of importance to health and socio-economic conditions, cultural heritage and the current use of land and resources for traditional purposes by Aboriginal persons."
EA Section or other technical document: Environmental Impact Statement
5.9.2.2 Forest Compositions through to 5.9.2.4 Field Surveys
Comment: There is no mention of species being selected to include those of importance to the current use of land and resources for traditional purposes by Aboriginal persons.
Please amend this section to reflect the above mentioned information.
Link to Annex A1: HE(1)-45
EA(1)-01
AC(1)-01

IR-1 Reference #: AC(1)-152
MNO#: 99, 100
EIS Guidelines: 7.2.1 Spatial Boundaries
"Spatial boundaries will be defined taking into account as applicable the appropriate scale and spatial extent of potential environmental effects … Aboriginal traditional knowledge, current land and resource use by Aboriginal groups…"
9.1.1 Methodology
"…the proponent will take an ecosystems approach that considers both scientific and traditional knowledge and perspectives regarding ecosystems health and integrity…"
EA Section or other technical document: Environmental Impact Statement
5.9.3 Wetlands
Comment: No spatial boundary is identified for Wetlands in this section of the EIS. While a general spatial study area was defined in Appendix G, Environmental Baseline Study, it must be referenced and reiterated in this section of the EIS. Further, it must take into account Aboriginal traditional knowledge or current land and resource use by MNO.
The baseline wetlands section does not take an ecosystem approach and consider traditional knowledge. In fact, the entire section related to wetlands does not mention traditional knowledge at all.
Please revise this section to include an ecosystem approach and include traditional knowledge of the MNO.
Link to Annex A1: WL(1)-03
HE(1)-45
EA(1)-01
AC(1)-01

IR-1 Reference #: AC(1)-153
MNO#: 101, 102, 103
EIS Guidelines: 7.2.1 Spatial Boundaries
"Spatial boundaries will be defined taking into account as applicable the appropriate scale and spatial extent of potential environmental effects … Aboriginal traditional knowledge, current land and resource use by Aboriginal groups…"
9.1.1 Methodology
"…the proponent will take an ecosystems approach that considers both scientific and traditional knowledge and perspectives regarding ecosystems health and integrity…"
EA Section or other technical document: Environmental Impact Statement
5.9.4 Mammals
Comment: No spatial boundary is identified for mammals in this section of the EIS. While a general spatial study area was defined in Appendix G, Environmental Baseline Study, it must be referenced and reiterated in this section of the EIS. Further, it must take into account Aboriginal traditional knowledge or current land and resource use by MNO.
There is no description in the baseline section for mammals of the distribution, populations, behavior and availability of wildlife in the important context of implications to current use of lands and resources by Aboriginal peoples. The baseline mammals section does not take an ecosystem approach and consider traditional knowledge. In fact, the entire section related to mammals does not mention traditional knowledge at all.
Please revise this section to include an ecosystem approach and include traditional knowledge of the MNO.
Link to Annex A1: HE(1)-45
EA(1)-01
AC(1)-01
WL(1)-01
WL(1)-02

IR-1 Reference #: AC(1)-154
MNO#: 104, 105, 106
EIS Guidelines: 7.2.1 Spatial Boundaries
"Spatial boundaries will be defined taking into account as applicable the appropriate scale and spatial extent of potential environmental effects … Aboriginal traditional knowledge, current land and resource use by Aboriginal groups…"
9.1.1 Methodology
"…the proponent will take an ecosystems approach that considers both scientific and traditional knowledge and perspectives regarding ecosystems health and integrity…"
EA Section or other technical document: Environmental Impact Statement
5.9.5 Birds
Comment: No spatial boundary is identified for Birds in this section of the EIS. While a general spatial study area was defined in Appendix G, Environmental Baseline Study, it must be referenced and reiterated in this section of the EIS. Further, it must take into account Aboriginal traditional knowledge or current land and resource use by MNO.
There is no description in the baseline section for birds of the distribution, populations, behavior and availability of birds in the important context of implications to current use of lands and resources by Aboriginal peoples. The baseline birds section does not take an ecosystem approach and consider traditional knowledge. In fact, the entire section related to birds does not mention traditional knowledge at all.
Please revise this section to include an ecosystem approach and include traditional knowledge of the MNO.
Link to Annex A1: HE(1)-45
EA(1)-01
AC(1)-01
WL(1)-01
WL(1)-02

IR-1 Reference #: AC(1)-155
MNO#: 107, 108
EIS Guidelines: 7.2.1 Spatial Boundaries
"Spatial boundaries will be defined taking into account as applicable the appropriate scale and spatial extent of potential environmental effects … Aboriginal traditional knowledge, current land and resource use by Aboriginal groups…"
9.1.1 Methodology
"…the proponent will take an ecosystems approach that considers both scientific and traditional knowledge and perspectives regarding ecosystems health and integrity…"
EA Section or other technical document: Environmental Impact Statement
5.9.8 Significant Wildlife Habitat
Comment: No spatial boundary is identified for Significant Wildlife Habitat in this section of the EIS. While a general spatial study area was defined in Appendix G, Environmental Baseline Study, it must be referenced and reiterated in this section of the EIS. Further, it must take into account Aboriginal traditional knowledge or current land and resource use by MNO.
The baseline section for significant wildlife habitat does not take an ecosystem approach and consider traditional knowledge. In fact, the entire section does not mention traditional knowledge at all. Please revise this section to include an ecosystem approach and include traditional knowledge of the MNO.
Link to Annex A1: HE(1)-45
EA(1)-01
AC(1)-01
WL(1)-01
WL(1)-02

IR-1 Reference #: AC(1)-156
MNO#: 109
EA Section or other technical document: Environmental Impact Statement
5.10 Species at Risk
Comment: Please identify how Section 10 of the EIS relates to Section 5.8.4.8 (Species at Risk and Species of Management Concern)

IR-1 Reference #: AC(1)-157
MNO#: 110
EIS Guidelines: 9.1.2 Biophysical Environment
"The following information sources on species at risk and species of conservation concern should be consulted:

• SARA (www.sararegistry.gc.ca);
• COSEWIC;
• Relevant Government agencies;
• Local naturalist and interest groups; and
• Aboriginal groups and First Nations."

EA Section or other technical document: Environmental Impact Statement
5.10.1 Definition
Comment: The definition given for SAR within the EIS references different information sources than those outlined in the EIS guidelines. While MNO does not object to additional information sources being added, the original listing should still be included. Specifically, relevant government agencies, local naturalist and interest groups and Aboriginal groups and First Nations.
Link to Annex A1: AC(1)-03
FH(1)-22

IR-1 Reference #: AC(1)-158
MNO#: 111, 112
EIS Guidelines: 7.2.1 Spatial Boundaries
"Spatial boundaries will be defined taking into account as applicable the appropriate scale and spatial extent of potential environmental effects … Aboriginal traditional knowledge, current land and resource use by Aboriginal groups…"
9.1.1 Methodology
"…the proponent will take an ecosystems approach that considers both scientific and traditional knowledge and perspectives regarding ecosystems health and integrity…"
EA Section or other technical document: Environmental Impact Statement
5.10 Species at Risk
Comment: No spatial boundary is identified for Species at Risk in this section of the EIS. While a general spatial study area was defined in Appendix G, Environmental Baseline Study, it must be referenced and reiterated in this section of the EIS.
Further, it must take into account Aboriginal traditional knowledge or current land and resource use by MNO.
The baseline section for species at risk does not take an ecosystem approach and consider traditional knowledge.
Please revise this section to include an ecosystem approach and include traditional knowledge of the MNO.
Link to Annex A1: HE(1)-45
EA(1)-01
AC(1)-01
AC(1)-03

IR-1 Reference #: AC(1)-159
MNO#: 113
EA Section or other technical document: Environmental Impact Statement
5.10.3.1 Plants
Comment: The EIS states that "Wild rice is a traditional food source for many First Nations."
Firstly, this information is obviously anecdotal in nature as many plants are traditional food sources for Aboriginal groups but are not specifically mentioned.
Secondly, the information is not sufficiently disaggregated to allow for an identification of which First Nation/Aboriginal group the information came from.
CEAA has previously requested proponents provide disaggregated information for consideration.
Specifically, as part of the correspondence in reference to the Pacific NorthWest LNG Ltd. Assessment (Reference Number 80032) CEAA specified that "Without the benefit of disaggregating by each Aboriginal group, for each factor considered under 5(1)(c), including related baseline information, it is difficult for the Agency to determine if enough detail exists to effectively assess the potential for significant adverse environmental effect that could potentially impact Aboriginal peoples. In other words, the conclusions regarding impacts on 5(1)(c) and Aboriginal rights contained in the EIS cannot be confidently relied upon without the benefit of a thorough understanding of the information used to support the conclusion."
Finally, there is no further information provided on traditional food sources for Aboriginal groups which is contrary to even the most basic of information MNO could provide through a TLUS.
Link to Annex A1: AC(1)-01
HE(1)-38
HE(1)-45

IR-1 Reference #: AC(1)-160
MNO#: 114
EIS Guidelines: 9.1.2 Biophysical Environment
"The species selected within each biotic VC should include those of importance to health and socio-economic conditions, cultural heritage and the current use of land and resources for traditional purposes by Aboriginal persons."
EA Section or other technical document: Environmental Impact Statement
5.10.3.2 Animals
Comment: The EIS states that "…the selected survey methodology only allows for the determination of presence; it does not allow for the estimation of abundance, seasonal activity, or spatial distribution."
This is contrary to the direction provided by the EIS guidelines and makes it impossible to include information on the importance to health and socio-economic conditions, cultural heritage, and the current use of land and resources for traditional purposes by Aboriginal persons.
Link to Annex A1: HE(1)-45

IR-1 Reference #: AC(1)-161
MNO#: 115
EA Section or other technical document: Environmental Impact Statement
5.10.3.2 Animals
Comment: Please provide additional rationale as to why evening surveys were selected even though "…evening surveys, though allowable in the protocol, will result in lower detection probability of target species."
Link to Annex A1: WL(1)-14

IR-1 Reference #: AC(1)-162
MNO#: 116
EIS Guidelines: 7.2.1 Spatial Boundaries
"Spatial boundaries will be defined taking into account as applicable the appropriate scale and spatial extent of potential environmental effects … Aboriginal traditional knowledge, current land and resource use by Aboriginal groups…"
EA Section or other technical document: Environmental Impact Statement
5.11 Human Environment
Comment: No spatial boundary is identified for the human environment in this section of the EIS. While a general spatial study area was defined in Appendix G, Environmental Baseline Study, it must be referenced and reiterated in this section of the EIS.
Further, it must take into account Aboriginal traditional knowledge or current land and resource use by MNO.
Link to Annex A1: HE(1)-33
AC(1)-01

IR-1 Reference #: AC(1)-163
MNO#: 117
EIS Guidelines: 9.1.3 Human Environment
"In describing the socio-economic environment, the proponent will provide information on the functioning and health of the socio-economic environment, encompassing a broad range of matters that affect communities and Aboriginal peoples in the study area in a way that recognizes interrelationships, system functions and vulnerabilities. A description of the rural and urban settings likely to be affected by the project will be provided."
EA Section or other technical document: Environmental Impact Statement
5.11.1 Land Use
Comment: There is no description of Métis land use within this section of the report. This is despite their being a description of the First Nation reserves.
Please amend the section to include specific details about Métis land use including Métis demographics in the surrounding towns and communities.
Link to Annex A1: HE(1)-33
HE(1)-38

IR-1 Reference #: AC(1)-164
MNO#: 118
EIS Guidelines: 9.1.3 Human Environment
"In describing the socio-economic environment, the proponent will provide information on the functioning and health of the socio-economic environment, encompassing a broad range of matters that affect communities and Aboriginal peoples in the study area in a way that recognizes interrelationships, system functions and vulnerabilities. A description of the rural and urban settings likely to be affected by the project will be provided."
EA Section or other technical document: Environmental Impact Statement
5.11.2.1 Population
Comment: This section of the EIS does not include specific details about the Métis population within the major urban centres surrounding the Project. Further, this section does not include the median age for Métis in the region as well as other population demographics that are available.
Please amend the section to include specific details around Métis population.
Link to Annex A1: HE(1)-33

IR-1 Reference #: AC(1)-165
MNO#: 119
EIS Guidelines: 9.1.3 Human Environment
"In describing the socio-economic environment, the proponent will provide information on the functioning and health of the socio-economic environment, encompassing a broad range of matters that affect communities and Aboriginal peoples in the study area in a way that recognizes interrelationships, system functions and vulnerabilities. A description of the rural and urban settings likely to be affected by the project will be provided."
EA Section or other technical document: Environmental Impact Statement
5.11.2.2 Education
Comment: This section of the EIS does not include specific details about the Métis education levels in the vicinity of the Project.
Please amend the section to include specific details around Métis education.
Link to Annex A1: HE(1)-33

IR-1 Reference #: AC(1)-166
MNO#: 120
EIS Guidelines: 9.1.3 Human Environment
"In describing the socio-economic environment, the proponent will provide information on the functioning and health of the socio-economic environment, encompassing a broad range of matters that affect communities and Aboriginal peoples in the study area in a way that recognizes interrelationships, system functions and vulnerabilities. A description of the rural and urban settings likely to be affected by the project will be provided."
EA Section or other technical document: Environmental Impact Statement
5.11.2.5 Crime and Justice
Comment: The description of crime and justice is inadequate for the purposes of a baseline assessment and must be supplemented in order to accurately reflect the current conditions of the area immediately surrounding the Project.
Link to Annex A1: HE(1)-33

IR-1 Reference #: AC(1)-167
MNO#: 121
EIS Guidelines: 9.1.3 Human Environment
"In describing the socio-economic environment, the proponent will provide information on the functioning and health of the socio-economic environment, encompassing a broad range of matters that affect communities and Aboriginal peoples in the study area in a way that recognizes interrelationships, system functions and vulnerabilities. A description of the rural and urban settings likely to be affected by the project will be provided."
EA Section or other technical document: Environmental Impact Statement
5.11.2.6 Poverty and Social Issues
Comment: This section of the EIS does not include specific details about Métis poverty or social issues.
Please amend the section to include specific details around Métis poverty and social issues.
Link to Annex A1: HE(1)-33

IR-1 Reference #: AC(1)-168
MNO#: 122, 123
EIS Guidelines: 7.2.1 Spatial Boundaries
"Spatial boundaries will be defined taking into account as applicable the appropriate scale and spatial extent of potential environmental effects … Aboriginal traditional knowledge, current land and resource use by Aboriginal groups…"
9.1.1 Methodology
"…the proponent will take an ecosystems approach that considers both scientific and traditional knowledge and perspectives regarding ecosystems health and integrity…"
EA Section or other technical document: Environmental Impact Statement
5.11.5 Aboriginal Peoples
Comment: No spatial boundary is identified for Aboriginal Peoples in this section of the EIS. While a general spatial study area was defined in Appendix G, Environmental Baseline Study, it must be referenced and reiterated in this section of the EIS.
Further, it must take into account Aboriginal traditional knowledge or current land and resource use by MNO.
The baseline section for Aboriginal Peoples does not take an ecosystem approach and consider traditional knowledge.
Please revise this section to include an ecosystem approach and include traditional knowledge of the MNO.
Link to Annex A1: HE(1)-33
EA(1)-01

IR-1 Reference #: AC(1)-169
MNO#: 124
EIS Guidelines: 9.2 Potential or established Aboriginal and Treaty rights and Related Interests
EA Section or other technical document: Environmental Impact Statement
5.11.5 Aboriginal Peoples
Comment: The title of this section serves to minimize the information presented by Treasury and does not reflect the requirement of the EIS guideline to assess potential or established Aboriginal rights and related interests.
Link to Annex A1: HE(1)-43

IR-1 Reference #: AC(1)-170
MNO#: 125
EIS Guidelines: 9.2 Potential or established Aboriginal and Treaty rights and Related Interests
"At minimum, the EIS will summarize available information on the potential or established Aboriginal and Treaty rights and related interests of the named Aboriginal groups that have the potential to be adversely impacted by the project. As part of this summary the EIS will include for each Aboriginal group:

• Background information and a map of the groups traditional territory;
• A summary engagement activities conducted prior to the submission of the EIS, including the date and means of engagement (e.g. meeting, mail, telephone);
• Information on each group's potential or established rights (including geographic extent, nature, frequency, timing), including maps and data sets (e.g. fish catch numbers) when this information is provided by a group to the proponent;
• An overview of key comments and concerns provided by each group to the proponent;
• Responses provided by government and/or the proponent, as appropriate; and
• Future planned engagement activities." [emphasis added]

EA Section or other technical document: Environmental Impact Statement
5.11.5 Aboriginal Peoples
Comment: Firstly, this section is presented in a pan-Aboriginal format which is not sufficiently disaggregated in order to allow MNO to adequately assess the validity of the information provided.
CEAA has previously requested proponents provide disaggregated information for consideration.
Specifically, as part of the correspondence in reference to the Pacific NorthWest LNG Ltd. Assessment (Reference Number 80032) CEAA specified that "Without the benefit of disaggregating by each Aboriginal group, for each factor considered under 5(1)(c), including related baseline information, it is difficult for the Agency to determine if enough detail exists to effectively assess the potential for significant adverse environmental effect that could potentially impact Aboriginal peoples. In other words, the conclusions regarding impacts on 5(1)(c) and Aboriginal rights contained in the EIS cannot be confidently relied upon without the benefit of a thorough understanding of the information used to support the conclusion."
Secondly, no background information is provided in relation to the MNO specifically. There are significant levels of information publically available on the MNO's website. Therefore, there is no reason Treasury should have excluded this information. Even if the consultation process had been sufficiently stalled, the information was still available publically.
Thirdly, there is no information provided on MNO's specific potential or established rights, including the geographic extent, nature, frequency and timing of these rights.
Finally, there is no reference to the MNO's comments and concerns and how those comments and concerns were incorporated into the EIS.
Overall, this section lacks the necessary detail for MNO to evaluate the EIS application.
Link to Annex A1: HE(1)-38
AC(1)-01

IR-1 Reference #: AC(1)-171
MNO#: 126
EA Section or other technical document: Environmental Impact Statement
5.11.5 Aboriginal Peoples
Comment: This section does not contain information on all vegetation gathered, species hunted, trapped or fished by the MNO.
Section must be updated following consultation with the MNO.
Link to Annex A1: HE(1)-38
HE(1)-45

IR-1 Reference #: AC(1)-172
MNO#: 127

EA Section or other technical document: Environmental Impact Statement
5.11.5.1 Vegetation
Comment: The statement that "First Nations communities and the public have not identified any specific plants or berries which may be negatively affected by the development of the project, nor have any locations been identified within the Project area from which plants and berries are being gathered been identified." Is misleading.
As MNO has yet to be sufficiently engaged by the proponent, of course this information has yet to be provided. An ineffective consultation program should not be used as a shield for the proponent. Nor should sweeping conclusions be based on a faulty consultation program.
Link to Annex A1: AC(1)-01
HE(1)-38
HE(1)-45

IR-1 Reference #: AC(1)-173
MNO#: 129
EA Section or other technical document: Environmental Impact Statement
5.11.5.1 Vegetation
Comment: The assumptions made in the section in relation to blueberries are largely incorrect. It is implied that blueberries are transient crops which are found in a variety of locales rather than in consistent spots.
However, MNO Harvesting does use consistent berry locales. The 4-6 years suggested is approximate and berries can be available at locations longer. Additionally, berries can be available in certain locales for the duration of an MNO citizens picking lifetime.
It is not clear why this point is being made in relation to blueberries and due to contradictory information held by the MNO, it is generally false and misleading.
Please amend EIS section.
Link to Annex A1: HE(1)-45

IR-1 Reference #: AC(1)-174
MNO#: 130
EA Section or other technical document: Environmental Impact Statement
5.11.5.1 Vegetation
Comment: Blueberries, chanterelle mushrooms and wild rice do not constitute the entirety of plant species harvested by the MNO.
MNO would be happy to provide Treasury with an amended listing of vegetation species preferred by the MNO to update this section of the EIS.
Link to Annex A1: HE(1)-38
HE(1)-40
HE(1)-45

IR-1 Reference #: AC(1)-175
MNO#: 131, 132
EA Section or other technical document: Environmental Impact Statement
Figure 5.11
Figure 5.11.2
Comment: This figure presents an inaccurate picture of cultural foods and interests as MNO information is not presented.
Link to Annex A1: HE(1)-40

IR-1 Reference #: AC(1)-176
MNO#: 133
EIS Guidelines: 7.1.1 Valued Components
"This list will be completed according to the evolution and design of the project and reflect the knowledge acquired on the environment through public and Aboriginal consultations."
EA Section or other technical document: Environmental Impact Statement
5.11.5.2 Hunting and Trapping
Comment: This section specifies that the game species listed have been identified as valued components. However, these were developed without sufficient consultation with the MNO, contrary to direction in the EIS guidelines.
Link to Annex A1: AC(1)-01
HE(1)-45

IR-1 Reference #: AC(1)-177
MNO#: 134, 135
EA Section or other technical document: Environmental Impact Statement
Table 5.11.8
Table 5.11.9
Comment: This table does not include the estimated number of active Métis hunters which is held by the Captain of the Hunt. This shows a lack of consultation on the part of Treasury with the MNO. Further, MNO could have initiated a count of total harvest for a season, should Treasury have requested this information. This shows significant gaps in the consultation process whereby MNO information was not considered and information requested was largely superficial.
Link to Annex A1: HE(1)-38

IR-1 Reference #: AC(1)-178
MNO#: 136
EA Section or other technical document: Environmental Impact Statement
Table 5.11.8 and 5.11.9
Comment: There are no similar tables presented for the other VCs listed, including waterfowl (which is not further broken out into species), furbearing species (which is not further broken out into specifics) and ruffed grouse.
Please update EIS to include specific information and tables.
Link to Annex A1: HE(1)-45

IR-1 Reference #: AC(1)-179
MNO#: 137
EIS Guidelines: 7.1.1 Valued Components
"This list will be completed according to the evolution and design of the project and reflect the knowledge acquired on the environment through public and Aboriginal consultations."
EA Section or other technical document: Environmental Impact Statement
5.11.5.3 Fishing
Comment: This section states that "The mouth of Nugget Creek at Wabigoon Lake is designated a Provincial Fish Sanctuary to protect spawning Walleye and fishing is prohibited in this area during the Walleye spawning season; therefore it is seen as a culturally important and relevant to country food harvesters as a valued component."
More information is required to identify how this area was identified as relevant to country food harvesters and further designated as a valued component as MNO was not consulted in order to reach these conclusions.
Link to Annex A1: AC(1)-01
HE(1)-38

IR-1 Reference #: AC(1)-180
MNO#: 138
EIS Guidelines: 7.1.1 Valued Components
"Valued Components (VCs) refer to attributes associated with the project that have been identified to be of concern by the proponent, government agencies, Aboriginal peoples and/or the public. The value of a component not only relates to its role in the ecosystem, but also to the value placed on it by humans."
EA Section or other technical document: Environmental Impact Statement
6.1.1 Potential Effects and Valued Components
Comment: The definition provided for valued components does not include the specific criteria outlined in the EIS guidelines.
Please amend this section of the EIS to include the information outlined in the EIS guidelines.
Link to Annex A1: AC(1)-01

IR-1 Reference #: AC(1)-181
MNO#: 139
EA Section or other technical document: Environmental Impact Statement
6.1.1 Potential Effects and Valued Components
Comment: This section outlines information related to natural environment VCs and specifies criteria that the VC would have met; however, there is no information on socio-economic VC provided.
Link to Annex A1: EA(1)-03

IR-1 Reference #: AC(1)-182
MNO#: 140
EIS Guidelines: 7.1.1 Valued Components
"This list will be completed according to the evolution and design of the project and reflect the knowledge acquired on the environment through public and Aboriginal consultations."
EA Section or other technical document: Environmental Impact Statement
6.1.2 Integration of Public and Aboriginal Considerations
Comment: The listing in this section does not explicitly state that Aboriginal consultations were considered as undertakings for the assessment. Please clarify.
Link to Annex A1: AC(1)-01

IR-1 Reference #: AC(1)-183
MNO#: 141
EA Section or other technical document: Environmental Impact Statement
6.1.2 Integration of Public and Aboriginal Considerations
Comment: Collection of Traditional Knowledge is only one vehicle for contributing to the Project VCs. However, Treasury has completed an inefficient and ineffectual consultation process as well, limiting MNO's opportunity for meaningful input.
Further, this section mischaracterizes the lack of TK information. Treasury has not offered MNO sufficient capacity to complete a TK study.
As a number of "Aboriginal communities have alluded to traditional use in the general area of the Project…" Treasury should have made significant effort to obtain this information, rather than stagnant the process in meaningless negotiation.
Link to Annex A1: AC(1)-01

IR-1 Reference #: AC(1)-184
MNO#: 142
EA Section or other technical document: Environmental Impact Statement
6.1.2 Integration of Public and Aboriginal Considerations
Comment: The statement that "The CEA Agency, in discussions with Aboriginal communities has also identified issues and concerns" mischaracterizes the process.
MNO has yet to be engaged by CEA to date in the identification of their issues and concerns.
Link to Annex A1: AC(1)-01

IR-1 Reference #: AC(1)-185
MNO#: 143
EIS Guidelines: 9.1.1 Methodology
"…the proponent will take an ecosystems approach that considers both scientific and traditional knowledge and perspectives regarding ecosystems health and integrity…"
EA Section or other technical document: Environmental Impact Statement
6.1.2 Integration of Public and Aboriginal Considerations
Comment: The statement that "[a]side from an expressed desire to maintain Treaty and Aboriginal rights, the concerns raised by Aboriginal communities have been very similar to those concerns raised by the general public…" shows an impoverished view of Aboriginal rights and interests and their interconnectivity.
Aboriginal concerns are intrinsically linked to their Aboriginal and treaty rights and require a holistic, ecosystems approach to be fully understood and realized.
Link to Annex A1: EA(1)-01

IR-1 Reference #: AC(1)-186
MNO#: 144
EA Section or other technical document: Environmental Impact Statement
6.1.2 Integration of Public and Aboriginal Considerations
Comment: Wabigoon Lake is an area heavily used by MNO in the exercise of their Aboriginal rights and interests. However, MNO is not listed in the examples provided of the raised concerns. Specifically, surface and groundwater quality and fish and fish habitat. This shows the lack of an adequate consultation process, to date.
Link to Annex A1: FH(1)-06
AC(1)-01

IR-1 Reference #: AC(1)-187
MNO#: 145
EA Section or other technical document: Environmental Impact Statement
6.1.2 Integration of Public and Aboriginal Considerations
Comment: The EIS states that "[c]onsultation and engagement efforts by Treasury have not resulted in any formal Traditional Knowledge (TK) studies being conducted…"
This is mainly due to the failings of Treasury. To date, Treasury has not come to agreement with MNO related to funding a TK Study as well as general capacity.
Further, Treasury suggested that MNO complete a shared TK Study with another Aboriginal group. This shows an impoverished view of Aboriginal rights that assumes all groups share the same interests.
Link to Annex A1: EA(1)-01

IR-1 Reference #: AC(1)-188
MNO#: 146
EA Section or other technical document: Environmental Impact Statement
6.1.3 Residual Effects Characterization
Comment: The EIS contains no specific information on the process of avoidance, minimization and mitigation.
Please provide specific steps in the development of these aspects.
Link to Annex A1: HE(1)-43
EA(1)-05

IR-1 Reference #: AC(1)-189
MNO#: 147
EA Section or other technical document: Environmental Impact Statement
6.2.1.3 Noise
Comment: This section does not account for the ongoing noise from blasting activities proposed by the Project. Where will these effects be assessed?
Link to Annex A1: AE(1)-22
AE(1)-23
AE(1)-28
AE(1)-30

IR-1 Reference #: AC(1)-190
MNO#: 148
EA Section or other technical document: Environmental Impact Statement
6.2.1.8 Surface Water Quantity
Comment: This section appears to delve into the effects assessment portion of the EIS and does not properly identify the potential effects to surface water quality which would be considered as part of the assessment.
Please amend the EIS to accurately identify these considerations.

IR-1 Reference #: AC(1)-191
MNO#: 149
EIS Guidelines: 7.1.1 Valued Components
"This list will be completed according to the evolution and design of the project and reflect the knowledge acquired on the environment through public and Aboriginal consultations."
EA Section or other technical document: Environmental Impact Statement
6.2.1.11 Wildlife and Wildlife Habitat
Comment: The identified potential effects do not reflect knowledge acquired on the environment through Aboriginal consultations; specifically, Métis consultation.
Link to Annex A1: EA(1)-01

IR-1 Reference #: AC(1)-192
MNO#: 150
EA Section or other technical document: Environmental Impact Statement
6.2.1.11 Wildlife and Wildlife Habitat
Comment: The statement that "In total, it is expected that 242 ha of wildlife habitat will be lost due to Project activities for the duration of the Project life. Habitats are expected to recover over time following project closure" is inappropriately placed in this section.
Conclusions of the effects assessment should be left to further sections in the EIS to maintain the illusion of an unbiased assessment.

IR-1 Reference #: AC(1)-193
MNO#: 151
EIS Guidelines: 7.1.1 Valued Components
"This list will be completed according to the evolution and design of the project and reflect the knowledge acquired on the environment through public and Aboriginal consultations."
EA Section or other technical document: Environmental Impact Statement
6.2.1.12 Fish and Fish Habitat
Comment: The identified potential effects do not reflect knowledge acquired on the environment through Aboriginal consultations; specifically, Métis consultation.
Link to Annex A1: FH(1)-06

IR-1 Reference #: AC(1)-194
MNO#: 152
EA Section or other technical document: Environmental Impact Statement
6.2.1.12 Fish and Fish Habitat
Comment: This section of the EIS specifies that "[l]iquid discharges from the Project, including treated tailings water and site runoff, are expected to meet all regulatory requirements before it is released to the natural environment. Water discharges are expected to be directed into the Blackwater Creek systems, which ultimately flows into Wabigoon Lake."
This information does not reflect MNO information and does not comment on the use of Wabigoon Lake by the MNO. Further, as this section is to outline the potential effects, assuming that the water will meet all regulatory requirements prior to the effects assessment is inappropriate.
Link to Annex A1: AC(1)-01

IR-1 Reference #: AC(1)-195
MNO#: 153
EIS Guidelines: 7.1.1 Valued Components
"This list will be completed according to the evolution and design of the project and reflect the knowledge acquired on the environment through public and Aboriginal consultations."
EA Section or other technical document: Environmental Impact Statement
6.2.1.13 Wetlands and Vegetation
Comment: The identified potential effects do not reflect knowledge acquired on the environment through Aboriginal consultations; specifically, Métis consultation.
Link to Annex A1: EA(1)-01

IR-1 Reference #: AC(1)-196
MNO#: 154
EIS Guidelines: 7.1.1 Valued Components
"This list will be completed according to the evolution and design of the project and reflect the knowledge acquired on the environment through public and Aboriginal consultations."
EA Section or other technical document: Environmental Impact Statement
6.2.2.1 Land Use
Comment: The identified potential effects do not reflect knowledge acquired on the environment through Aboriginal consultations; specifically, Métis consultation.
Specifically, the primary effects identified as noise and visual disturbance may not be correct as potential effects to wildlife, fish and flora may be potential higher than those of noise and visual disturbance.
Link to Annex A1: EA(1)-01
HE(1)-45
AC(1)-01

IR-1 Reference #: AC(1)-197
MNO#: MNO#: 155
EA Section or other technical document: Environmental Impact Statement
6.2.2.1 Land Use
Comment: The reference in this section to recreational and tourism activities exclude the exercise of Aboriginal rights.
Please amend the EIS.
Link to Annex A1: HE(1)-33
HE(1)-35

IR-1 Reference #: AC(1)-198
MNO#: 156
EA Section or other technical document: Environmental Impact Statement
6.3 Valued Component Identification
Comment: This section does not include the most basic components that are present in most EIS' that allow for consideration of the scientific method and potential project effects.
The section is missing:

• Information on the establishment of assessment boundaries for each VC (spatial, temporal, technical and administrative)
• Information on the scope of the assessment, including:
  • Selection of potential effects
  • Measurable parameters an significance thresholds
  • Traditional knowledge and traditional use information
  • Influence of consultation on the assessment

IR-1 Reference #: AC(1)-199
MNO#: 157
EA Section or other technical document: Environmental Impact Statement
6.3 Valued Component Identification
Comment: This section does not include a matrix which displays those VCs that were included/excluded from the assessment. Without this information there is no pathway shown by the proponent that rationalizes their assessment and selection of VCs. Additionally, there is no discussion of why specific VCs were included/excluded in the EIS.
Link to Annex A1: AC(1)-01
EA(1)-03

IR-1 Reference #: AC(1)-200
MNO#: 158
EA Section or other technical document: Environmental Impact Statement
6.3.1.3 Noise
Comment: The two noise VCs that were identified for inclusion in the environmental assessment do not include a consideration of blasting noise.
As this will be a continuous and disruptive source of noise throughout the Project's lifetime, it must be considered as a potential VC and not as an indicator under a VC.
Link to Annex A1: AE(1)-22

IR-1 Reference #: AC(1)-201
MNO#: 159, 161, 163, 167, 171,
EIS Guidelines: 2.3 Aboriginal Consultation
"The proponent will make reasonable efforts to integrate "traditional Aboriginal knowledge" that will contribute to the assessment of environmental impacts."
EA Section or other technical document: Environmental Impact Statement
6.3.1.3 Noise
6.3.1.4 Light
6.3.1.5 Air Quality
6.3.1.11 Wildlife and Wildlife Habitat
6.3.1.13 Wetlands and Vegetation
Comment: At minimum, the noise assessment VCs should link back to effects on Aboriginal rights and interests. This has not been completed and there is no linkage between Aboriginal interests and noise.
At minimum, the light assessment VCs should link back to effects on Aboriginal rights and interests. This has not been completed and there is no linkage between Aboriginal interests and light.
At minimum, the air quality assessment VCs should link back to effects on Aboriginal rights and interests. This has not been completed and there is no linkage between Aboriginal interests and air quality.
At minimum, the wildlife and wildlife habitat assessment VCs should link back to effects on Aboriginal rights and interests. This has not been completed and there is no linkage between Aboriginal interests and wildlife and wildlife habitat.
At minimum, the wetland and vegetation assessment VCs should link back to effects on Aboriginal rights and interests. This has not been completed and there is no linkage between Aboriginal interests and wetlands and vegetation.
Link to Annex A1: HE(1)-45

IR-1 Reference #: AC(1)-202
MNO#: 160
EA Section or other technical document: Environmental Impact Statement
6.3.1.4 Light
Comment: This section outlines the conclusions of the effects assessment and does not explicitly outline the project VCs or potential effects.
Conclusions of the effects assessment should be left to further sections in the EIS to maintain the illusion of an unbiased assessment.
Link to Annex A1: AE(1)-19

IR-1 Reference #: AC(1)-203
MNO#: 162
EIS Guidelines: 9.1.2 Biophysical Environment
"…including the following contaminants: Total Suspended Particulates, PM2.5, PM10, Sox, VOCs, CO, NH3, ground level ozone, and NOx"
EA Section or other technical document: Environmental Impact Statement
6.3.1.5 Air Quality
Comment: The potential contaminants listed as the air quality VCs should be classified as indicators for change under the VC, not the VC itself. The VC should be an overarching component such as "Air Quality" or equivalent.
Further, the listing of contaminants of concern does not include VOCs or ground level ozone, of which the EIS Guidelines require information on.
Link to Annex A1: AE(1)-03

IR-1 Reference #: AC(1)-204
MNO#: 164
EA Section or other technical document: Environmental Impact Statement
6.3.1.6 Climate
Comment: The first sentence of this section contains a typo.
Sentence states: "…Treasury included one climate CV…" should state "…Treasury included one climate VC…"

IR-1 Reference #: AC(1)-205
MNO#: 165
EA Section or other technical document: Environmental Impact Statement
6.3.1.9 Groundwater Quality
Comment: This section of the EIS states "… Treasury considered the protection of water quality for future discharge … to be a VC … in order to ensure there are no adverse impacts to the surface water environment."
Selection of water quality as a VC does not ensure there are no adverse impacts. Instead, a VC is used as a measure by which potential effects can be marked against.
Please amend this section to reflect the accurate description of VCs.

IR-1 Reference #: AC(1)-206
MNO#: 166
EA Section or other technical document: Environmental Impact Statement
6.3.1.11 Wildlife and Wildlife Habitat
Comment: The VCs selected for inclusion in the environmental assessment do not include discussion of indicators or measurable parameters.
Examples of effects for wildlife are:

• Change in habitat
• Change in mortality risk
• Alternation of movement
• Etc.

These are not listed in this section.
Please update the EIS to reflect standard EIS methodology.
Link to Annex A1: EA(1)-03

IR-1 Reference #: AC(1)-207
MNO#: 168, 169
EIS Guidelines: 2.3 Aboriginal Consultation
"The proponent will make reasonable efforts to integrate "traditional Aboriginal knowledge" that will contribute to the assessment of environmental impacts."
EA Section or other technical document: Environmental Impact Statement
6.3.1.12 Fish and Fish Habitat
Comment: The VCs selected for inclusion in the environmental assessment do not include discussion of indicators or measurable parameters.
Examples of actual effects for fish and fish habitat include:

• Change in sediment or water quality;
• Change in fish habitat;
• Direct mortality or physical injury to fish; or
• Change in behavior of fish.

These are not listed in this section.
Please update the EIS to reflect standard EIS methodology.
Link to Annex A1: FH(1)-21
FH(1)-06
EA(1)-03

IR-1 Reference #: AC(1)-208
MNO#: 170
EA Section or other technical document: Environmental Impact Statement
6.3.1.13 Wetlands and Vegetation
Comment: The VCs identified for wetlands and vegetation are more statements of facts than identification of VCs.
Please amend the EIS to reflect VCs for wetlands and vegetation that are not statements. This will ensure the assessment of effects can occur on items that are less broad and more reflective of the potential project effects.
Link to Annex A1: WL(1)-03
EA(1)-03

IR-1 Reference #: AC(1)-209
MNO#: 172
EA Section or other technical document: Environmental Impact Statement
6.3.2.1 Land Use
Comment: The identification of Land and resource use as a VC for Land Use is inappropriate. The VC must represent a vulnerable component under Land and Resource Use instead of just repeating the section title.
Link to Annex A1: HE(1)-43

IR-1 Reference #: AC(1)-210
MNO#: 173
EIS Guidelines: 2.3 Aboriginal Consultation
"The proponent will make reasonable efforts to integrate "traditional Aboriginal knowledge" that will contribute to the assessment of environmental impacts."
EA Section or other technical document: Environmental Impact Statement
6.3.2.1 Land Use
Comment: At minimum, the Land Use assessment VCs should link back to effects on Aboriginal rights and interests. This has not been completed and there is no linkage between Aboriginal interests and land use.
Link to Annex A1: HE(1)-43

IR-1 Reference #: AC(1)-211
MNO#: 174
EA Section or other technical document: Environmental Impact Statement
6.3.2.5 Aboriginal Peoples
Comment: The title of this section minimizes the duty of the proponent to assess potential effects on Aboriginal rights and interests.
Suggest rewording the title to reflect the wording in the EIS guidelines: "Potential or established Aboriginal and Treaty rights and Related Interests"
Link to Annex A1: HE(1)-43

IR-1 Reference #: AC(1)-212
MNO#: 175
EA Section or other technical document: Environmental Impact Statement
6.4 Effects Assessment
Comment: This section does not include an interaction matrix of project activities during each phase and the VCs chosen for inclusion in the assessment.
This would serve to rank the interactions, taking a conservative approach, and identify where the higher risk interactions occur and focus the assessment on these interactions.
Link to Annex A1: EA(1)-02

IR-1 Reference #: AC(1)-213
MNO#: 176, 178, 180, 182, 183, 185, 205,
207, 208, 209
EA Section or other technical document: Environmental Impact Statement
6.4.1.3 Noise
6.4.1.4 Light
6.4.1.5 Air Quality
6.4.1.6 Climate
6.4.1.7 Surface Water Quality
6.4.1.8 Surface Water Quantity
6.4.1.9 Groundwater Quality
6.4.1.10 Groundwater Quantity
6.4.1.13 Wetlands and Vegetation
6.4.2.1 Land Use
6.4.2.2 Social Factors
6.4.2.3 Economic Factors
Comment: This section is titled "Effects Assessment" however, there is no such effects assessment included.
Typically, an effects assessment will include:

• Definition of temporal boundaries (not present)
• Definition of spatial boundaries including a PDA, LAA and RAA (not present)
• A description of baseline conditions (included in another volume, not to the satisfaction of MNO)
• A description of Analytical Methods
• A description of assumptions and conservative approach
• An outline of the potential effects
• Details about potential mitigation
• Characterization of residual effects, including a residual effects classification
• A determination of significance of residual effects
• Details of confidence and risk
• Outline of follow-up monitoring, if applicable

This EIS does not follow these basic parameters for reporting the results. Instead, the noise including blasting, light, air quality, climate, surface water quality and quantity and the groundwater quality and quantity assessments jump straight to mitigation with cursory descriptions of the characterization of the residual effects and a superficial description of ongoing monitoring. The sections describing wetlands and vegetation, land use, social factors and economic factors contain cursory identification of effects with no explanation or detail. Then jumps directly into mitigation, a broad overview of residual effects characterization, etc. The lack of details is troubling and makes evaluating the results of the EIS impossible.

This is inappropriate.

Please update the effects assessment for noise including blasting, light, air quality, climate, surface water quality and quantity, groundwater quality and quantity, wetlands and vegetation, land use, social factors and economic factors to include an assessment of effects .
Link to Annex A1: EA(1)-01
EA(1)-02
EA(1)-03
EA(1)-04
EA(1)-05
EA(1)-06
EA(1)-07
EA(1)-08
EA(1)-09

IR-1 Reference #: AC(1)-214
MNO#: 177, 179, 181, 197, 203, 204
EIS Guidelines: 2.3 Aboriginal Consultation
"The proponent will make reasonable efforts to integrate "traditional Aboriginal knowledge" that will contribute to the assessment of environmental impacts."
10.1.3 Effects of Changes to the Environment
"The EIS will describe the effects of any change the project may cause to the environment, with respect to Aboriginal peoples…"
EA Section or other technical document: Environmental Impact Statement
6.4.1.3 Noise
6.4.1.4 Light
6.4.1.5 Air Quality
6.4.1.11 Wildlife and Wildlife Habitat
6.4.1.12 Fish and Fish Habitat
6.4.1.13 Wetlands and Vegetation
Comment: At minimum, the noise assessment results should link back to effects on Aboriginal rights and interests. This has not been completed and there is no linkage between Aboriginal interests and noise.

At minimum, the light assessment results should link back to effects on Aboriginal rights and interests. This has not been completed and there is no linkage between Aboriginal interests and light.

 At minimum, the air quality assessment results should link back to effects on Aboriginal rights and interests. This has not been completed and there is no linkage between Aboriginal interests and air quality.

At minimum, the wildlife and wildlife habitat assessment results should link back to effects on Aboriginal rights and interests. This has not been completed and there is no linkage between Aboriginal interests and wildlife and wildlife habitat.

At minimum, the fish and fish habitat assessment results should link back to effects on Aboriginal rights and interests. This has not been completed and there is no linkage between Aboriginal interests and fish and fish habitat.

At minimum, the wetlands and vegetation assessment results should link back to effects on Aboriginal rights and interests. This has not been completed and there is no linkage between Aboriginal interests and wetlands and vegetation.
Link to Annex A1: HE(1)-43
HE(1)-45

IR-1 Reference #: AC(1)-215
MNO#: 184
EA Section or other technical document: Environmental Impact Statement
6.4.1.7 Surface Water Quality
Comment: This section of the EIS states that "Wabigoon Lake would be affected for a very short period of time and the effect would be mostly localized to Kelpyn Bay" in the event of a catastrophic failure of the TSF.
MNO requires additional information on this potential effect including a more comprehensive description of the effects including specific data related to the potential scenarios, information about potential mitigation measures, characterization of residual effects, determination of significance and information related to Treasury's confidence and risk.
Link to Annex A1: AM(1)-04

IR-1 Reference #: AC(1)-216
MNO#: 186
EA Section or other technical document: Environmental Impact Statement
6.4.1.11 Wildlife and Wildlife Habitat
Comment: The VC selected for wildlife and wildlife habitat has not been assessed. Instead, the proponent relies on the delineation of terrestrial habitat to characterize effects (for SAR, ungulates, furbearers, upland birds, and wetland birds). Not only is this inappropriate methodologically, the habitat selected has not been identify or classified to a specific SAR, ungulate, furbearer, upland bird or wetland bird and is therefore too general for assessment of effects.
Link to Annex A1: EA(1)-02

IR-1 Reference #: AC(1)-217
MNO#: 187,188,189,190
EA Section or other technical document: Environmental Impact Statement
6.4.1.11 Wildlife and Wildlife Habitat
Comment: This section outlines additional potential effects for SAR during construction that include "direct mortality as a result of human activity, mortality of roosting bats or nesting birds during habitat clearing activities, and vehicular collisions." However, these potential effects do not appear to be adequately assessed as they were not listed as valued components nor characterized as part of the effects assessment. Instead, the assessment jumps directly to potential mitigation for these potential effects, characterizes the residual effects in a cursory manner and defines a significance rating for them all in the space of 13 lines.

The section related to SAR Operations and Closure, again, only contains a very sparse and cursory description of the potential effects before launching into potential mitigation for these potential effects, characterizes the residual effects in a cursory manner and defines a significance rating for them all in the space of 12 lines.

This section outlines additional potential effects for ungulates during construction that include "direct mortality as a result of human activity (e.g. Vehicular collisions)." However, these potential effects do not appear to be adequately assessed as they were not listed as valued components nor characterized as part of the effects assessment. Instead, the assessment jumps directly to potential mitigation for these potential effects, characterizes the residual effects in a cursory manner and defines a significance rating for them all in the space of 11 lines.

The section related to ungulate Operations and Closure, again, only contains a very sparse and cursory description of the potential effects before launching into potential mitigation for these potential effects, characterizes the residual effects in a cursory manner and defines a significance rating for them all in the space of 12 lines.

IR-1 Reference #: AC(1)-218
MNO#: 191
EA Section or other technical document: Environmental Impact Statement
6.4.1.11 Wildlife and Wildlife Habitat
Comment: This section outlines additional potential effects for furbearers during construction that include "direct mortality as a result of human activity (e.g. Vehicular collisions)." However, these potential effects do not appear to be adequately assessed as they were not listed as valued components nor characterized as part of the effects assessment. Instead, the assessment jumps directly to potential mitigation for these potential effects, characterizes the residual effects in a cursory manner and defines a significance rating for them all in the space of 11 lines.
Link to Annex A1: EA(1)-02
EA(1)-03

IR-1 Reference #: AC(1)-219
MNO#: 192
EA Section or other technical document: Environmental Impact Statement
6.4.1.11 Wildlife and Wildlife Habitat
Comment: The section related to furbearer Operations and Closure, again, only contains a very sparse and cursory description of the potential effects before launching into potential mitigation for these potential effects, characterizes the residual effects in a cursory manner and defines a significance rating for them all in the space of 12 lines.
Link to Annex A1: EA(1)-02
EA(1)-03

IR-1 Reference #: AC(1)-220
MNO#: 193
EA Section or other technical document: Environmental Impact Statement
6.4.1.11 Wildlife and Wildlife Habitat
Comment: This section outlines additional potential effects for upland birds during construction that include "direct mortality as a result of human activity, mortality of nesting birds during habitat clearing activities, and vehicular collisions" However, these potential effects do not appear to be adequately assessed as they were not listed as valued components nor characterized as part of the effects assessment. Instead, the assessment jumps directly to potential mitigation for these potential effects, characterizes the residual effects in a cursory manner and defines a significance rating for them all in the space of 13 lines.
Link to Annex A1: EA(1)-02
EA(1)-03

IR-1 Reference #: AC(1)-221
MNO#: 194
EA Section or other technical document: Environmental Impact Statement
6.4.1.11 Wildlife and Wildlife Habitat
Comment: The section related to upland birds Operations and Closure, again, only contains a very sparse and cursory description of the potential effects before launching into potential mitigation for these potential effects, characterizes the residual effects in a cursory manner and defines a significance rating for them all in the space of 12 lines.
Link to Annex A1: EA(1)-02
EA(1)-03

IR-1 Reference #: AC(1)-222
MNO#: 195
EA Section or other technical document: Environmental Impact Statement
6.4.1.11 Wildlife and Wildlife Habitat
Comment: This section outlines additional potential effects for wetland birds during construction that include "direct mortality as a result of human activity, mortality of nesting birds during habitat clearing activities, and vehicular collisions" However, these potential effects do not appear to be adequately assessed as they were not listed as valued components nor characterized as part of the effects assessment. Instead, the assessment jumps directly to potential mitigation for these potential effects, characterizes the residual effects in a cursory manner and defines a significance rating for them all in the space of 13 lines.
Link to Annex A1: EA(1)-02
EA(1)-03

IR-1 Reference #: AC(1)-223
MNO#: 196
EA Section or other technical document: Environmental Impact Statement
6.4.1.11 Wildlife and Wildlife Habitat
Comment: The section related to wetland birds Operations and Closure, again, only contains a very sparse and cursory description of the potential effects before launching into potential mitigation for these potential effects, characterizes the residual effects in a cursory manner and defines a significance rating for them all in the space of 12 lines.
Link to Annex A1: EA(1)-02
EA(1)-03

IR-1 Reference #: AC(1)-224
MNO#: 198
EA Section or other technical document: Environmental Impact Statement
6.4.1.12 Fish and Fish Habitat
Comment: The statement that "[t]he remaining potential effects to fish and fish habitat are considered not to be significant if appropriate mitigation measures are implemented" is problematic for a number of reasons.

First, these remaining potential effects must be described in the EIS. Leaving them out is wholly inappropriate. Once outlined in the EIS, they must then have mitigation applied (which is described in the EIS), the residual effects characterized, and then, and only then can a significance determination be completed.

The assurance of Treasury that this has all occurred is not sufficient and it must be displayed in the EIS.

Particularly, as there will be habitat loss/degradation as part of the Project which can translate into a variety of effects to fish and fish habitat.
Link to Annex A1: FH(1)-06

IR-1 Reference #: AC(1)-225
MNO#: 199, 200
EA Section or other technical document: Environmental Impact Statement
6.4.1.12 Fish and Fish Habitat
Comment: The identification of four potential effects to fish and fish habitat deviates from assessment methodology. Further, if we accept the characterization of effects, the information provided in this section is largely cursory and includes the effect, the mitigation, the residual effect characterization and the significance and monitoring program in the space of a few lines. This does not contain the necessary detail to evaluate the results of the assessment.
Link to Annex A1: FH(1)-16
EA(1)-02
EA(1)-03

IR-1 Reference #: AC(1)-226
MNO#: 201
EIS Guidelines: 11.2 Meaures to address impacts on Aboriginal rights
"This section will describe the measures identified to mitigate the potential adverse impacts of the project described in section 10.2 on the potential or established Aboriginal and Treaty rights and related interests identified in section 9.2 … This description will include a summary of: …efforts undertaken to engage with Aboriginal groups as part of developing the information indentified above."
EA Section or other technical document: Environmental Impact Statement
6.4.1.12 Fish and Fish Habitat
Comment: This section of the EIS specifies that "[w]aterbodies identified as potential candidate sites for the implementation of habitat compensation prescriptions are Thunder Lake, Wabigoon Lake and Thunder Creek."
However, this section contains no detail on engagement of Aboriginal groups in the development of these potential habitat compensation sites.
As Wabigoon Lake is used by MNO, MNO requires consultation on the potential use of the lake as a habitat compensation locale.
Link to Annex A1: FH(1)-06

IR-1 Reference #: AC(1)-227
MNO#: 202
EA Section or other technical document: Environmental Impact Statement
6.4.1.12 Fish and Fish Habitat
Comment: While the catastrophic failure of the TSF is a "highly improbable event", it does not preclude this item from a fulsome assessment. Particularly as Wabigoon Lake is extensively used by MNO in the exercise of their Aboriginal rights and interests and the effects must be adequately quantified.
Link to Annex A1: AM(1)-04

IR-1 Reference #: AC(1)-228
MNO#: 206
EIS Guidelines: 2.3 Aboriginal Consultation
"The proponent will make reasonable efforts to integrate "traditional Aboriginal knowledge" that will contribute to the assessment of environmental impacts."
10.1.3 Effects of Changes to the Environment
"The EIS will describe the effects of any change the project may cause to the environment, with respect to Aboriginal peoples…"
EA Section or other technical document: Environmental Impact Statement
6.4.2.1 Land Use
Comment: At minimum, the land use assessment results should link back to effects on Aboriginal rights and interests. This has not been completed and there is no linkage between Aboriginal interests and land use.
Link to Annex A1: HE(1)-43

IR-1 Reference #: AC(1)-229
MNO#: 210
EA Section or other technical document: Environmental Impact Statement
6.4.2.4 Heritage Resources
Comment: This section does not even characterize effects and instead jumps directly to "potential direct residual effects".
The assumption that, based on a flawed consultation process, no sites of interest or importance exist within the project area is faulty.
Link to Annex A1: HE(1)-47

IR-1 Reference #: AC(1)-230
MNO#: 211
EA Section or other technical document: Environmental Impact Statement
6.4.2.5 Aboriginal Peoples
Comment: Specific detail is required in relation to exceedances of deleterious substances including the type of substance, the levels anticipated of each substance, the predicted effects of the substances on the environment and, finally, the effects of the substances on Aboriginal peoples.
Without this necessary detail it is impossible to properly quantify the potential adverse effects and therefore impossible to apply mitigation.
Link to Annex A1: HE(1)-01

IR-1 Reference #: AC(1)-231
MNO#: 212
EA Section or other technical document: Environmental Impact Statement
6.4.2.5 Aboriginal Peoples
Comment: This section of the EIS refers to the lead exposure of grouse and indicates that "[t]he HQ falls below the risk threshold when the assumption is made that grouse obtain one third rather than one half of their food from plants and soil invertebrates living on the tailings." However, no justification is provided that allows for this adjustment of the data.
On what basis was the grouses' diet reduced?
Link to Annex A1: HE(1)-12

IR-1 Reference #: AC(1)-232
MNO#: 213
EA Section or other technical document: Environmental Impact Statement
6.4.2.5 Aboriginal Peoples
Comment: This section states that "Aboriginal communities have identified the potential impacts of the Project on water as a concern." However, this statement is pan-Aboriginal and does not specify which group(s) has made this statement. To be used as a valued component for study, it should have been a consistent concern, raised by multiple groups and this cannot be evaluated without disaggregation of the information.
Link to Annex A1: AC(1)-01

IR-1 Reference #: AC(1)-233
MNO#: 214
EA Section or other technical document: Environmental Impact Statement
6.4.2.5 Aboriginal Peoples
Comment: The statement in the EIS that "…it is anticipated that the Project will not impact the lake level of Wabigoon Lake or Thunder Lake" requires additional detail to be sufficient as part of the effects assessment, including:

• Definition of temporal boundaries
• Definition of spatial boundaries including a PDA, LAA and RAA
• A description of Analytical Methods
• A description of assumptions and conservative approach
• An outline of the potential effects
• Details about potential mitigation
• Characterization of residual effects, including a residual effects classification
• A determination of significance of residual effects
• Details of confidence and risk
• Outline of follow-up monitoring, if applicable

Link to Annex A1: EA(1)-01
EA(1)-02
EA(1)-03
EA(1)-04
EA(1)-05
EA(1)-06
EA(1)-07
EA(1)-08
EA(1)-09

IR-1 Reference #: AC(1)-234
MNO#: 215
EIS Guidelines: 10.1.3 Effects of Changes to the Environment
"The EIS will describe the effects of any change the project may cause to the environment, with respect to Aboriginal peoples…"
EA Section or other technical document: Environmental Impact Statement
6.4.2.5 Aboriginal Peoples
Comment: This section largely just repeats conclusions from other sections of the EIS and does not endeavor to actually relate the information to Aboriginal peoples.
Link to Annex A1: HE(1)-38
HE(1)-43

IR-1 Reference #: AC(1)-235
MNO#: 216
EA Section or other technical document: Environmental Impact Statement

6.4.2.5 Aboriginal Peoples
Comment: This section states that "Aboriginal communities have expressed concern that the Project could adversely impact their ability to gather plants and berries." However, this statement is pan-Aboriginal and does not specify which group(s) has made this claim. To be used as a valued component for study, it should have been a consistent concern, raised by multiple groups and this cannot be evaluated without disaggregation of the information.
Link to Annex A1: HE(1)-43

IR-1 Reference #: AC(1)-236
MNO#: 217
EA Section or other technical document: Environmental Impact Statement
6.4.2.5 Aboriginal Peoples
Comment: The continued focus on three plant species for consideration in the EIS is inappropriate and does not take into account the specific species used by MNO in the exercise of their rights.
Link to Annex A1: AC(1)-01
HE(1)-45

IR-1 Reference #: AC(1)-237
MNO#: 218
EA Section or other technical document: Environmental Impact Statement
6.4.2.5 Aboriginal Peoples
Comment: The statement that "Upon closure of the Project this site will be available to the public and First Nation communities" does not alleviate any potential adverse impact to chanterelle picking. As project closure is set to occur in the far future, there will still be generational effects to MNO gathering in the region that must be considered.
Link to Annex A1: HE(1)-43

IR-1 Reference #: AC(1)-238
MNO#: 219
EA Section or other technical document: Environmental Impact Statement
6.4.2.5 Aboriginal Peoples
Comment: This section states that "Potential impacts to hunting, trapping and fishing that could result from the Project have been identified by Aboriginal communities as a concern" However, this statement is pan-Aboriginal and does not specify which group(s) has made this claim. To be used as a valued component for study, it should have been a consistent concern, raised by multiple groups and this cannot be evaluated without disaggregation of the information.
Link to Annex A1: HE(1)-43
AC(1)-01

IR-1 Reference #: AC(1)-239
MNO#: 220
EIS Guidelines: 10.1.3 Effects of Changes to the Environment
"The EIS will describe the effects of any change the project may cause to the environment, with respect to Aboriginal peoples…"
EA Section or other technical document: Environmental Impact Statement
6.4.2.5 Aboriginal Peoples
Comment: Effects to hunting and trapping have not been described or characterized beyond the availability of Crown land. This does not take into account the particulars of the experience of hunting such as air quality, noise, light, etc.
Further, no mitigation has been proposed and the application of criteria on this threadbare assessment is wholly inappropriate.
Link to Annex A1: HE(1)-38

IR-1 Reference #: AC(1)-240
MNO#: 221
EIS Guidelines: 10.1.3 Effects of Changes to the Environment
"The EIS will describe the effects of any change the project may cause to the environment, with respect to Aboriginal peoples…"
EA Section or other technical document: Environmental Impact Statement
6.4.2.5 Aboriginal Peoples
Comment: The assessment of fishing wholly relies on previously assessed criteria and does not take into account the actual activity of fishing and the potential impacts of the same.
Link to Annex A1: FH(1)-06
CE(1)-02

IR-1 Reference #: AC(1)-241
MNO#: 222
EIS Guidelines: 10.2 Adverse Impacts on Aboriginal and Treaty Rights and Related Interests
"The assessment of the potential adverse impacts of each of the project components and physical activities, in all phases, will be based on a comparison of the exercise of the identified rights between the predicted future conditions with the project and the predicted future conditions without the project. It is recommended that the impact matrix methodology described in section 10.1.1 be adapted for this purpose."
Comment: There is no assessment completed of the potential adverse impacts of each of the project components and physical activities.
Further, the impact matrix was not adapted for this purpose.
Link to Annex A1: HE(1)-43
EA(1)-02

IR-1 Reference #: AC(1)-242
MNO#: 223
EIS Guidelines: 7.2.1 Spatial Boundaries
"The EIS will clearly indicate the spatial boundaries to be used in assessing the potential adverse environmental effects of the proposed project and provide a rationale for each boundary. It is recognized that the spatial boundaries for each VC may not be the same."
EA Section or other technical document: Environmental Impact Statement
7.2.1 Spatial and Temporal Scale
Comment: While this section references a LSA and RSA for the cumulative effects assessment, it is not specifically described, nor is a figure present which represents this.
Link to Annex A1: CE(1)-01

IR-1 Reference #: AC(1)-243
MNO#: 224
EIS Guidelines: 9.2 Potential or established Aboriginal or treaty rights and Related Interests
"At a minimum, the EIS will summarize available information on the potential or established Aboriginal and Treaty rights and related interests of the named Aboriginal groups that have the potential to be adversely impacted by the project. As part of this summary, the EIS will include for each Aboriginal group:

• Background information and a map of the group's traditional territory;
• A summary engagement activities conducted prior to the submission of the EIS…
• Information on each group's potential or established rights (including geographical extent, nature, frequency, timing) including maps and data sets (e.g. fish catch numbers) when this information is provided to the proponent;
• An overview of key comments and concerns provided by each group to the proponent;
• An overview of key comments and concerns provided by each group to the proponent;
• Responses provided by government and/or the proponent, as appropriate; and
• Planned future engagement activities

EA Section or other technical document: 8.0 Aboriginal and Public Engagement
Comment: Section 8.0 of the EIS contains none of this information in relation to the MNO or any other Aboriginal group.
Appendix DD: Aboriginal Consultation Report contains some of these required details with regards to the MNO. However information on: Background information and a map of the group's traditional territory, and Information on each group's potential or established rights (including geographical extent, nature, frequency, timing) including maps and data sets (e.g. fish catch numbers) when this information is provided to the proponent is not included.
Link to Annex A1: HE(1)-38

IR-1 Reference #: AC(1)-244
MNO#: 225
EA Section or other technical document: 8.0 Aboriginal and Public Engagement
Comment: The layout of the section is confusing as it jumps between Aboriginal and public consultation and concerns throughout. The requirements for consultation and the rights held by Aboriginal groups are separate and unique and should have a different treatment in the EIS than the general public.

IR-1 Reference #: AC(1)-245
MNO#: 226
EIS Guidelines: 2.3 Aboriginal consultation
"One of the purposes of CEAA, 2012 is to promote communication and cooperation with Aboriginal peoples, including First Nation, Inuit and Métis. To work toward this goal, the proponent will ensure that it engages with Aboriginal people….as early as possible in the project planning process. The proponent is strongly encourages to work with Aboriginal groups in establishing an engagement approach."
EA Section or other technical document: 8.0 Aboriginal and Public Engagement
8.1 Introduction
Comment: The EIS states that "A key challenge and opportunity in the Aboriginal and public participation process is the timing around when and what type of information is provided…..providing information that is incomplete, too detailed, or presenting of options that are impractical or unrealistic may result in confusion."
This paragraph reads like Treasury is attempting to excuse a poor consultation process by indicating that it's difficult. A meaningful consultation process begins early, even when a proponent is in planning stages and may only have "incomplete information," this allows time for stakeholders and Aboriginal groups to have input and influence the project planning and design.
Link to Annex A1: AC(1)-01

IR-1 Reference #: AC(1)-246
MNO#: 227
EA Section or other technical document: 8.0 Aboriginal and Public Engagement
8.1 Introduction
Comment: The EIS states that "Treasury anticipates that with the submission of this EIS, virtually all of the outstanding questions that were raised at public meetings and other events in the years previously noted have now been answered."
MNO has not been meaningfully engaged by Treasury on this project. This is due to the lack of agreement by Treasury to fund the activities (e.g. a TLKUS) necessary for MNO to gather and understand the questions, issues and concerns that MNO citizens have about the proposed Project. Therefore, MNO has many outstanding concerns about the Project. Many of these concerns are reflected in the comments on the EIS; however the EIS comments are not the totality of MNO concerns.
Link to Annex A1: AC(1)-01

IR-1 Reference #: AC(1)-247
MNO#: 228
EIS Guidelines: 9.2 Potential or established Aboriginal or treaty rights and Related Interests
"For the purposes of developing the EIS, the proponent will engage with Aboriginal groups whose potential or established Aboriginal rights and Treaty rights and related interests may be affected by the project which include at a minimum the following groups:
….
- Métis Nation of Ontario"
EA Section or other technical document: 8.0 Aboriginal and Public Engagement
8.3.3 Aboriginal Communities
Comment: The EIS states "There are a number of Aboriginal communities that have expressed an interest in the Project."
MNO has not just expressed an interest in the Project, MNO has Aboriginal rights in the area where the Project is proposed and the Crown (both CEAA and MNDM) have directed Treasury to consult with the MNO.
Link to Annex A1: AC(1)-01

IR-1 Reference #: AC(1)-248
MNO#: 229
EA Section or other technical document: 8.0 Aboriginal and Public Engagement
8.3.3 Aboriginal Communities
Comment: There is an error in the sentence "Treasury's efforts to consult with Aboriginal communities are presented in Appendix V…." Appendix V is the Public Engagement report.

IR-1 Reference #: AC(1)-249
MNO#: 230
EIS Guidelines: 3.3 Integration of EA, Aboriginal and public consultation information
"The proponent will ensure that public and Aboriginal concerns are well documented in the EIS."
EA Section or other technical document: 8.0 Aboriginal and Public Engagement
8.5 Aboriginal Consultation Information
Comment: This section of the EIS outlines comments and questions received from Aboriginal groups about the Project. These were presented in an aggregated format. MNO requires disaggregated information in order to adequately assess whether MNO involvement was adequate.
CEAA has previously requested proponents provide disaggregated information for consideration.
Specifically, as part of the correspondence in reference to the Pacific NorthWest LNG Ltd. Assessment (Reference Number 80032) CEAA specified that "Without the benefit of disaggregating by each Aboriginal group, for each factor considered under 5(1)(c), including related baseline information, it is difficult for the Agency to determine if enough detail exists to effectively assess the potential for significant adverse environmental effect that could potentially impact Aboriginal peoples. In other words, the conclusions regarding impacts on 5(1)(c) and Aboriginal rights contained in the EIS cannot be confidently relied upon without the benefit of a thorough understanding of the information used to support the conclusion."
Link to Annex A1: AC(1)-01

IR-1 Reference #: AC(1)-250
MNO#: 231
EIS Guidelines: 3.3 Integration of EA, Aboriginal and public consultation information
"In preparing the EIS, the proponent is encouraged to integrate Aboriginal and public consultation outcomes into the consideration and mitigation of environmental effects at the appropriate EA analytical steps…"
EA Section or other technical document: 8.0 Aboriginal and Public Engagement
8.5 Aboriginal Consultation Information
Comment: The EIS indicated "Baseline studies relating to all of the above noted concerns have been completed. Measures contemplated to address these concerns are included as part of this EIS."

Please provide a reference to which baselines studies are related to which concerns. Additionally, provide reference to which measures address the noted concerns.
Link to Annex A1: AC(1)-01

IR-1 Reference #: AC(1)-251
MNO#: 232
EIS Guidelines: 3.3 Integration of EA, Aboriginal and public consultation information
"In preparing the EIS, the proponent is encouraged to integrate Aboriginal and public consultation outcomes into the consideration and mitigation of environmental effects at the appropriate EA analytical steps…"
EA Section or other technical document: 8.0 Aboriginal and Public Engagement
8.6 Participants in the Environmental Assessment
Comment: This section of the EIS does not describe "Participants in the Environmental Assessment" rather; it merely provides a listing of public communities and events where the Project was discussed.
Please provide a description of how consultation influenced the design and execution of the EIS.
Link to Annex A1: PC(1)-01

IR-1 Reference #: AC(1)-252
MNO#: 233
EIS Guidelines: 3.3 Integration of EA, Aboriginal and public consultation information
"The proponent will ensure that public and Aboriginal concerns are well documented in the EIS."
EA Section or other technical document: 8.0 Aboriginal and Public Engagement
8.9 Aboriginal Concerns
Comment: Again, this section of the EIS is not specific to any Aboriginal group. It lists aggregated concerns making it very difficult, if not impossible, to determine what concerns were collected from MNO.
MNO requires disaggregated information in order to adequately assess whether MNO involvement was adequate.
CEAA has previously requested proponents provide disaggregated information for consideration.
Specifically, as part of the correspondence in reference to the Pacific NorthWest LNG Ltd. Assessment (Reference Number 80032) CEAA specified that "Without the benefit of disaggregating by each Aboriginal group, for each factor considered under 5(1)(c), including related baseline information, it is difficult for the Agency to determine if enough detail exists to effectively assess the potential for significant adverse environmental effect that could potentially impact Aboriginal peoples. In other words, the conclusions regarding impacts on 5(1)(c) and Aboriginal rights contained in the EIS cannot be confidently relied upon without the benefit of a thorough understanding of the information used to support the conclusion."
Link to Annex A1: AC(1)-01

IR-1 Reference #: AC(1)-253
MNO#: 234
EIS Guidelines: 3.3 Integration of EA, Aboriginal and public consultation information
"In preparing the EIS, the proponent is encouraged to integrate Aboriginal and public consultation outcomes into the consideration and mitigation of environmental effects at the appropriate EA analytical steps…"
EA Section or other technical document: 8.0 Aboriginal and Public Engagement
8.9.1 Measures to Address Aboriginal Concerns
Comment: The EIS states that "The detail as to how Aboriginal concerns are to be addressed is included throughout the EIS." Please provide a reference as to where in the EIS this detail is located. Without this information MNO cannot assess whether concerns are addressed in the EIS.
Link to Annex A1: AC(1)-01

IR-1 Reference #: AC(1)-254
MNO#: 235
EA Section or other technical document: 8.0 Aboriginal and Public Engagement
8.9.1 Measures to Address Aboriginal Concerns
Comment: In relation to Treasury's commitment to installing a monitoring plan for groundwater resources, the EIS indicates that "Termination of the program will be expected following full review of data collection by regulatory authorities."
If this project proceeds, MNO requires ongoing monitoring of groundwater resources throughout the life of the Project.

IR-1 Reference #: AC(1)-255
MNO#: 236
EIS Guidelines: 3.4.2 Community knowledge and Aboriginal traditional knowledge
"The proponent will incorporate into the EIS the community and Aboriginal traditional knowledge to which it has access or that is acquired though Aboriginal engagement activities…"
EA Section or other technical document: 8.0 Aboriginal and Public Engagement
8.9.1 Measures to Address Aboriginal Concerns
Comment: In response to concerns about "potential impacts on land use such as hunting, trapping, and other traditional land uses: the EIS states that "The development of the Project is not anticipated to adversely impact the rights of Aboriginal peoples to hunt within the project area."
Please provide a reference to the section of the EIS where this assessment and conclusions are located. What information from MNO was used in the determination?
Link to Annex A1: HE(1)-43

IR-1 Reference #: AC(1)-256
MNO#: 237
EA Section or other technical document: 8.0 Aboriginal and Public Engagement
8.9.1 Measures to Address Aboriginal Concerns
Comment: In response to concerns about "potential impacts on land use such as hunting, trapping, and other traditional land uses:, the EIS states that "Treasury has made concerted effort to place mine infrastructure...on private properties and thereby reduce potential impacts to Crown lands."
Locating the Project partially on private lands does not negate the requirement to assess the impacts on the exercise of Aboriginal rights. MNO requires an assessment of Project impacts on Métis rights in within a Regional Study Area as well as information on how much previously unoccupied Crown land will be taken up by the proposed Project.
Link to Annex A1: HE(1)-43

IR-1 Reference #: AC(1)-257
MNO#: 238
EIS Guidelines: 3.4.2 Community knowledge and Aboriginal traditional knowledge
"The proponent will incorporate into the EIS the community and Aboriginal traditional knowledge to which it has access or that is acquired though Aboriginal engagement activities…"
EA Section or other technical document: 8.0 Aboriginal and Public Engagement
8.9.1 Measures to Address Aboriginal Concerns
Comment: Additional detail is required to support the claim that "Trapping on Crown lands in the vicinity of the Project site will not be altered as a result of the development of the Goliath Gold Mine."
What assessment was undertaken to reach this conclusion? What information from MNO was used in the determination?
Link to Annex A1: HE(1)-43

IR-1 Reference #: AC(1)-258
MNO#: 239
EIS Guidelines: 3.4.2 Community knowledge and Aboriginal traditional knowledge
"The proponent will incorporate into the EIS the community and Aboriginal traditional knowledge to which it has access or that is acquired though Aboriginal engagement activities…"
EA Section or other technical document: 8.0 Aboriginal and Public Engagement
8.9.1 Measures to Address Aboriginal Concerns
Comment: In response to concerns about "potential impacts on land use such as hunting, trapping, and other traditional land uses:, the EIS states that "Concerns have been identified relating to the provision outlined in section 35 of the Constitution Act (1982), which provides for the protection of Aboriginal rights. The opportunity to practice section 35 harvesting rights in the general area of the Project will continue."
Please provide a reference to the section of the EIS where this assessment and conclusions are located. What information from MNO was used in the determination?
Additionally, even if the exercise of rights may continue in the project vicinity, this does not negate the fact that the exercise of rights will no longer be possible on new areas of previously unoccupied Crown lands that will be taken up by the Project.
Link to Annex A1: HE(1)-38,
HE(1)-43

IR-1 Reference #: AC(1)-259
MNO#: 240
EIS Guidelines: 3.4.2 Community knowledge and Aboriginal traditional knowledge
"The proponent will incorporate into the EIS the community and Aboriginal traditional knowledge to which it has access or that is acquired though Aboriginal engagement activities…"
EA Section or other technical document: 8.0 Aboriginal and Public Engagement
8.9.1 Measures to Address Aboriginal Concerns
Comment: In response to the concerns about "Potential impacts on gathering plants and berries", the EIS states that "Blueberries are one type of berry known to be of interest to First Nations and other Aboriginal people. No specific areas associated with the Project have been identified as areas from which blueberries have been gathered."
MNO objects to the characterization that no areas have been identified in the project vicinity, this conclusion is premature. MNO has, on numerous occasions, requested capacity to document information related to the exercise of Métis rights, to no avail.
Treasury has willfully and knowingly proceeded with its project development without the collection of MNO TLUS and has proceeded with the Project application without fulsome consultation with the MNO.
Blueberries, while potentially representative of some berry types, cannot be used as a substitute for all berry types within the vicinity of the Project. MNO gathers many varieties of berries and their exclusion from consideration in the assessment highlights the deficiency of the report.
Link to Annex A1: HE(1)-38
HE(1)-43

IR-1 Reference #: AC(1)-260
MNO#: 241
EA Section or other technical document: 8.0 Aboriginal and Public Engagement
8.9.1 Measures to Address Aboriginal Concerns
Comment: In relation to a concern about "Potential impact from flooding and weather related disasters" the EIS states that "Treasury does not have the expertise to comment on the causes of climate change and weather patterns." However, it is Treasury's responsibility to procure the necessary expertise to address all issues and concerns raised as part of the EIS application process.
Not having the expertise does not remove the issue.
Link to Annex A1: EE(1)-06

IR-1 Reference #: AC(1)-261
MNO#: 242
EA Section or other technical document: 8.0 Aboriginal and Public Engagement
8.9.1 Measures to Address Aboriginal Concerns
Comment: In the response to concerns about "Potential access restrictions" the EIS states that: "…the impact on access to Treaty 3 lands will be small." Please provide a reference to the section of the EIS where this assessment and conclusions are located.
As MNO has not completed a TLUS, the scope and extent of their trails and travelways cannot be quantified in the Project area. This section does not consider this or make provisions for the potential information.
Link to Annex A1: HE(1)-38
HE(1)-44

IR-1 Reference #: AC(1)-262
MNO#: 243
EIS Guidelines: 3.4.2 Community knowledge and Aboriginal traditional knowledge
"The proponent will incorporate into the EIS the community and Aboriginal traditional knowledge to which it has access or that is acquired though Aboriginal engagement activities…"
EA Section or other technical document: 8.0 Aboriginal and Public Engagement
8.9.1 Measures to Address Aboriginal Concerns
Comment: In response to concerns about "Potential impacts from noise associated with the Project site" the EIS indicates that mitigation measures may include "timing of blasting in open pit to limit noise and vibration to home owners" as well as "Blasting undertaken at the mine site will be conducted in a manner that will not result in impacts to private properties…"
These mitigation measures are focused on property owners rather than Aboriginal rights holders. It fails to consider the potential impacts of Project noise on Aboriginal harvesters who may be in the project vicinity. The EIS also fails entirely in considering the effect of blasting on the exercise of rights, and on the wildlife that harvesters depend on, within the regional study area.
Link to Annex A1: HE(1)-01
HE(1)-43
HE(1)-45

IR-1 Reference #: AC(1)-263
MNO#: 244
EA Section or other technical document: 8.0 Aboriginal and Public Engagement
8.9.1 Measures to Address Aboriginal Concerns
Comment: In response to concerns about mine closure plans, the EIS states that "Treasury has assured Aboriginal communities that the closure plan details will be vetted by Provincial representatives and qualified consultation firms will provide details in clear and transparent fashion."
This assurance is not enough; MNO requires consultation on the development and implementation of any Project closure plan developed by Treasury.

IR-1 Reference #: AC(1)-264
MNO#: 245
EIS Guidelines: 3.4.2 Community knowledge and Aboriginal traditional knowledge
"The proponent will incorporate into the EIS the community and Aboriginal traditional knowledge to which it has access or that is acquired though Aboriginal engagement activities…"
EA Section or other technical document: 8.0 Aboriginal and Public Engagement

8.9.1 Measures to Address Aboriginal Concerns
Comment: In response to the concerns regarding "Potential impacts to property values in the vicinity of the mine" the EIS indicates that the changes to property values will be minimal.
Please provide a reference to the section of the EIS where this assessment and conclusions are located. What information from MNO was used in the determination? For example, are MNO Citizens homeowners or renters in the Project vicinity and how the Project will impact those citizens?
Link to Annex A1: HE(1)-35

IR-1 Reference #: AC(1)-265
MNO#: 246
EA Section or other technical document: 8.0 Aboriginal and Public Engagement
8.9.2 Proponent Commitments
Comment: This section has 2 commitments listed then refers to additional commitments in the Commitment Registry.
At a minimum, this section should describe any commitments made is response to the Concerns from Aboriginal Groups.
Link to Annex A1: EA(1)-09

IR-1 Reference #: AC(1)-266
MNO#: 247
EIS Guidelines: 3.3 Integration of EA, Aboriginal and public consultation information
"The proponent will ensure that public and Aboriginal concerns are well documented in the EIS."
EA Section or other technical document: 8.0 Aboriginal and Public Engagement
8.9.3 Outstanding Aboriginal and Public Concerns
Comment: MNO has not been meaningfully engaged by Treasury on this project. This is due to the lack of agreement by Treasury to fund the activities (e.g. a TLKUS) necessary for MNO to gather and understand the questions, issues and concerns that MNO citizens have about the proposed Project. Therefore, MNO has many outstanding concerns about the Project. Many of these concerns are reflected in the comments on the EIS; however the EIS comments are not the totality of MNO concerns.
Link to Annex A1: HE(1)-38
AC(1)-01

IR-1 Reference #: AC(1)-267
MNO#: 248
EA Section or other technical document: Environmental Impact Statement
Table 10.1.1 Changes to the Project Since Initially Proposed
Comment: Please provide additional detail on the thresholds used to reach the conclusions that there would be reduced potential effects to Aboriginal rights by placing the freshwater make-up system on more private versus crown land. What is the threshold of impact?
Link to Annex A1: EA(1)-03

IR-1 Reference #: AC(1)-268
MNO#: 249
EA Section or other technical document: Appendix DD: Aboriginal Consultation Report
DD.2 Project Details
Comment: This section indicates that the Ministry of Northern Development and Mines has delegated procedural aspect of consultation to Treasury in relation to the requirements of a Mine Closure Plan as outlined in Regulation 240-00.
Has the Ministry of the Environment and Climate Change provided any similar direction with regards to the provincial Environmental Assessment process?

IR-1 Reference #: AC(1)-269
MNO#: 250
EA Section or other technical document: Appendix DD: Aboriginal Consultation Report
DD.2 Project Details
Comment: The EIS indicates that "An Aboriginal Consultation Plan related to Treasury's Goliath Gold Project was submitted to the Ministry of Northern Development and Mines on July 3, 2013." Additionally, "…an ‘Interim' Aboriginal Consultation report was prepared and submitted to the Ontario Ministry of Northern Development and Mines on May 12, 2014."
MNO requests copies of the plan and the interim report as well as any further Aboriginal consultation reports that are filed by Treasury.

IR-1 Reference #: AC(1)-270
MNO#: 251
EA Section or other technical document: Appendix DD: Aboriginal Consultation Report
DD.2 Project Details
Comment: The EIS states "Treasury analysis indicated that the Goliath Gold Project will provide substantial benefits to the people of Northwestern Ontario, including First Nations and Aboriginal communities in the immediate area of the project…"
Please provide a reference to where this analysis can be found in the EIS. MNO also requests additional detail about what the specific benefits will be for MNO citizens.
Link to Annex A1: HE(1)-35

IR-1 Reference #: AC(1)-271
MNO#: 252
EA Section or other technical document: Appendix DD: Aboriginal Consultation Report
DD.2.1 History of the Goliath Gold Project
Comment: This sections notes that "there are only a few small parcels of Crown land associated with the Goliath Project."
The EIS repeatedly relies on the location of the proposed Project as being partially on private lands to minimize the requirement to assess the impacts on the exercise of Aboriginal rights. MNO requires an assessment of Project impacts on Métis rights within a Regional Study Area as well as information on how much previously unoccupied Crown land will be taken up by the proposed Project.
Link to Annex A1: HE(1)-38
HE(1)-43

IR-1 Reference #: AC(1)-263
MNO#: 253
EIS Guidelines: 3.4.2 Community knowledge and Aboriginal traditional knowledge
"The proponent will incorporate into the EIS the community and Aboriginal traditional knowledge to which it has access or that is acquired though Aboriginal engagement activities…"
EA Section or other technical document: Appendix DD: Aboriginal Consultation Report
DD.2.1 History of the Goliath Gold Project
Comment: This section states "Treasury Metals does recognize that potential adverse impacts from mine development may not be limited specifically to the actual mine site. Potential adverse impacts to water and air quality away from the mine site and which may in turn have adverse impacts on Aboriginal and Treaty Rights have been raised as a concern."
MNO shares this concern that there may be regional effects on the exercise of Métis rights. Please provide a reference to where this is assessed in the EIS.

Additionally, this concern about regional effects is not just limited to water and air quality. The potential for regional effects to wildlife and Métis harvesters from Project noise (e.g. blasting on a near daily basis) is also a concern.
Link to Annex A1: HE(1)-43

IR-1 Reference #: AC(1)-272
MNO#: 254
EA Section or other technical document:
Appendix DD: Aboriginal Consultation Report
DD.2.1 History of the Goliath Gold Project
Comment: In reference to the private lands on which the Project is located, this section states "….any impacts to Aboriginal and Treaty rights associated with their removal from the Treaty 3 land base would have been experienced at time of their original removal. Developing a mine on these privately owned properties does not present a new impact to Aboriginal and Treaty Rights. The few parcels of Crown land that are associated with the Project are by and large small in size and surrounded by private properties."
Firstly, there are new Crown lands taken up for the purposes of the is Project that Treasury continually minimizes and has not provided detailed information about how much Crown land the Project will take up.
Secondly, the land use and associated regional environmental effects of a mine is different than the current use of this private land (e.g. tree farm and homes) and therefore the conclusion that there are no new effects is premature and not based on sound environmental assessment methodology.
Link to Annex A1:
HE(1)-38
HE(1)-43

IR-1 Reference #: AC(1)-273
MNO#: 255
EA Section or other technical document:
Appendix DD: Aboriginal Consultation Report
DD.2.1 History of the Goliath Gold Project
Comment: The section makes the following assumption: "As the traditional means of travel by Aboriginal peoples was along waterways it is logical that most sites that are of significance to Aboriginal people are to be found in close proximity to lakes, rivers or navigable streams. The Goliath site is not immediately adjacent to such water bodies."
While, many sites may be located in proximity to water bodies it is faulty logic to assume that there are no sites of importance to Aboriginal peoples if there is no water. Additionally, the assumption ignores the fact the Aboriginal and treaty rights are exercised today and harvesters use many different modes of travel including cars, trucks and ATVs.
Link to Annex A1:
HE(1)-38

IR-1 Reference #: AC(1)-274
MNO#: 256
EA Section or other technical document:
Appendix DD: Aboriginal Consultation Report
DD.2.1 History of the Goliath Gold Project
Comment: Please provide a reference to the section of the EIS that supports the following conclusion: "…it is a reasonable assumption that any significant adverse impacts to Aboriginal rights in the area would have been experienced through these various project developments. On-site Impacts to Aboriginal and treaty rights resulting from the development of the Goliath Gold Mine are expected to be low."
Link to Annex A1:
HE(1)-38
HE(1)-43

IR-1 Reference #: AC(1)-275
MNO#: 257
EIS Guidelines: 3.3 Integration of EA, Aboriginal and public consultation information
"The proponent will ensure that public and Aboriginal concerns are well documented in the EIS."
EA Section or other technical document:
Appendix DD: Aboriginal Consultation Report
DD.5.7.3 Concerns identified by the Métis Nation of Ontario
Comment: MNO has more concerns with the Project than was is documented in this section; however, due to lack of capacity the MNO has not been able to meaningfully engage MNO citizens to fully understand Project-related issues and concerns.
This is due to the lack of agreement by Treasury to fund the activities (e.g. a TLKUS) necessary for MNO to gather and understand the questions, issues and concerns that MNO citizens have about the proposed Project. Therefore, MNO has many outstanding concerns about the Project. Many of these concerns are reflected in the comments on the EIS; however the EIS comments are not the totality of MNO concerns.
Link to Annex A1:
AC(1)-01

IR-1 Reference #: AC(1)-276
MNO#: 258
EIS Guidelines: 3.4.2 Community knowledge and Aboriginal traditional knowledge
"The proponent will incorporate into the EIS the community and Aboriginal traditional knowledge to which it has access or that is acquired though Aboriginal engagement activities…"
EA Section or other technical document:
Appendix DD: Aboriginal Consultation Report
DD.6 Next Steps in Aboriginal Consultation
Comment: This section indicates that one next step is to "Implement Traditional Knowledge Studies with the Métis Nation of Ontario…"
MNO agrees that this is an important step in the consultation process; however, please provide more information on how the information contained in the TKLUS will be used to identify potential impacts on MNO citizens since the EIS has been completed and filed with the regulator?
Link to Annex A1:
EA(1)-01
HE(1)-38

IR-1 Reference #: AC(1)-277
MNO#: 259
EA Section or other technical document:
Appendix DD: Aboriginal Consultation Report
DD.6 Next Steps in Aboriginal Consultation
Comment: This section states that next steps also include "Continue to pursue mutually beneficial long-term agreements with interested First Nations and Aboriginal communities" and "Keep First Nations and Aboriginal Communities informed of potential employment and business opportunities."
Please provide additional details on how Treasury will implement these next steps specifically with the MNO.

IR-1 Reference #: AC(1)-278
MNO#: 260
EIS Guidelines: 3.2 Study Strategy and methodology

"In describing methods, the proponent will document how it used … traditional and local knowledge to reach its conclusions."
EA Section or other technical document:
Environmental Impact Statement
Appendix G Environmental Baseline Study
Comment: There is no mention of traditional and local knowledge in the description of methods for any of the baseline studies, including:

• Climate
• Hydrology
• Surface water quality
• Hydrogeology
• Soils
• Geochemistry
• Wildlife
• Vegetation
• Fish and Aquatic resources
• Sediment

Link to Annex A1: EA(1)-01

IR-1 Reference #: AC(1)-279
MNO#: 261
EIS Guidelines: 3.4.2 Community Knowledge and Aboriginal Traditional Knowledge
"The proponent will incorporate into the EIS the community and Aboriginal knowledge to which it has access or that is acquired through Aboriginal engagement activities."
EA Section or other technical document:
Environmental Impact Statement
Appendix G Environmental Baseline Study
Comment: As the baseline environment study was completed prior to engagement with the MNO, no opportunity was provided for MNO to provide information for incorporation into this study.
Link to Annex A1:
AC(1)-01
Link to Annex A1
Aboriginal Consultation for the Project- Consultation Protocol

Table 3 - Agency Disposition of Written Comments Submitted by Eagle Lake First Nation on the Environmental Impact Statement (Report prepared by ICA Associates Inc.)

IR-1 Reference #: AC(1)-280
Page #: 4,5
Section 5 Concern/EA Process Item: Aboriginal consultation
Comment: The proposed Goliath Gold Mine Project has the potential to infringe on Treaty Rights. The contact with First Nations upon whose traditional land where the mine is anticipated to be built, is described in the EIS Summary in Chapter 9.0 Aboriginal Engagement in the full EIS in Chapter 9.0 Aboriginal and Public Engagement and in Appendix DD and Appendix V.
In Appendix DD Treasury Metals Inc. States that, "Developing a mine on these privately owned properties does not present a new impact to Aboriginal and Treaty rights… The proponent then goes on to state "Treasury Metals does recognize that potential adverse impacts from mine development may not be limited specifically to the actual mine site. Potential adverse impacts to water and air quality away from the mine site and which may in turn have adverse impacts on Aboriginal and Treaty rights have been raised as a concern.
Section 35 of the Canadian Constitution Act (1982) recognizes and affirms existing  " Aboriginal and treaty rights"  It is firmly entrenched in case law that governments have a duty  "to consult and accommodate"  indigenous peoples whenever they take a decision that could infringe on their rights. In 2010 Canada endorsed the United Nations Declaration on the Rights of Indigenous Peoples (UNDRIP, 2007). The United Nations Declaration on the Rights of Indigenous Peoples states:
a. Indigenous peoples have the right to the conservation and protection of the environment and the productive capacity of their lands or territories and resources (Article 29(1)); and
b. Indigenous peoples have the right to determine and develop priorities and strategies for the development or use of their lands or territories and other resources (Article 32(1)); 

To have informed consent indigenous peoples must receive adequate information in order to fully understand the positives and negatives consequences of pending decisions and must be
Able make decisions according to their own processes.
ELFN is concerned that Grand Council Treaty #3 has not been directly involved early enough in the process; i.e., at the prospecting stage of this project. Eagle Lake FN subscribes to the Great Earth Law (Manito Aki Inakonigaawin) and has developed Principles for Consultation for the People of Migisi Sahgaigan (2011). ELFN's consultation policy was developed as a result responding to advanced exploration projects and abandoned mines on their lands. When a proponent enters Treaty #3 Territory they must come to an agreement with the Grand Council. In turn, the proponent must negotiate with the Grand Council and in turn the Grand Council Will determine the communities to be consulted.
ELFN explains its consultation process on their official website and sets out the terms on which consent might be based (ELFN, 2015).

"The following Principles of Consultation are mandatory for meaningful consultation based on Anishinaabe traditions and practices:

• Give direction to achieve a wise result and healing through informed consent
• Everyone's views are listened to, consequences (costs) have been considered and a decision is made based on consensus
• Be careful in our decision making, our actions, interactions, and to consider everyone, everything, past, present and future
• We will have a clear understanding of all facts, impacts and future costs
• There is a procedure to make things right as part of decision making
• There is an order or way of doing things
• See things clearly, to be transparent, an openness of procedures, actions and decisions
• Show respect to those who have knowledge i.e. Elder

General Principles for Meaningful Consultation with the people of Eagle Lake:

• The Declaration will be understood and respected
• Government is required to consult with and accommodate our community in good faith  with clear intent of the proposed activities
• Consultation procedures will be guided by mutually acceptable protocols, plans and timelines and the objectives and scope clearly laid out to our community before consultation begins and before decisions are made
• Adequate financial, human and expert resources will be made available to our community through the Government or the proponent
• Consultations will strengthen our people to state the value of the land and decisions will be based on consensus
• We will be informed as to what changes will take place
• Consultations will meaningfully support our land use plan and provide adequate time to consider all objectives and questions and will be conducted through mutual respect
• Where there are disagreements, the proponent will be responsible, or through third party mediation if deemed necessary. The proponent is still responsible for the costs."

The community of Eagle Lake has yet to give its consent to this project and the consultation protocol developed by Eagle Lake First Nation has yet to be implemented in regards to this project.
Link to Annex A1:
AC(1)-01
EA(1)-01
HE(1)-38
HE(1)-43

Aboriginal Consultation for the Project-Outstanding Community Concerns-Eagle Lake First Nation (ELFN)

IR-1 Reference #: AC(1)-281
Page #: 5
Section 5 Concern/EA Process Item: Aboriginal consultation
Comment: On May 3rd 2015, ICA Associates Inc. completed a community workshop to identify and outline the concerns that have not yet been addressed by Treasury Metals according to community members. There were 18 community members present ranging from the age of 16 to 70. There were several Elders and youth present at the workshop. The following table is documentation from the community workshop.

IR-1 Reference #: AC(1)-282
Page #: 6
Section 5 Concern/EA Process Item: Aboriginal consultation
Comment: Concerned that the consultation process was limited
The duty to consult process overlooked
Medicines will be contaminated. ELFN has not provided any traditional knowledge to Treasury Metals.
Concerned that that Treasury Metals has not consulted Grand Council Treaty #3
Are they going to listen to us? Concerned that consultation doesn't matter
Link to Annex A1:
EA(1)-01
AC(1)-01

IR-1 Reference #: AC(1)-283
Page #: 6
Section 5 Concern/EA Process Item: Accidents and Malfunctions
Fish and Fish Habitat
Alternatives Assessment
Aboriginal Health and Socio-economic Conditions
Current Use of Lands and Resources for Traditional Purposes
Comment: Environmental Monitoring and Assessment
Environmental monitoring should be around seepage areas, concerned it is not being completed
Concerned that environmental testing by the industry should done be an outside body
Concerned about back-up plans
Policies should be written down, we are concerned about the (emergency) procedures
If CDA standards failed before, why use something that has failed? (Mt. Polley)
Monitoring of the Tailing ponds, concerned about who will monitor over the next 10-100 years
Link to Annex A1:
AM(1)-01
AM(1)-03
AE(1)-01

IR-1 Reference #: AC(1)-284
Page #: 6
Section 5 Concern/EA Process Item: Aboriginal Health and Socio-Economic Conditions
Accidents and Malfunctions
Comment: Impact on People and the Community  
What is the plan in the event of human health concerns?
What are the guarantees of no damage?
Concerned about outside people from Toronto not realizing the needs of our community
Concerned with air quality
Concerned that they may come closer to the community
Mine cannot ensure that people will be compensated if something happens
Link to Annex A1:
HE(1)-01
HE(1)-33

IR-1 Reference #: AC(1)-285
Page #: 6
Section 5 Concern/EA Process Item: Current Use of Lands and Resources for Traditional Purposes
Accidents and Malfunctions
Comment: Concerned about closure plan
Concerned that there will be hazardous waste impacting the land
Concerned government vs. Goliath clean up standard the same or better?
Concerned that they will not have enough money to clean it up
Smaller mines need to be watched more because they may not have the resources
Need more information from provincial and federal government

IR-1 Reference #: AC(1)-286
Page #: 6
Section 5 Concern/EA Process Item: Fish and Fish Habitat
Aboriginal Health and Socio-Economic Conditions
Project Description
Comment: Impact on Freshwater and Fish
Mine closure and potential effects on water management
Freshwater coming out of the plant, my great grandchildren will be drinking that water for 100 years
Concerned about how you developed the baseline for fish
Concerned that the site is close to water, should move the processing plant.
Link to Annex A1:
FH(1)-06
FH(1)-10

IR-1 Reference #: AC(1)-287
Page #: 7
Section 5 Concern/EA Process Item: Cumulative effects
Project Description
Accidents and Malfunctions
Comment: Concerned about Management of Mine
The cost – how much so far has been spent?
144 million isn't enough to clean up the mess
Concerned about a possible connection to Energy East
Concerned about the mill, same situation and impact. The same individual that ran the mill is managing this project.
Link to Annex A1:
CE(1)-02

IR-1 Reference #: AC(1)-288
Page #: 7
Section 5 Concern/EA Process Item: Fish and Fish Habitat
Current Use of Lands and Resources for Traditional Purposes
Comment: Site preparation, wildlife and fish habitat
Construction phase environmental concerns
Nothing to preserve the wildlife in the area
Nature reserve bordering the property
Impact on wildlife
Link to Annex A1:
WL(1)-02
WL(1)-04
WL(1)-05
WL(1)-08
WL(1)-10

IR-1 Reference #: AC(1)-289
Page #: 7
Section 5 Concern/EA Process Item: Aboriginal Consultation
Current Use of Lands and Resources for Traditional Purposes
Aboriginal Health and Socio-Economic Conditions
Comment: Key Messages for Treasury Metal Inc. and CEAA
Air, water and oxygen are life
We hold the knowledge of the land
We are keepers of the land
We have a duty to take care of the lands and waters
Quality of peace
Our water is priceless
Preserve, protect and persevere  
Protectors of 10 000 years
The government needs to follow the MAI and the Grand Council of Treaty 3
Before entering Treaty #3 Territory Grand Council must give consent to those affected and must advise what is intended.
Consent should be required not consultation
I can trust the water but not your mine
We want our water not your money
Link to Annex A1:
EA(1)-01
AC(1)-01
HE(1)-43

IR-1 Reference #: AC(1)-290
Page #: 7,8
Section 5 Concern/EA Process Item: Aboriginal Consultation
Current Use of Lands and Resources for Traditional Purposes
Aboriginal Health and Socio-Economic Conditions, Current Use of Lands and Resources for Traditional Purposes
Comment: Key Questions for Treasury Metals Inc. and CEA Agency
What has been the history of mining to date (land, water) with First Nations? What is the history of this the leadership with Aboriginal communities?
Why is there only a 30 days to review an EIS? How many First Nations have been involved in reviews of EIS? Is this process working and for who?
Have they considered traditional knowledge and knowledge of the land?
Why is the revenue for the Project only 144 million dollars?
How can you guarantee that the groundwater and lake won't be affected? What are you going to do?
Why are First Nations not involved in the development of The Mining Act policies?
How will this impact our environment in the past, present and future?
If the company goes bankrupt, who will pay?
Are the First Nation people the only people standing in the way of the mine?
How much money do you have for closure? Where is it?
What is the risk of long and short-term health issues?
What is the benefit for the community after you are gone in 10 years?
Why do you consider this a consultation rather than a visit?
Why are you consulting us? Where are you taking our concerns?
Are you providing references of other similar projects?
Why are we being consulted on this Project? Why are you asking our opinion?

The community of ELFN including Elders, youth, management have yet to have their concerns adequately addressed by Treasury Metals Inc. and CEA Agency. The concerns, questions and messages documented in the community workshop indicate that there has not been effective dialogue between the proponent and community members.
Link to Annex A1:
AC(1)-01
EA(1)-01
HE(1)-01

IR-1 Reference #: AC(1)-291
Page #: 8
Section 5 Concern/EA Process Item: Aboriginal Consultation
Current Use of Lands and Resources for Traditional Purposes
Structure, site, or thing of historical, archaeological, paleontological or architectural significance to Aboriginal groups
Comment: "Consultation and engagement efforts by Treasury have not resulted in any formal Traditional Knowledge (TK) studies being conducted that are specific to the Project." (Chapter 3.0) The greatest concern of the community was the lack of consent for this project and lack of documentation of Traditional Knowledge. The community was concerned that Treasury Metals Inc. records informational events and phone calls as part of the consultation log and records interactions without the approval of Eagle Lake First Nation. There have been no engagement sessions that have resulted in meaningful participation with the community in regards to the development of baseline studies or environmental monitoring programs.

In Appendix DD, Treasury recognizes that there is wild rice harvesting sites near the location of the mine (pg, 23Q24 in Appendix DD).

"These wild rice harvesting areas have not been confirmed with WLON. Regardless of these areas being confirmed. Treasury is aware of the presence of wild rice in the areas identified and will take measures to ensure that these sites remain suitable for wild rice growth. Eagle Lake, as well as the other First Nations with which Treasury is obliged to consult, was sent a letter by Treasury on January 28, 2014 requesting information related to Aboriginal values associated with wetlands. Information relating to wetlands which may have been used for wild rice harvesting was specifically requested. No responses were received." Treasury has not confirmed these sites with WLON and Eagle Lake FN. Treasury also claims there are no sites of archaeological significance. Rather than relying on the expertise of an archaeological firm and MNRF data, the Company must engage with the communities in a comprehensive manner.

In Appendix DD and in the Conclusion (Chapter 13) outlines Eagle Lake First Nation concerns. Table 2.1 in the fifth column records the community's response to the concerns presented to CEAA by Eagle Lake First Nation. For example, a key concern from an Elder in the community was the impact of the Project on Lola Nature Reserve. Treasury indicates that there will be no impact on the Lola' Nature Reserve because it is situated 2 km upstream from the site. This is a conclusion that was not made in consultation with Aboriginal people and dismisses a traditional and holistic understanding.
Link to Annex A1:
EA(1)-01
AC(1)-01
HE(1)-45
HE(1)-47

IR-1 Reference #: AC(1)-292
Page #: 9
Section 5 Concern/EA Process Item: Fish and Fish Habitat
Migratory Birds
Current Use of Lands and Resources for Traditional Purposes
Aboriginal Health and Socio-Economic Conditions
Aboriginal Physical and Cultural Heritage
Effect that is directly linked or necessarily incidental to a federal authority's exercise of a power or a performance of a duty or function
Accidents and Malfunctions
Comment: Refer to Table 2.1 Community Response to "Table DD.7.9 "Feedback from Aboriginal Communities provided by the CEA Agency to Treasury" (pg 119-121 in Appendix DD).

Eagle Lake has provided feedback to responses provided by Treasury, including:

• "Concerned about the impact seepage of the TSF into groundwater and surface water flowing to Wabigoon Lake."
• ELFN has traditionally used this area for wild rice harvesting and blueberry harvesting. We have a camp. We have seen many robins in that area. We believe that Wabigoon FN has sites of significance in the area. This response is disrespectful of traditional knowledge and teachings. Archaeological assessment needs to be in consultation with First Nation.
• There will be an impact on the nature reserve. Concerned about the Project impacting Mavis and Ghost lake where there is a sacred site called The Serpent (7 km away), concerned about the impact on the overall landscape.
• The community is concerned about how the baseline for fish was established. Walleye uses this stream in June. This needs to be assessed with traditional knowledge.
• Will TM be applying for HADD, Fisheries Compensation Agreement, and Fisheries Act Authorization through the Federal government? (Page 157 PD)  
• We have been going to this blueberry camp for centuries. Concerned about the impact on the fox and the bear.
• "Its disrespectful for the community to think about mitigation because you can't off set an impact on something." Community was not involved in providing information related to mitigation measures which is another example for the need of a comprehensive community engagement strategy
• How do we know if those regulations will be safe? There needs to be an independent monitoring panel to ensure safety. Community members have never seen a TSF, it may be beneficial to provide a site tour to an operating gold mine such as Detour etc. First Nations are visual people.
• The community needs to be able to see the closure plan. What happens in 100 years? There was an effort made by MNDM in the Treaty #9 area to involve First Nations in a comprehensive review of the Closure Plan while in draft stages. Premier Gold Mines and MNDM jointly worked with the communities to discuss both the Draft CP and the Final CP before the commenting period to allow for comprehensive community involvement that resulted in detailed comments and mitigation measures being identified by the communities. Engaging communities can be interactive and hands on and can be innovative as opposed to being confined to commenting periods.
• We need an independent monitoring panel of both the tailing storage facility and groundwater. First Nations Need to be involved in monitoring, environmental effects and monitoring plan Success story on APTN regarding community environmental monitors on at an advanced exploration site that are directly involved in capacity building such as OBBN, sampling protocols, waste management inspections, hazardous waste inspections, facility inspections etc. The community environmental monitors are directly involved in the permitting and approvals process and provide community assurance and are involved at comprehensive community engagement activities.

Link to Annex A1:
EA(1)-01
AC(1)-01
HE(1)-38
HE(1)-43
HE(1)-45
HE(1)-46
HE(1)-47
FH(1)-06
SW(1)-24

Aboriginal Consultation for the Project- Cumulative Effects and Valued Components

IR-1 Reference #: AC(1)-293
Page #: 15,16
Section 5 Concern/EA Process Item: Cumulative effects
Aboriginal consultation
Alternatives assessment
Aboriginal health and socio-economic conditions
Comment: The Cumulative Effects Assessment is included in Chapter 6.0 of the Environmental Impact Statement with methodological considerations found in Appendix W (Human Health). The decision process to which significance is determined (Figure 6.1.1 Decision Tree for the Determination of Significance for Residual Effects) does not incorporate traditional indigenous knowledge and understanding. Table 14.1.1 in Appendix DD sets of the summary of concerns and accommodation measures. These measures were not made in consultation with the Aboriginal communities. The accommodation measures rely on a number of "management plans" that currently rely on the permitting process and a developed monitoring plan.

The cumulative effects do not consider long term ecosystem impacts. For instance to understand the long term impact of mercury in fish, it is important to assess current levels in Wabigoon Lake with the levels that could be released from a potential failure. This was not a part of Treasury s analysis and the company has not provided a scenario for increased mercury levels human health assessment. In Appendix W, The current risk estimates for humans are based solely on dust exposure from soil. Due to the toxicological properties of mercury it is important to derive a comprehensive exposure that includes all sources for humans. Therefore the risk estimates for mercury likely underestimate the potential risk for humans.

The elders from ELFN community are concerned by the impact of the mine on overall health of the landscape and watershed, and impact of sites of cultural significance. The proponent needs to assess the cumulative effects on specific VCs that are important for the Aboriginal community. For example, in order to understand the impact of this project on fish population we need to understand both the fishery habitat lost in this project, current levels of contaminants in fish and the impact of recreational fishing on fish habitat and spawning. (Duinker and Greig, 2006).

"The mitigation measures to be applied to this project have been integrated into the Project design; consequently, it is only the residual effects of the Project which require significance assessment." (Chapter 3.0, Environmental Impact Statement). Treasury has focused on potential cumulative effects on the existing environmental and socioeconomic baseline relative to identified projects and activities that are predicted to occur (or are reasonably foreseeable) in the next 10 years. It is difficult for the community assess risk when there are no scenarios for cumulative effects that consider design failure or possible failure.

Chapter 2.0 in the EIS considers the Alternative Assessment. "Three economic factors VCs were identified and retained during the socioeconomic assessment: All three VCs Employment; Income; and Economic Development have been evaluated in recent mining EAs and are key areas of interest for regulators and Aboriginal and local communities". Treasury claims to incorporate Aboriginal values into VCs and significant criteria but the community has had no direct involvement in their development.

"The information from local stakeholder groups remains invaluable as it provides an opportunity to assign relative importance of contributing factors from these stakeholder groups". Treasury uses the following criteria in Environmental Account; Technical Account; Project Economic Account; and Socio-Economic Account (Chapter 2.0 pg., 22). An alternative assessment that is helpful in decision-making is one that considers all social, cultural and environmental effects in relation to the life of the mine.

Highlighted Concerns and Omissions

• No traditional knowledge studies or confirmation with Aboriginal communities in any of the EIS.
• Consultation log was limited in its summary of consultation with potentially affected Aboriginal groups, no current details on how the information was obtained during the consultation or how these concerns were taken into consideration in the preparation and updating the plan.
• Valued Components and Significance Criteria not developed in consultation with Aboriginal communities.
• Alternatives are assessed using simplified criteria. According to the Mt. Polley Independent Review Panel "safety attributes should be evaluated separately from economics, and cost should not be the determining factor"
• Human health from dissolved Mercury Hg) in fish not yet considered in the Human Health Risk Assessment.

Conclusion
Treasury Metals Inc. has not adequately addressed the concerns of the Eagle Lake First Nation. The "consultation" to date and the conduct of the EA has not yet allowed for productive dialogue between the community and the proponent. The mine does not have the consent of the Eagle Lake First Nation to proceed with current proposal.
Link to Annex A1:
 CE(1)-01
CE(1)-04
CE(1)-05
CE(1)-06
EA(1)-01
AC(1)-01
HE(1)-01
HE(1)-10
HE(1)-47

Design Considerations - Acid Rock Drainage

IR-1 Reference #: AC(1)-294
Comment: A detailed analysis on water quality and methodological concern of the technical review are included in Maclean Environmental Consulting report. A few concerns are highlighted below.

IR-1 Reference #: AC(1)-295
Page #: 17
Section 5 Concern/EA Process Item: Aboriginal Health and Socio-Economic Conditions
Fish and Fish Habitat
Comment: Acid Rock Drainage
Maclean Environmental Consulting reported that:
• Segregation or separation of PAG and non-PAG mine rock is NOT POSSIBLE, because all rock types have high potential to be acid –generating. How will Treasury build tailings structures and other mine structure without using this rock fill?
• In Appendix F in the EIS recommend that the "potential generation of acidic generating material required additional model simulations". In Appendix D, the Tailing Storage Facility design is dependent on acid rock drainage testing being completed " Confirmation of the acid potential of the mine waste rocks should be determined before proceeding with the design" The alternatives for Tailing Storage Facility presented by Treasury are incomplete due to an incomplete analysis of acid rock drainage.
Link to Annex A1:
MW(1)-08

IR-1 Reference #: AC(1)-296
Page #: 17,18
Section 5 Concern/EA Process Item: Alternatives assessment
Comment:
Tailing Storage Facility (TSF) – Best Available Technology

The Goliath Gold Mine proposal is one of the first mines to undergo environmental assessment since the findings of the Mount Polley Expert Review Panel have been released in January 2015. It is an opportunity for CEAA and the Ontario Ministry of the Environment, Ontario Ministry of Mines and Northern Affairs to implement their significant recommendations. Some of the key recommendations pertinent to the Goliath Gold proposal include best available technology. Some pertinent quotes are included below:
 
"The goal of BAT [Best Available Technology] for tailings management is to assure physical stability of the tailings deposit. This is achieved by preventing release of impoundment contents, independent of the integrity of any containment structures. In accomplishing this objective, BAT has three components that derive from first principles of soil mechanics:

1. Eliminate surface water from the impoundment. 2. Promote unsaturated conditions in the tailings with drainage provisions. 3. Achieve dilatant conditions throughout the tailings deposit by compaction.

The Panel recognizes that eliminating water from the tailings deposit will not eliminate the need for storage of mine and processing water elsewhere. But Mount Polley has shown the intrinsic hazards associated with dual-purpose impoundments storing both water and tailings. The Panel considers that security can be more readily assured for conventional water dams that are designed and constructed for their own purpose and that preventing tailings release is the overriding imperative..."

Best Available Technology

Mt. Polley panel recommends:

"For new tailings facilities. BAT should be actively encouraged for new tailings facilities at existing and proposed mine. Safety attributes should be evaluated separately from economic considerations, and cost should not be the determining factor.

"For closure BAT principles should be applied to closure of active impoundments so that they are progressively removed from the inventory by attrition. Where applicable, alternatives to water covers should be aggressively pursued." 

The company has not addressed the concerns outlined the Mt. Polley Review Panel. It is clear that the TSF design for Goliath Project does not meet any of the Panel s BAT recommendations: the tailings will be saturated with water, will depend on a water cover to prevent Acid Mine Drainage, and will have to be maintained in that condition in perpetuity. Mt. Polley Review Panel Report outlines that observational monitoring of the tailing storage facility cannot predict the unpredictable impact of slope failure. In the ESI Appendix D pg. 34) refers to an observation approach Peck 1969) to safety. The Mt. Polley Independent Review also recommended that Canadian Dam Guidelines to be adapted to the slurry of tailings material rather than for water.

No filtered or dry tailings analysis has been presented, as the proponent argues that the process would make the mine uneconomic and not be suitable. The proponent s proposal fails to meet the safety design criteria recommended in the Mount Polley's Expert Panel report. The best practices recommended on the site including dry stack tailings and tailing impoundment areas, rather than tailing storage facilities.

Highlighted Concerns and Omissions

• Outstanding concerns about water quality (refer to Maclean Environmental Consulting Report). Current design considerations do not take in account the Independent Review. Safety attributes should be evaluated separately from economics, and cost should not be the determining factor.
• Using an observational approach and building the TSF overtime is not considered the best approach.
• The only alternatives they have considered are "readily available technology" (Chapter 7.0, page 22) The Best Available Technology (including tailings impoundment areas) have not been considered and due to economic factors.

Link to Annex A1:
AA(1)-01
AM(1)-05

Environmental Monitoring Plan and Closure Plan

IR-1 Reference #: AC(1)-297
Page #: 19
Section 5 Concern/EA Process Item: Aboriginal consultation
Accidents and malfunctions
Fish and Fish Habitat
Aboriginal Health and Socio-Economic Conditions
Comment: Environmental Monitoring Plans (EMP)

Currently EMP is limited to Chapter 13.0 in the Environmental Impact Statement and Chapter 9.0 in the Environmental Impact Statement Summary, "The monitoring program will be finalized through discussions with Environment Canada and the Technical Advisory Committee TAC). It is anticipated that the sampling locations will be finalized prior to construction so that concurrent baseline data can collected prior to effluent discharge." (Chapter 13)  

It is difficult to comment on the EMP plan as it is yet to be developed in detail and a throughout review of the EMP is beyond the scope of reviewing this ESI at this time. Currently Treasury plans to test tailing composition annually (Chapter 13). An independent monitoring panel could include a multi-stakeholder group with key recommendations from each stakeholder group. A review of the environmental monitoring program should be developed with the Aboriginal community and should be subjected to an external review and compared with best practices.

Potential Recommendations for Effective Monitoring

• Review of the permitting process with community stakeholders and Aboriginal groups
• Provisions for robust and independent monitoring and develop mechanisms for on-going dialogue and dispute resolution. Develop an independent monitoring panel with adequate Aboriginal representation
• Methods to monitor the effectiveness of reclamation including comparison to baseline and regional reference data
• Detailed annual report including frequent monitoring and testing of tailings material.
• Ongoing monitoring of cumulative effects, which would include Traditional Ecological Knowledge and involving First Nations, groups in regional planning.
• The emergency response outlined in Appendix F to include specific details on how to prevent the contaminants from entering Wabigoon Lake.

Link to Annex A1:
HE(1)-46

IR-1 Reference #: AC(1)-298
Page #: 20
Section 5 Concern/EA Process Item: Aboriginal consultation
Fish and Fish Habitat
Aboriginal Health and Socio-Economic Conditions
Comment:
Closure Plans
 
Monitoring of the closed facility will consist of annual Dam Safety Inspections of the closed facility as well as Dam Safety Reviews for a period of five years following closure (Chapter 11, ESI) The closure plan is anticipated for a 5 year period yet this site needs to have ongoing monitoring. There is no provision for the costs of long term care of the mine site. Since the tailings will be acid generating, they will have to be monitored in perpetuity with an emergency plan and financial bonds in place. Such a monitoring program after closure and perpetual care of the site has yet to be recognized by Treasury.

Highlighted Concerns and Omissions

• Closure plans and financials should be made public and available to review
• Long term water management is the most serious issue at closed mine sites
• Water supply spillways and other engineered features need to be monitored and maintained in perpetuity.
• Need clarity on how tailings, as well as underground mine will react with groundwater flowing under the surface.

Link to Annex A1:
MW(1)-23

Financial Consideration and Social-Economic Assessment

IR-1 Reference #: AC(1)-299
Section 5 Concern/EA Process Item: Aboriginal Health and Socio-Economic Conditions
Comment: Financials and social-economic baseline
A detailed economic review of the mine was not in the scope of this review of the ESI. In Chapter 14.0 of the Environmental Impact Statement, Treasury Metals Inc. reports

" Based on the results of the environmental assessment presented in this EIS for the Project including all mitigation strategies and all supporting technical studies), Treasury concludes that: "the Project will provide an economic net benefit to the local, Aboriginal, regional, and provincial economies and will not result in adverse impacts to Aboriginal and Treaty Rights or related interests (Table 14.0.1 and Table 14.0.3) or other public concerns (Table 14.0.2);"
Link to Annex A1:
HE(1)-35

IR-1 Reference #: AC(1)-300
Section 5 Concern/EA Process Item: Aboriginal Health and Socio-Economic Conditions
Comment: Social-economic assessment
This project has the potential to have significant social-economic impacts for the community of ELFN. In ESI, Appendix T outlines a social-economic baseline study and Appendix CC outlines the person hours that will be required for the Project. The information in this social-economic baseline was based on 2006 and 2011 census data.

In Appendix CC, on page 98, the proponent outlines the type of jobs and number of person hours that will be potentially available a Goliath gold mine. Many of the jobs generated at the site are for highly specialized fields and not been explained in details.

The community has identified that job creation is not a major community consideration, despite claims by Treasury Metals Inc. that ELFN will benefit from job creation at the site. Speculating the impact on ELFN is based on social-economic data not specific to this project in Appendix T. The mining company has not yet expanded on the potential benefit of the mine to ELFN to include relevant social-economic opportunities for the community.
Link to Annex A1:
HE(1)-33
HE(1)-34
HE(1)-35

IR-1 Reference #: AC(1)-301
Section 5 Concern/EA Process Item: Aboriginal Health and Socio-Economic Conditions
Comment: Financial concerns
According to Appendix F, "The potentially mineable portion of the mineral resources in the Goliath mine area is presented in has been estimated using a gold price of US$1,350/ounce and a silver price of US$22/ounce. All mineralized blocks that are above the marginal cut-off grades of 0.43 grams gold per tonne of open pit rock and 2.50 grams gold per tonne of underground rock."

The economics of the mine are likely to result in "boom and bust" economics. The company needs to ensure that there is significant budget for emergency conditions and long term perpetual care of the site.

In 2005, The Auditor General has expressed concerns about the financial assurance provisions at operating the mines and about the Ministry's relationship with First Nations. Mining Watch Canada, 2015 has expressed concerns to the Auditor General that "The Mineral Development Strategy in Ontario" continues to rely economic impact model with no debit column (input out), that externalizes risk including environmental, cultural, and social costs. The use of GDP and an Input-Output model to measure economic consideration does not take in account the full risks to the community and hidden costs" (Mining Watch Canada, 2015).

Table 2.2 – Table 22.1 in Appendix BB – Capital Costs of the Goliath Project

According to Appendix BB (Table 22.1) Summary Net Cash Flow, the capital cost for closure is 950,000 dollars. "Closer & Restorage (net of Salvage) $950,000, $0.11 per tonne ore milled" The closure cost seems to be low according to the cash flow predictions. Within the capital cost, there is no specific category associated with ongoing monitoring of the site after closure.

On May 19, 2015 the financial profile of the company currently is at 38 cents a share (TSX) and with 29 million market capitalization. There is 144 million net profit is expected (NPV discounted) from this project, based on project of similar nature does not allow for implementation of a long-term reclamation plan and monitoring plan or on-going investment in best available technology.

Conclusion

Maclean Environmental Consulting indicates that all rock from the mining site will have ADR potential at some point in the future. This unpredicted and thus unexpected ADR would require treatment and containment of contaminated water, sealing of waste-rock piles, prevention of overspill from pond. Such large costs for long-term care of the mining site should be estimated in advance of mining, and financial security should be scheduled into the operation as an on-going cost rather than a capital expense.
Link to Annex A1:
HE(1)-35

Table 4 – Agency Disposition of Written Comments submitted by Eagle Lake First Nation on the Environmental Impact Statement (Report by Maclean Environmental Consulting)

IR-1 Reference #: AC(1)-302
Page #: 24
Comment: Introduction
Maclean-Environmental Consulting was asked to provide a review of Treasury Metal's EIS for the proposed Goliath mine. More specifically, this review will focus on the water quality sections of the EIS, with respect to certain community concerns as identified by Kaitlin Almack of ICA Associates Inc., on behalf of the Eagle Lake First Nation. The following concerns will be addressed where feasible:

• What is the process by which Acid Rock Drainage (ADR) water will be separated from non-ADR water?
• What will be the water quality of the pit lake, which in turn will be released to the environment?
• Is the process for collecting run off water at the site sufficient?
• Is the model used to predict contaminants sufficient?

Further areas of major concern were identified by Ugo Lapointe of Mining Watch Canada and will be considered in this report where feasible. They include:

• Mining effluent quality and impacts on the receiving waters;
• Risks for underground water contamination; and,
• Risks of dam breach and tailings spill in receiving environment, and potential impacts related to toxicity of tailing material.

With respect to the above concerns as presented by the First Nation and Mining Watch Canada, this report will describe aspects of the EIS related to:

• Water management;
• Groundwater flow and quality;
• Water quality; and,
• Predictions of the EIS modeled water quality.

Finally, the report will also point out any errors or omissions in the EIS, as it relates to the CEAA EIS guidelines.

IR-1 Reference #: AC(1)-303
Page #: 25,26
Section 5 Concern/EA Process Item: Fish and Fish Habitat
Aboriginal Health and Socio-Economic Conditions
Comment: Water Management
The site requires multiple water management structures and considerations. Treasury Metals (TM) proposes to create a Tailings Storage Facility (TSF), a polishing pond, and numerous collection ponds. TM also proposes to build pipelines to receive water and to discharge water. Principle discharge pipelines will be to the TSF from the collection ponds, and from the TSF to an Effluent Treatment Plant. Intake pipelines appear to connect the Tree Nursery Ponds with the Effluent Treatment Plant. Other structures on site pre-exist.

Table 4 – Agency Disposition of Written Comments submitted by Eagle Lake First Nation on the Environmental Impact Statement (Report by Maclean Environmental Consulting)

For example, Section 3.1.6 M Dams and Impoundments, states, "The unnamed tributaries passing through the former tree nursery were historically impounded by OMNRF to provide water for the tree nursery. The structures and impoundments remain in place and functional."
The ponds are part of the Thunder Lake Tributary #3. To meet the needs of the mine, 26% of the flow of this creek will be needed. The processing plant will consume an estimated average 600 m3/d of fresh water during operation. Final treated water will be discharged to the Blackwater Creek. Blackwater Creek will also be realigned.

Physical diversions of creeks and dewatering of existing natural waterways is expected, as is the creation of ditches and berms to control run off. Section 3.3.2 Surface and Mine Water Management, states, "runoff will be prevented from entering the open pit by means of a small berm or ditch." TM does not define to what depth, height, or standard any of these features will be built.

Collected water from these ditches into collection ponds will be pumped via pipeline to the TSF. A more thorough review of site grading and geo-engineering was not undertaken in this report. Plans to keep run off from the open pit as well as the environment are not well defined.

Section 3.2 of the EIS defines Project Phases and Schedule. The management of the mine is divided into 4 phases. Within these, water management priorities are outlined as follows:

• Site Preparation Phase M Dewater ponds and wetlands and build surface draining diversion structures, establish water management and flood protection;
• Construction Phase – site drainage works including pipelines and construction of the TSF;
• Operations Phase – none given
• Closure Phase – none given

With respect to the community concern about control of runoff, Section 3.3.2 M Surface and Mine Water Management, defines, "The topography of the Project site is generally flat which allows the mine water management to consist mainly of surface water runoff redirection or collection". Management of water on the site will involve control of drainage from creeks and other tributaries, and precipitation and "the system will be designed to handle the average annual precipitation and will also include provisions for functionality under all climatic conditions". Precipitation is estimated, and taken from historical records. Section 5.1.4. defines this:
"Based on historical observations at Dryden, mean annual precipitation at the Project site is 705 mm, of which, between 20% to 24% falls as snow. Precipitation recorded at Dryden is considered as representative of the LSA due to the proximity and the lack of significant elevation differences or orographic features. Slightly higher precipitation totals and a higher percentage of precipitation falling at snow at Sioux Lookout may suggest that precipitation is less homogeneous through the RSA." No consideration of changes to precipitation as a result of climate change are provided.

Further to collection of runoff concerns, Section 3.3.3 -Open Pit Design, describes, "An in-pit sump will be used to collect mine water resulting from groundwater inflows and surface runoff. Perimeter wells or drainage holes in the pit walls may be installed to aid in the mine water management as mining progresses."

As well the Project will use ditching and seepage collection around the edges of the stockpile to collect and direct surface water runoff and seepage. This water will likely be acidic. This runoff will be piped to the treatment plant, tested and then released. The mine water management system may also include directing run-off water into the completed open pits after closure and to facilitate pit flooding.
Link to Annex A1:
SW(1)-08
AA(1)-08
EE(1)-06

IR-1 Reference #: AC(1)-304
Page #: 26,27,28
Section 5 Concern/EA Process Item: Fish and Fish Habitat
Aboriginal Health and Socio-Economic Conditions
Comment: Acid Rock Drainage

While this report does not examine the technical science behind the ARD predictions, it does describe the potential risks associated with managing run-off that is potentially acidic.

From 3.5.1 Mine Rock Stockpile, approximately 23 million tonnes of waste rock will be produced during the open pit mine life with an additional 2 million tonnes being generated and stored on surface from underground mining. 13 million will be stored and 12 million backfilled. Also, "the pits will be developed and mined in series from west to east. As a result, approximately 40 or 12 million tonnes) of the total open pit waste rock can be used to backfill the pits and minimize the volume and footprint of the waste rock stockpile north of the pit. The waste rock stockpile will have a footprint of 37 ha, a height of 30 m above grade

Section 5.4.3.4 M Materials and Characterization and Management Studies, indicates that there are 4 mine rock types – all were classified as Potentially Acid Generating (PAG). Given that the materials have what is known as a "very low NPR ratio" Price, 2009), this indicates rock material having a high potential to be acid generating. This means that ALL runoff has the potential to generate acid. Current predictions see acid generating potential in all materials stored past conservatively 20 M40 weeks).

3.5.1 Mine rock stockpile states, "during production, waste rock will be classified and separated according to acid generation potential. The placement of these stockpiles will fall under a management plan for mine rock management that will detail the methods for classifying rock type for acid generating potential through appropriate testing in order to direct this rock to the appropriate stockpile location. A management plan of this type is standard industry practice for rock that has the potential for acid generation. This plan is not defined and contradicts the earlier statements in the EIS that all waste rock is potentially acid generating.

Where possible, potentially acid generating (PAG) rock will be placed within the completed open pits to provide a long term water cover in order to mitigate potential acid generation.

Management will also include treatment of water run-off from the permanent waste rock storage pile and the low grade stockpile. The low grade ore stockpile will have temporarily the potential to generate acid runoff while being stockpiled, however, at the end of mining operations, the LGO will be depleted and no material will be left behind. Yet, "Treasury understands that conditions may change over the life of the mine. For this reason, a contingency plan is presented in Section 3.14.3 to address potential for a low-grade stockpile at closure. Section 3.14.3 was not reviewed in this report however requires consideration as a potential risk. What will be the long term plan to control this ARD should a stockpile remain at closure?

Control of runoff is essential as all runoff has the potential to be acid generating. This means runoff may contain (from 5.4.3.4 Materials and characterization and management studies) sulphates, antimony, cadmium, zinc, aluminum, copper, and lead. These same contaminants will be those of concern should any large spills, accidents or persistent leaks occur at the site.

Highlighted Concerns and Omissions

• Section 5.4.3.5 describes that all (100% ) mined materials, including waste   rock, tailings, and lowMgrade ore, have been classified as Potentially Acid   Generating (PAG).
• The EIS states, "If segregation of PAG and nonMPAG mine rock is completed, any material used for construction purposes should be evaluated for acid generation potential and metal leaching prior to use." Segregation or separation of PAG and nonMPAG mine rock is NOT POSSIBLE, because all rock types have high potential to be acid – generating. How will Treasury build tailings structures and other mine structure without using this rock fill?
• No consideration of climate change has been given.
• No consideration of Traditional Knowledge has been given.

Link to Annex A1:
MW(1)-08
MW(1)-10

IR-1 Reference #: AC(1)-305
Page #: 29,30,31
Section 5 Concern/EA Process Item: Fish and Fish Habitat
Aboriginal Health and Socio-Economic Conditions
Comment:
Groundwater Flow and Quality

Groundwater was studied for the EIS over a short period of time in 2013 and 2014. The study looked at two types of flow; M flow in the surface to bedrock region and flow in the bedrock itself.

Groundwater studied for the flow in the surface to bedrock layer, discussed in the EIS section 5.6.2.3 Groundwater Flow, indicates that flow was only studied for an 8 month period, June 2013UJan 2014 . No spring freshette evaluation was considered where highest flows would be expected.

Over the short 8 months evaluation period, the water table seems quite variable. Water table depth varied from 14cm deep to almost 2 m. The resulting hydraulic conductivity values seem generally representative of silty and sandy conditions. This will mean considerable possibility for movement of runoff, or TSF leaks/accidents into groundwater. Groundwater flow is described in the EIS as having a SW direction, towards Wabigoon Lake.     

For the studies on flow in the bedrock itself (Section 5.6.3.3. M Groundwater Flow (bedrock)), studies were undertaken for 5 months in 2013, and indicated "a groundwater elevation rise following the spring freshet, followed by a gradual decline through to the winter of 2013/2014". Total water level fluctuations in these wells was reported to be between 1.0 m and 1.5 m. Water table levels fluctuate and rise with the spring freshette. This fluctuation suggests an active groundwater flow area. To truly understand the potential consequences of this, the speed of flow to the SW needs better consideration, especially given that any potential seepage from the tailings facility may acidify local wells. Some consideration is given to this below.

The movement of groundwater in the bedrock shows an outward radial flow to the east and SW and might discharge to the Blackwater Creek.

How quickly TSF waters could leach or leak into the aquifer/ groundwater depends on citing of the TSF and measured rate of flow. The TSF is located in the NE corner of the mining property and as such is situated furthest from Wabigoon Lake, (as the property will allow) given the direction of groundwater flow (SW).

Section 5.6.2.2. of the EIS states surface to bedrock groundwater movements at 1EM 06 m/s and bedrock groundwater movement at 1E M07 1EM09m/s flow. This translates into 31.5 meters per year at the fastest groundwater movement or would take 63 years to reach the nearest well. This report did not comprehensively assess these findings and should only be taken as a superficial consideration of hydrological processes. For example, the studies taken to determine groundflow were undertaken only over a five month period. This may not be sufficient.

Section 5.6.5 also describes where the TSF is cited as having being a "sand clay/silts and unit consisting mainly of silty sand overlying a mainly continuous silty clay above the basal sand unit. This unit is mainly found in the northwestern portion of the Blackwater Creek Watershed (near the top of Blackwater Tributary #2). This silty sand does provide some groundwater flow to Blackwater Creek and likely has a hydraulic conductivity similar to the basal sand. " Figure 1 below shows that the TSF is situated over what appears to be a highly porous substrate. This would seem to imply greater potential for migration of TSF waters and contaminants into the groundwater. This report did review the tailings structure in any detail, however section 2.3.6 of the EIS needs to be reviewed in context to other geological and physical data to fully understand the potential risk to groundwater contamination.

Highlighted Concerns and Omissions

• From Section 5.6.5 Conceptual Hydrogeological Model suggests that "based on data collected during 2012 to 2014, it appears that there is limited groundwater flow that provides a minimal contribution to creeks in the vicinity of the project site and across much of the project area". The reviewer noted only one sample taken in January of 2014 and no record of sampling in 2012, suggesting that the above statement is in error and misrepresents the duration of effort put into studying groundwater
• The above statement that suggests, "it appears that there is limited groundwater flow that provides a minimal contribution to creeks in the vicinity of the project site and across much of the project area" is directly contradicted by the dry year of 2013 below year 30 average precipitation) where the creeks had continuous flow.
• Contradictory information is given, which furthers the argument above, "Monitoring of stream flows in Blackwater and Little Creek during the regional dry/low precipitation year of 2011 found that these creeks had no flow or not enough flow for accurate measurement beyond the spring freshet. This was considered to be an indication that there was no significant groundwater discharge to these creeks, as otherwise some base flow could be expected during very dry conditions. In 2012 and 2013, precipitation was again below the 30 year average, but near continuous flow was noted in both of these creeks, which was then assumed to account for part of the recharge to the overburden aquifer system. The above rationale makes no sense and is contradictory. What is the true answer? Does groundwater significantly contribute to creek flow or not?
• The nearest wells are less than 2 KM away.
• Already at the monitoring wells (background) there are exceedances of aluminum, arsenic, chromium, cobalt, copper, iron, tungsten, vanadium and zinc.
• Groundwater samples have not been collected from any of the bedrock exploration wells for laboratory analysis so no information is available relating to water quality in the bedrock unit at the site. How then can we determine if groundwater is being contaminated if we do not know what it is to begin with?
• The area with the greatest groundwater flow appears to be where the tailings structure will be situated. A sand and gravel unit consisting of coarse glacial deposits located on the northern and northeastern edge of the project area (where the TSF is located). This unit provides the most groundwater flow to the unnamed tributaries leading to Thunder Lake.
• No traditional Knowledge about the area was considered, and therefore no discussion about observational changes over long term was provided. Five to eight months of research on groundwater to surface observations is very weak data on which to make predictions.

Link to Annex A1:
GW(1)-02

IR-1 Reference #: AC(1)-306
Page #: 32
Section 5 Concern/EA Process Item: Fish and Fish Habitat
Aboriginal Health and Socio-Economic Conditions
Comment:
Water Quality
Water from the decant TSF will be treated by the filtration system. This appears to be a catch all solution to any water concerns on site. Two main features of this are the Cyanide Detoxification/Destruction Unit and the Effluent Treatment Plant. Each are assessed for their "best practices" below.

Cyanide Detoxification

Section 3.6.6.3 - Cyanide Detoxification, defines the process as the following: The cyanide detoxification circuit will consist of two stirred reactors with air sparging as well as copper sulphate, sodium metabisulphite, and lime addition. Piping arrangements will allow the reactors to be operated in a series, parallel, or bypass configuration. The detoxification circuit will receive CIL tails and discharge treated slurry to the tailings hopper. Movement of slurry through the detoxification circuit will be by gravity. The cyanide detoxification circuit is intended to be designed to destroy cyanide to 1 mg/L total cyanide, which is the current Metal Mining Effluent Regulations (MMER) limit for maximum authorized monthly mean concentration.
Further natural cyanide degradation will take place in the tailings facility prior to discharge to the environment. Further to this, Section 3.8.7 of the EIS M Final Effluent Discharge, states "by destroying cyanide prior to discharging the tailings to the storage facility, potential cyanide contamination situations such as dam seepage or tailings facility overflow during extreme storm events late in the project life are eliminated".
The Inco SO2- Air process has been selected as the preferred method for in plant cyanide destruction.

Inco SO2-Air process

Most cyanide destruction processes operate on the principle of converting cyanide into a less toxic compound through an oxidation reaction. The INCO SO2M Air process was developed by INCO in the 1980 s and is in operation at over thirty sites in the world http://www.infomine.com/publications/docs/Botz1999.pdf

Table 1 represents a simplified summary, by Michael Botz regarding comparable cyanide treatment processes and may be used as a screening tool. The INCO SO2 Air Process ranks well.
http://chemistry.mdma.ch/hiveboard/rhodium/pdf/cyanide.destruction.overview.pdf

Table 1. Preliminary Selection Guide for Cyanide treatment Processes

Table 2 details the advantages and disadvantages of the INCO SO2 -Air Process.

Table 2. Advantages and Disadvantages of the INCO So2 -Air Process

Advantages

1. The process has been proven in numerous full0scale applications to yield low effluent and metal concentrations
2. The process is effective in treating slurries as well as solutions
3. The process is suitable for batch and continuous treatment
4. All forms of cyanide are removed from solution, including the stable iron cyanide complexes
5. Capital and operating costs are comparable with other chemical treatment processes

Disadvantages

1. If treating high levels of cyanide, the costs for reagents and electrical power can be high
2. Cyanide is not recovered
3. Undesirable levels of sulphate in the treated solution can result
4. Additional treatment may be necessary for the removal of iron cyanide, thiicyanate, cyanate, ammonia, nitrate and/or metals for solutions to be discharged to the environment,

(Mudder et al, 2008).
The process chosen to deal with cyanide seems appropriate. Cyanide destruction through the INCO SO2 – Air process will deliver water into the TSF with levels of cyanide below the levels acceptable to the MMER and PWQO standards. Furthermore, his method ensures that "wildlife, including waterfowl and aquatic life, are protected, that cyanide consumption is minimized, and that contingency is in place to prevent the inadvertent release of cyanide into the environment". TSF will also undergo treatment at the Effluent Treatment Plant.
Link to Annex A1:
SW(1)-14

IR-1 Reference #: AC(1)-307
Page #: 34,35
Section 5 Concern/EA Process Item: Fish and Fish Habitat
Aboriginal Health and Socio-Economic Conditions
Alternatives Assessment
Comment: Effluent Treatment Plant

Tailings storage facility decants will be pumped to the effluent treatment plant for treatment prior to discharge to the polishing pond and ultimately Blackwater Creek. According to the EIS, tailings pond decant water will be treated in three distinct process steps including an advanced oxidation process for residual cyanide destruction, multimedia filtration, and reverse osmosis membrane filtration. TSF decant water will be pumped from a transfer tank to a three chamber multimedia filtration system, operating in parallel, via three multimedia filter feed pumps. This is consistent with literature, which suggests the use of filtration, preferably nano filtration, prior to reverse osmosis (RO) to avoid RO membrane clogging, fouling or damage, (EPA, 2014). Filtration is to a nominal 1.0 micron range. Filtration media will consist of a combination of anthracite, silica sand, and garnet.

The Effluent Treatment Plant will require additions of both sulphuric acid and sodium bisulphite prior to the multimedia filtration step to lower pH and sodium bisulphite consume any excess oxidants respectively. A polymer or coagulant addition will also be included as a flocculation agent. No description of the coagulant is given. Potential risks are associated with the storage of these additives.   

Treasury claims that when the system is functioning well that the RO can operate at recoveries as high as 90%. Treasury identifies scaling as a risk to the correct functioning of the RO system, suggesting, "scaling calculations will indicate the upper limits on recovery and efficiency. Overall the RO should rejection "greater than 98% of all contaminants including: in-organics, organics [greater than 200 nominal molecular weight limit (NMWL)], bacteria and suspended solids as small as 0.003 microns depending upon their shape and strength.

The EIS then describes that the RO treated water will be stored in the permeate storage tank, from where it is returned to the process or discharged to the environment via the polishing pond.

If permeate quality is out of specification (through monitoring) it can be diverted to the transfer tank for retreatment.
Link to Annex A1: SW(1)-18

IR-1 Reference #: AC(1)-308
Page #: 35
Section 5 Concern/EA Process Item: Fish and Fish Habitat
Aboriginal Health and Socio-Economic Conditions
Comment:Sediment quality

A cursory review of sediments was given to attempt to tie any potential pathways of contamination across media (Table 3). For example, do certain metals in water also persist in sediments and wind up in wildlife and fish?

Sediment samples from each location were analyzed for twenty-four PAHs. Benzo[b]fluoranthene and naphthalene were detected at the outlet of Blackwater Creek at Wabigoon Lake. Benzo[k]fluoranthene was detected at all locations. Sediments were also tested for metals and exceedances were found for chromium, copper, manganese, nickel, and zinc, iron and also phosphorus.

Manganese in particular was the only parameter to exceed the SEL at site JCTa, where levels were observed at 1260 μg/g, or 160 μg/g over the SEL.

IR-1 Reference #: AC(1)-309
Page #: 35,36
Section 5 Concern/EA Process Item: Fish and Fish Habitat
Aboriginal Health and Socio-Economic Conditions
Comment:Background water quality

Background water samples were taken at 16 sites over two years. Exceedances of the Province of Ontario's Water Quality Guidelines for pH occurred at 3 sites, cobalt at 10 sites, copper at two sites, iron at all sites except SW8, lead at one site, selenium at one site, silver at one site, vanadium at one site and zinc at 6 sites.

Table 3. Consideration of Contaminants Across Media
Of the metals that appear to be across more than one media, Aluminum, arsenic, copper, lead, mercury, and zinc are considered to increase with the development of the mine (while discharged water is predicted to meet MMER standards these are not the same as POWQ or CCME standards).
Link to Annex A1:
SW(1)-18

IR-1 Reference #: AC(1)-310
Section 5 Concern/EA Process Item: Fish and Fish Habitat
Aboriginal Health and Socio-Economic Conditions
Current Use of Lands and Resources for Traditional Purposes
Comment:Benthic Invertebrates

Some of the EIS Assumptions are unjustified. Section 5.8.3.2 - Benthic Invertebrate Results, in Table 5.8.10 shows that two different companies DST and KCB) did two different studies with no overlap in project sites and with different methodologies, KCB sampled at 4 sites using ponar grabs in 2011. DTS collected at 19 completely different sites, using the kick net method in 2012, in two riffles and one pool per site).

Description of the sample years in the EIS is misleading also. Table 5.8.10 states samples were collected in 2010/2011 and 2012/2013 when in fact were only collected over a total of 4 days (Oct 16 and 17, 2011 by KCB and Oct 22 and 23, 2012 by DST).

Conclusions about water quality from this research are extremely vague, such as "In general, the benthic invertebrate community reflects general conditions at the Site." This type of information does not help decision makers. Furthermore conclusions about water quality in the EIS above 5.8.3.2 indicating general – read good, conditions) differ from those in Appendix P, which indicates poor water quality and that "samples from Wabigoon Lake (SB12-22, SB12-23, and SB12M24) in 2012 were dominated by Diptera (ranging from 52.3% to 80.1%), again suggesting poor water quality".

The conclusions from section 5.8.3.2 cannot be made because studies are not comparable, with different sites and methodologies. This section concludes that "results of benthic invertebrate sampling from Blackwater Creek in 2012 were somewhat similar to 2011 in that a higher percentage of EPT families were observed in downstream samples compared to upstream samples. Simpson s index, which ranged from 0.4 to 0.9 further suggests moderate to high species diversity in Blackwater Creek.

This above conclusion is directly contradicted in Section 10.4.5. -Benthic, which concludes, that "In general, percentages of EPT taxa in Blackwater Creek were extremely low, reflecting the slow moving, turbid, and soft bottomed nature of the stream".

In fact, generally invertebrate samples dominated by only two species or that have percentage of Diptera greater than 40% are indicative of poor water quality. Low EPT also suggests dominance by species better able to tolerate a low oxygen environment. This may have considerations for habitat, as this will be the creek receiving the processed mine waters to MMER standards only), though many still above the CCME guidelines, possibly including phosphorus. This may further limit oxygen and worsen habitat.

There was no effort to cross examine nutrient data with contaminant data or background water chemistry to consider the conclusions of this work? Low EPT values can be explained by low oxygen in slow moving creeks, but not in the more open lakes. This was not considered, nor was the ultimate impacts the mine might pose benthic life in general.

IR-1 Reference #: AC(1)-311
Page #: 37, 38
Section 5 Concern/EA Process Item: Fish and Fish Habitat
Aboriginal Health and Socio-Economic Conditions
Comment:Fish

Fish health was examined in this report to understand what potential contaminants were already of concern and to see if further mine water releases might impact these fish.

From the Fisheries - Appendix Q section 3.1.2 Tissue Sampling, Thunder Lake was studied, however only 11 fish were used for tissue sampling and ageing. This is insufficient given that all of the Walleye sampled were two years of age or less." Mercury results for the largest and smallest fish in the sample were 0.143 mg/kg and 0.331 mg/kg respectively. Mercury levels ranged from a low of 0.102 mg/kg to a high of .503 mg/kg.

Four fish sampled from Thunder Lake exceeded the minimum levels advised for sensitive populations of 0.26.mg/kg. The EIS must include a better age class range to get a true sense of the Hg problem and potential for a rights infringement by further influencing this population with Hg.

Sampling effort was better in Wabigoon Lake, with a total of 28 Walleye and one Sauger caught and retained for tissue sampling and ageing. Age range was from 1 year to 10 years. "Mercury results for the largest and smallest fish by weight in the sample were 0.245 mg/kg and 0.114 mg/kg respectively. Mercury levels ranged from a low of 0.0865 mg/kg to a high of .473 mg/kg." Three fish sampled from Wabigoon Lake exceeded the minimum levels advised for sensitive populations of 0.26.mg/kg M .52 mg/kg.

Highlighted Concerns and Omissions

• No consideration of dissolved versus total metals. If the metals are mostly dissolved this is more problematic as dissolved metals are more readily accessible to aquatic life.
• Given that the fisheries report in section 3.1.2 already identifies consumption guidelines for mercury a better age class assessment of mercury in fish important to the First Nations needs to be undertaken. The current studies for Thunder Lake are on walleye that are all one year old (with one exception on a 2 year old fish). Many First Nations will prefer larger fish where more mercury concerns exist. How Hg will increase in the lakes is unclear from the EIS.
• No contaminants data on benthic invertebrates is considered. This limits the ability to determine pathways from water to sediments through benthic inverts to fish.
• Would be nice to see the consideration of pathways in order to consider if MMER are sufficient to prevent negative impacts on aquatic life.
• A further assessment should consider the proposed influence from predicted CCME exceedances of pH, ammonia, Aluminum, arsenic, cadmium, copper, lead, mercury, thallium and zinc.
• PAHs were only tested for sediment, however not for water.

Link to Annex A1: HE(1)-14

IR-1 Reference #: AC(1)-312
 Section 5 Concern/EA Process Item: Fish and Fish Habitat
Aboriginal Health and Socio-Economic Conditions
Comment: Predictions of the EIS P Modeled Water Quality

The supernatant ( surface water in the TSF) has modeled CCME exceedances of pH, ammonia, Aluminum, arsenic, cadmium, copper, lead, mercury, thallium and zinc. Seven of these are identified by the US EPA as pollutants of priority out of 13 listed Kelly et al., 2010).

Treasury proposes that all water with the exception of lead will meet MMER standard. Furthermore, the TSF supernatant waters will go through a filtration system before being released to Blackwater Creek. Nonetheless, these are only modeled predictions and this is discussed further below.

In Appendix F, of the Water Management Plan, a description of modeled water quality in the TSF is given, based on use of the PHREEQCi geochemical modeling computer code from Terra Tech. Models require goof initial data in order to make accurate predictions. Data to populate the model came from the analysis of laboratory results from Humidity Test Cell (HTC) and field cell studies, which examined chemical changes to weathering mine rock.

Results of the modeling are provided in Table 3.8.3 in the project description yet it remains unclear why total metals were used as opposed to dissolved metals. Table 3 demonstrates the percentage of dissolve to total metals (from the EIS modeled data). Total metals were likely used, as these are what the current CMME and POWQ guidelines reference. Nonetheless, an assessment of the percentage of these metals that are dissolved needs to be undertaken, as the dissolved metals are those that are more likely to influence the aquatic life surrounding the project.

There appear to be methodological problems in determining dissolved concentrations versus total concentration of metals (as Table 4 demonstrates) in the ultimate fate of TFS waters. Separate experimental field cell studies were developed for total and dissolved metal analysis. With the results as posted many are not comparable. As dissolved concentrations are far more likely to be a problem to aquatic life this a major concern in assessing potential impacts. Should total and dissolved metals be run from the same batch we could get a better percentage of the dissolved potential of certain metals – especially those known to ARD environments.

Table 4. Percentage of Metals that are Dissolved.

It was furthermore not clear why the EIS reported (Section 3), only on intermediate values and not long-term values. A long-term assessment would be more useful and more appropriate. The reason might be a result of incomplete long-term analysis, and discussed further below.

Also it remains unclear why only field cell results were considered and not Humidity Test Cell (HTC) studies given their difference. Section 5.1.2. "Model scenarios based on the dissolved metal concentrations in the field cell leachate were notably different from the HTC leachate- derived scenarios".

Given the differences in the HTC and the field cell, it is unclear why only field cell results have been presented in the body of the EIS report? How come the differences are not discussed with implications for water management and ultimate treatment options? A cursory analysis (Table 5) shows how some of the variables are indeed quite different.

Table 5. Goliath Mine EA Model Outputs Appendix F HTC vs. field cell

The biggest concern to the effectiveness of the modeled numbers is that the studies were incomplete. Section 5.1.2 states, "Although the field cells have operated for approximately the same length of time as the HTCs, differences in particle size, flushing volumes, and temperature-dependent reaction rates results in a delay in the onset of acid-generating conditions. As such, the field tests were not yet acid generating at the time of this modeling effort. "This would indicate that that no laboratory data exists on a modeled ARD scenario to populate a model to derive long term TSF values.

Furthermore, Section 5.1.2 states, "Regression analysis of cumulative elemental concentrations for each element and humidity cell sample was attempted in order to assess rates of element (i.e. metal and sulphur) release after closure. However, as of April 1, 2014, the humidity cells in operation show evidence of the onset of acid generating conditions and significant decreases in the leachate pH with coincident increases in dissolved metal concentrations. Because the pH and metal concentrations have not yet attained a steady-state, the curves fitted to the data suggest an exponential dependence of pH or elemental concentration on time. This over-estimates the projected long term water quality. Therefore, the average of the data collected from weeks 60 through 80 were used to represent long-term water quality. "This contains a whole host of assumptions.

Then, the EIS describes the incomplete nature of the research, "After week 63, operations of two of the three HTCs of each rock type was discontinued. Beyond week 63, only a single HTC of each rock type remained in operation. "Does this indicate that Treasury is estimating the long term water quality and ARD impacts based on TWO incomplete samples?

Highlighted Concerns and Omissions

• Lead levels will increase to roughly 6Mtimes the MMER limit of 0.2 mg/L, after acid generating conditions are established (modeled). HTC data indicates that these metal concentrations, as well as sulphate, will continue to rise as pH decreases. Will treatment be effective in removing this lead prior to release to Blackwater Creek?
• Section 5.1 from Appendix F, from the HTC tests expects cadmium and lead levels to increase over project lifetime and beyond. The same data indicates that metal concentrations as well as sulphate will rise as pH decreases. This is not considered in the main text of the EIS, as only the field test data is used.
• The report goes on to suggest that "Multiple data gaps were identified while reviewing the available data. In an effort to address those gaps, a series of assumptions were made".
• Too many large assumptions are made, such as in section 4.0, "The material composition of the waste rock and pit walls is assumed to remain constant over time. However, this is not likely the case and may be updated in future modeling efforts". Statements like these indicate that actual conditions at the mine where the acid rock potential of mine waste is concerned are very poorly understood.
• Section 4.0 of Appendix F indicates that modeled long- term water quality generated from exposed materials (WRSF, LGO stockpile, pit wall, underground slopes) after the onset of acid generating conditions (weeks 60-80) is based on two incomplete samples. Therefore the confidence in the modeled predictions is understandably quite low.

Link to Annex A1:
MW(1)-15
MW(1)-21
MW(1)-22

IR-1 Reference #: AC(1)-313
Page #: 44
Section 5 Concern/EA Process Item: Fish and Fish Habitat
Aboriginal Health and Socio-Economic Conditions

Comment: EIS Errors and Inconsistencies

• In table 3.8.3 chromium value should be .001 not .0001
• Section 3.2.4 Closure Plan Environmental Monitoring and "potential effluent quality management" will occur during this passive period of reclamation Why potential? This monitoring should be mandatory.
• Management of ARD is never a walk away solution. Will require some form of management in perpetuity to prevent acid generated runoff from occurring and contaminating the surrounding environment.
• In 3.2 Project Phases and Schedule it is listed that Closure and Post-Closure Phase will take 6 years, whereas Table 3.2.1 indicates that closure phase will take 2 years. Again in section 3.2.4 Closure Phase refers to a two-year active closure period. Which is it?
• From 3.3.2. Surface and Mine Water Management "There are no permanent ponds or lakes that require dewatering". Yet the 4 mine phases 3.2.1 -Site Preparation Phase, has "dewatering ponds" within footprint as an activity.
• 5.8.2.2 Copper concentrations from sediments collected in 2011 from TL2, TL3 and BC were above the LEL of 16 μg/g but below the "LEL" of 110 μg/g. (this should be SEL, not LEL).
• The concentration of zinc collected from BC was above the LEL of 120 μg/g. ( this should read SEL not LEL). This mistake downplays impacts as it exceeds the Severe Effect Level not the Lowest Effect Level.
• Related to cumulative impacts from Section 3.4 M Underground Mine states "It should be noted that the resource is "open at depth"; meaning that there is a possibility that it could extend to further depths with continued underground drilling and exploration. Difficult to address impacts without a full understanding of project scope. This needs to comprehensively addressed in the cumulative impacts section.
• Page numbers in the TOC would help for a 979 page document (Appendix G)

Link to Annex A1:
CE(1)-03

IR-1 Reference #: AC(1)-314
Page #: 45
Section 5 Concern/EA Process Item: Fish and Fish Habitat
Aboriginal Health and Socio-Economic Conditions
Project description
Effects of the Environment on the Project
Aboriginal consultation
Alternatives Assessment

Comment: Other Potential Research Questions

• How does the Ontario Mining Act (for closure) relate to CEAA rules for closure and follow-up?
• What are the flocculants used in TSF? Polishing pond?
• How effectively is the Effluent Treatment Plant able to deal with the modeled levels of contaminants? Can this be tested with actual Goliath Project waste rock
• What is the water quality of waste rock leachate after 60-80 weeks?
• What changes occur seasonally in water quality?
• What is the potential for climate change to impact water management and risk management plans?
• Can isotopic tracing in the groundwater be used to determine flow rates?
• Can modeling be done to determine groundwater to surface and surface to groundwater interactions more completely
• How does Traditional Knowledge of the First Nation and Métis communities compare to the science about potential impacts.

Link to Annex A1:
EE(1)-06
SW(1)-34
SW(1)-18
EA(1)-01

Table 5 - Agency Disposition of Written Comments Submitted by Naotkamegwanning First Nation on the Environmental Impact Statement

IR-1 Reference #: AC(1)-315
Page #: 1
Section 5 Concern/EA Process Item: Aboriginal Consultation
Aboriginal and Treaty Rights
Comment: NFN has not been provided adequate funding from either the Proponent or the Canadian Environmental Assessment Agency ("CEA Agency") to conduct a more detailed assessment of the EIS to date. Our initial review has been enough to identify, however, that the Project as proposed has a strong potential for adverse effects of an as-yet unknown (but potentially significant) nature on our aboriginal and treaty rights and the resources they rely upon in the Project-affected area.
Link to Annex A1:
AC(1)-01
HE(1)-38
HE(1)-43

IR-1 Reference #: AC(1)-316
Page #: 2,3
Section 5 Concern/EA Process Item: Aboriginal consultation
Aboriginal and Treaty Rights
Aboriginal Physical and Cultural Heritage
Aboriginal Health and Socio-economic Conditions
Current Use of Lands and Resources for Traditional Purposes

Comment: NFN General Comments on the EIS

Our initial reading finds the EIS deficient in fundamental ways, particularly in its inadequate assessment of effects related to NFN. It is difficult to see how the EIS could be accepted as meeting the requirements of CEAA 2012, as it does not provide sufficient information to meet the requirements in the EISG that pertain to impacts on NFN's treaty rights and socio-economic well-being, health, traditional land use and cultural heritage.

The critical parameters of the effects assessment in the EA, included in the identification of Valued Components (VCs), Key Indicators (Kls), VC thresholds of significance, essential considerations when designing baseline and effects studies, appear to have been developed largely independently from any Aboriginal community's input or consultation. The deficiencies are so readily evident that, in our view, the EIS should not have been allowed by the CEA Agency to pass through the screening phase into the current technical review phase of the EA.

The current stage of the EA under the federal process is the EIS technical review. This is the most critical stage for ensuring that adverse effects of the Project are properly characterized and any necessary measures for avoiding and mitigating adverse effects are clearly identified. Therefore, the CEA Agency and the Proponent must use this opportunity to address gaps and deficiencies that place NFN's treaty rights and interests at risk. Given capacity constraints NFN has been able to highlight these at a high level only to date but passes this information on faithfully to the Agency.

Link to Annex A1:
AC(1)-01
HE(1)-01
HE(1)-33
HE(1)-35
HE(1)-38
HE(1)-43

IR-1 Reference #: AC(1)-317
Page #: 3
Section 5 Concern/EA Process Item: Migratory Birds
Wildlife
Comment: Key Potential Adverse Effects: From a preliminary analysis of the Project Description contained in the EIS, the following non-exclusive potential adverse effects on NFN's rights, interests and well­ being have been identified:

• Adverse effects on hunting of migratory birds due to alienation of wetlands by mining development;

Link to Annex A1:
WL(1)-02
WL(1)-03

IR-1 Reference #: AC(1)-318
Page #: 3
Section 5 Concern/EA Process Item: Current Use of Lands and Resources for Traditional Purposes
Wildlife
Comment:

• Adverse effects on hunting of moose, deer and other ungulates due to alienation of lands and loss of access to mining development;

Link to Annex A1:
HE(1)-38
HE(1)-43
HE(1)-45
WL(1)-04
WL(1)-08

IR-1 Reference #: AC(1)-319
Page #: 3
Section 5 Concern/EA Process Item: Current Use of Lands and Resources for Traditional Purposes
Wildlife
Comment:

• Adverse effects on trapping of furbearers due to alienation and loss of access to lands to mining development;

Link to Annex A1:
HE(1)-38
HE(1)-43
HE(1)-45
WL(1)-10

IR-1 Reference #: AC(1)-320
Page #: 3
Section 5 Concern/EA Process Item: Fish and Fish Habitat
Current Use of Lands and Resources for Traditional Purposes
Comment:

• Adverse effects on fishing due potential changes to Thunder Lake water quality and composition;

Link to Annex A1:
HE(1)-38
HE(1)-43

IR-1 Reference #: AC(1)-321
Page #: 3
Section 5 Concern/EA Process Item: Fish and Fish Habitat
Current Use of Lands and Resources for Traditional Purposes
Comment:

• Adverse effects on fishing due to "re-location" of fish-bearing segment of Blackwater Creek tributary;

Link to Annex A1:
FH(1)-06
HE(1)-38
HE(1)-43

IR-1 Reference #: AC(1)-322
Page #: 3
Section 5 Concern/EA Process Item: Fish and Fish Habitat
Current Use of Lands and Resources for Traditional Purposes
Comment:

• Adverse effects on fishing due to downstream contamination effects on Blackwater creek and Wabigoon Lake;

Link to Annex A1:
SW(1)-19
SW(1)-17
GW(1)-03
HE(1)-38
HE(1)-43

IR-1 Reference #: AC(1)-323
Page #: 3
Section 5 Concern/EA Process Item: Fish and Fish Habitat
Current Use of Lands and Resources for Traditional Purposes
Aboriginal health and socio-economic conditions
Comment:

• Adverse effects on fishing due to increased perception of risk related to potential contamination of Blackwater creek and Wabigoon Lake;

Link to Annex A1:
HE(1)-38
HE(1)-43

IR-1 Reference #: AC(1)-324
Page #: 3
Section 5 Concern/EA Process Item: Current Use of Lands and Resources for Traditional Purposes
Aboriginal Health and Socio-economic Conditions
Comment:

• Adverse effects on use of water and aquatic plants (i.e., wild rice) due to potential contamination of Blackwater creek and Wabigoon Lake;

Link to Annex A1:
SW(1)-19
SW(1)-17
GW(1)-03
HE(1)-45

IR-1 Reference #: AC(1)-325
Page #: 3
Section 5 Concern/EA Process Item: Cumulative effects
Comment:

• Significant adverse effects on treaty fishing rights and commercial fishing interests on Wabigoon Lake in the event of a catastrophic breach of the Tailings Storage Facility (TSF);

Link to Annex A1:
AM(1)-04

IR-1 Reference #: AC(1)-326
Page #: 3
Section 5 Concern/EA Process Item: Accidents and Malfunctions
Comment:

• Significance adverse effects on socio-economic conditions in the event of a catastrophic breach of the TSF that impacts the commercial fishery on Wabigoon Lake;

Link to Annex A1:
AM(1)-04

IR-1 Reference #: AC(1)-327
Page #: 4
Section 5 Concern/EA Process Item: Cumulative effects

Comment:

• Cumulative adverse effects on fishing and aquatic plant (i.e., wild rice) due to contamination and perceived risk of contamination; and

Link to Annex A1:
 HE(1)-01

IR-1 Reference #: AC(1)-328
Page #: 4
Section 5 Concern/EA Process Item: Aboriginal Health and Socio-economic Conditions
Comment:

• Adverse effects on edible and medicinal plants due to potential airborne distribution of contaminants (tailings particulate matter) downwind of mining site.

Link to Annex A1:
HE(1)-01
HE(1)-02
AE(1)-10

IR-1 Reference #: AC(1)-329
Page #: 5
Section 5 Concern/EA Process Item: Aboriginal Consultation
Comment: Overview of gaps and deficiencies in the EIS
The following critical gaps and deficiencies have been identified by NFN through a comparison of the EIS to the requirements of the EISG

1. Absence of evidence that NFN was meaningfully consulted on the development of fundamental components of the EA, including Valued Components (VCs), Key Indicators (Kls), significance thresholds for VCs and Kls, spatial and temporal boundaries;²

²Subsections 7.2.1and 7.2.2 of the EISG require the Proponent to consult with Aboriginal groups (among other parties) in regards to the development of appropriate spatial and temporal boundaries for the project. The extent of consultation by the Proponent with NFN, as indicated in the Aboriginal Consultation Report, appears to have been minimal and largely limited to show-and-tell presentations, rather than a dialogue informed by substantive studies involving the provision of traditional knowledge from community members. For example, one of the few in-person meetings between the Proponent and Treaty 3 nations is described in the Consultation Log, "TMI provided an overview/update of the project, inquired about how to move forward and responded to questions asked by band members.
Link to Annex A1:
AC(1)-01
EA(1)-03

IR-1 Reference #: AC(1)-330
Page #: 5
Section 5 Concern/EA Process Item: Aboriginal Consultation
Comment:

2. Absence of rationale for any VCs that were excluded from the EA;

Link to Annex A1:
AC(1)-01

IR-1 Reference #: AC(1)-331
Page #: 5
Section 5 Concern/EA Process Item: Aboriginal Consultation
Comment:

4. Absence of NFN Traditional Knowledge (TK) being incorporated at any stage in the assessment of any of the VCs being considered in the EIS;³

³ "Consultation and engagement efforts by Treasury have not resulted in any formal Traditional Knowledge (TK) studies being conducted that are specific to the Project. Consequently, direct traditional Aboriginal knowledge gained through these studies has not been made available or used to derive VCs. A number of Aboriginal communities have alluded to traditional use of the general area of the Project but no specific information has been provided to Treasury on either the location or extent of traditional use." Chapter 6.0, Effects Assessment, Treasury Metals Incorporated, Goliath Gold Project, Environmental Impact Statement, p. 6-2.

5. Absence of plausible rationale for the exclusion of TK from the assessment of biophysical and social VCs, as well as effects on treaty rights;

Link to Annex A1:
EA(1)-01

IR-1 Reference #: AC(1)-333
Page #: 5,6
Section 5 Concern/EA Process Item: Current Use of Lands and Resources for Traditional Purposes
Aboriginal Health and Socio-economic Conditions
Aboriginal Physical and Cultural Heritage
Structure, site, or thing of historical, archaeological, paleontological or architectural significance to Aboriginal groups
Comment:

6. Absence (non-aggregated) baseline studies with NFN to be able to meaningfully assess adverse effects on NFN:

1. Socio-economic and health conditions
2. Cultural heritage
3. Current use of lands and resources for traditional purposes
4. Any structure, site or thing that is of historical, archaeological, paleontological or architectural significance.

Link to Annex A1:
HE(1)-01
HE(1)-33
HE(1)-35
HE(1)-38
HE(1)-47

IR-1 Reference #: AC(1)-334
Page #: 6
Comment:

7. Absence of any suggested mitigation/avoidance and follow-up measures from NFN; and

Link to Annex A1:
AC(1)-01

IR-1 Reference #: AC(1)-335
Page #: 6
Section 5 Concern/EA Process Item: Aboriginal Consultation
Comment:

8. Inadequate consultation with NFN, including the failure of the Proponent to develop with NFN an appropriate consultation plan, and to give NFN sufficient opportunities comment on information provided by the Proponent in the language of NFN's choosing.

Link to Annex A1:
AC(1)-01

IR-1 Reference #: AC(1)-336
Page #: 6
Section 5 Concern/EA Process Item: Aboriginal Health and Socio-economic Conditions
Additional Information on Specific Deficiencies
Additional information on initial deficiencies identified with specific sections of the EIS is provided below.

• Baseline Studies for Human Environment (Chapter 5.11): The Proponent has conducted only two baseline studies for this section, both of which are seriously deficient and do not provide baseline information related to NFN
  • The socio-economic baseline study references three regional First Nations (Wabigoon Lake Ojibway Nation, Eagle Lake First Nation, Lac Seul First Nation) but does not include NFN, even though NFN is listed in the EISG.
  • The report sections related to First Nations are entirely desktop exercises that do not provide an adequate basis for assessing CEAA)(c) effects.
  • Furthermore, these sections of the report include internal First Nations funding arrangements that that were mined from the First Nations Financial Transparency Act section of the Aboriginal Affairs and Northern Development Canada (AANDC) website.

Link to Annex A1:
HE(1)-33
HE(1)-35

IR-1 Reference #: AC(1)-337
Page #: 6
Section 5 Concern/EA Process Item: Aboriginal Physical and Cultural Heritage
Structure, site, or thing of historical, archaeological, paleontological or architectural significance to Aboriginal groups
Comment:

• The Heritage and Archaeology study indicates that only a visual survey of the mining project area for sites of archaeological potential has been conducted. No cultural heritage study has been conducted. No evidence that NFN members have been consulted on cultural heritage in the vicinity of the mine site appears in the Proponent's EIS materials. The so-called heritage and archaeology study is a very high level, superficial assessment- e.g., with no First Nation consultation, no basic test pits. Apparently from a visual investigation of surface feature only the Proponent concluded that there is NO archaeological potential throughout the entire site. This limited archaeological study is the full extent of the heritage and archaeological work alluded to in the EIS. No reference whatsoever are included to First Nations' cultural and historical associations with the area in which the project is proposed.⁴

⁴ In contrast, the introduction to the socio-economic report (Appendix T) for Wabigoon Lake Ojibway Nation states, "Wabigoon Lake Ojibway Nation is a Fi rst Nation community in Northwestern Ontario. The ancient presence of Wabigoon Lake Ojibway Nation people on their Land is reflected in its vast forests and countless lakes, rivers and streams. This landscape is in turn reflected in them in their language, culture and way of life. Extensive fields of Manomin (wild rice) were planted by the ancestors and now form an abundant source of food for people and animals in the Region. Vast towering stands of pine, birch, cedar and spruce, as well as blueberries and other foods, were nurtured by an extensive knowledge and practice of co n trolled burning. The homeland of Wabigoon people is a n Ojibway cultural landscape." (emphasis added) Our intention in raising this comparison is not designed in any way to question the Wabigoon relationship to this a rea, but to point out that NFN's connection to this area- the area's role in the cultural landscape of the NFN, is not likewise contemplated by the Proponent.
Link to Annex A1:
HE(1)-47

IR-1 Reference #: AC(1)-338
Page #: 7,8
Section 5 Concern/EA Process Item: Aboriginal Consultation
Aboriginal Health and Socio-economic Conditions
Current Use of Lands and Resources for Traditional Purposes
Aboriginal Consultation
Comment:

• Baseline for Aboriginal Peoples section (5.11.5): This section does not provide a baseline for assessing the legislative requirements under CEAA 2012, section 5(1)(c) related to First Nations, and does not provide a baseline for assessing impacts to treaty rights. The section is essentially a summary of the inadequate "Country Foods Assessment", which is described further below.            
• Country Food Assessment (Appendix EE) is thoroughly inadequate.
  • There are no indications of direct studies on country food harvesting with individual Treaty 3 Nations being undertaken for the project, therefore there is no discussion of thresholds, preferred locations, timing and methods of harvesting, or change of harvesting practices over time.
  • This so-called "assessment" provides no information indicating that any country food studies were conducted with any of the Treaty 3

Nations. Any information provided appears to have been obtained from existing local studies that were conducted in the area from 2010-2014, but which are not specific to Treaty 3 Nations. All data appears to have been obtained from other studies, or alternatively, collected ad hoc through other indirect meetings, e.g., information obtained from CEA Agency or through meetings with Chief and Council. Most information is presented as an aggregate of First Nation and non-First Nation harvest data, a fundamentally flawed approach given the distinction between Aboriginal priority rights and non-Aboriginal interests. Any methodological discussion, including description of the level and type of engagement, in entirely absent.
Link to Annex A1:
HE(1)-01
HE(1)-38
HE(1)-43

IR-1 Reference #: AC(1)-339
Page #: 8,9
Section 5 Concern/EA Process Item: Aboriginal Consultation
Comment:

• Effects Assessment Chapter 6- Identification of Valued Components (6.3.2): In the introduction to Chapter 6 there is reference to "consultation" on VCs, but it does not specify that consultation was undertaken with any particular First Nations, and the precise way information was obtain from First Nations is unclear (e.g., "The CEA Agency, in discussion with Aboriginal communities has also identified issues and concerns."). It appears that much or all of the information that was collected by the Proponent did not come out of a proper consultation process, but was derived ad hoc through preliminary meetings with communities and review of First Nations' correspondence with CEAA. As a result, the evidence of meaningful consultation at least in reference to NFN- is slim to non-existent. For example, the specific section for how socio­ economic VCs were determined is approximately one page in length and does not provide any indication of what specific VCs or Kls were proposed by individual First Nations involved in the EA.

Link to Annex A1:
AC(1)-01

IR-1 Reference #: AC(1)-340
Page #: 9
Section 5 Concern/EA Process Item: Current Use of Lands and Resources for Traditional Purposes
Comment:

• Effects Assessment on Aboriginal Peoples (6.4.2.5): The inadequate baseline for all relevant VCs for NFN effectively guaranteed that any related effects assessment would also be insufficient. This is compounded by methodological errors in the effects characterization and significance estimation related to effects on aboriginal peoples. In general, deficiencies in this section are attributable to:
  • Prevalence of an implicit "go harvest elsewhere" argument made in section for "gathering of country foods and traditional plant materials". The Proponent's analysis has complete disregard for preferred locations, methods and timing of harvesting, and instead attempts to claim that the mine poses no adverse effects to treaty­ protected harvesting rights because First Nations can "go harvest elsewhere" in their territories. This is a common but thoroughly rebuked argument. Where such an argument is presented by a Proponent, the onus needs to be on the Proponent to identify where else the First Nation can go and pressures on harvesting in those alternative locations, as well as consider whether the areas where harvest will be impacted - the place the First Nation will be alienated from as a result of the Project - are preferred harvesting areas of heightened import. In addition, the Proponent and eventually the Crown ca n be subject to challenge to show how the loss of any aspect of the landscape that supports Treaty rights practices to industrial activity is justified and what forms of accommodation- and their adequacy- are committed to by the Proponent and the Crown for these infringements being contemplated;

Link to Annex A1:
HE(1)-38
HE(1)-43

IR-1 Reference #: AC(1)-341
Page #: 9
Section 5 Concern/EA Process Item: Fish and Fish Habitat
Comment:

• This section of the EIS is missing any reference to perception of risk related to the mine and mine effluent releases into Blackwater Creek

Link to Annex A1:
HE(1)-43

IR-1 Reference #: AC(1)-342
Page #: 9
Section 5 Concern/EA Process Item: Fish and Fish Habitat
Comment:

• Impacts by the mine on fish and fish habitat are undeniable, as it will require a DFO Section 35 authorization and fisheries offsetting (compensation) plan. In addition, NFN members have indicated that fishing licenses in the Project-affected area are of high importance to the Nation. The Proponent does not present adequate information on NFN commercial and subsistence fishing values in the EIS. Nonetheless, the Proponent insists that residual effects to fishing are not significant;

Link to Annex A1:
FH(1)-06
HE(1)-35
HE(1)-38
HE(1)-43

IR-1 Reference #: AC(1)-343
Page #: 9
Section 5 Concern/EA Process Item: Aboriginal Consultation
Comment:

• The methodology used for assessing magnitude and other criteria for characterizing residual effects is lacking transparency and certainly has not been subject to any vetting with NFN

Link to Annex A1:
EA(1)-01
AC(1)-01

IR-1 Reference #: AC(1)-344
Page #: 9
Section 5 Concern/EA Process Item: Current Use of Lands and Resources for Traditional Purposes
Comment:

• The section contains no reference to impacts on moose habitat (also identified as critical in this area to NFN Treaty rights practices), or impacts to migratory bird habitat; and

Link to Annex A1:
HE(1)- 45

IR-1 Reference #: AC(1)-344
Page #: 9
Section 5 Concern/EA Process Item: Current Use of Lands and Resources for Traditional Purposes
Comment:

• The section does not address the methodological limitation of assessing adverse effects on First Nations' current use of lands and resources for traditional purposes without the benefit of a study involving First Nations' traditional users of the Project vicinity. The logic and credibility of assessing effects on current use of lands and resources for traditional purposes without any knowledge of current use of lands and resources for traditional purposes, should be self-­ evidently unacceptable and begging for additional information requirements from the CEA Agency to the Proponent.

Link to Annex A1:
HE(1)-38

IR-1 Reference #: AC(1)-345
Page #: 9,10
Section 5 Concern/EA Process Item: Aboriginal Health and Socio-economic Conditions
Aboriginal Physical and Cultural Heritage
Current Use of Lands and Resources for Traditional Purposes
Comment:

• Overall, our review of the baseline and effects assessment sections of the EIS indicates that NFN's socio-economic and health conditions, tradition land and resource use activities, and cultural heritage have not been adequately described or characterized, nor have potential adverse effects on these valued components and NFN's treaty rights been properly assessed. Without a proper baseline of NFN's land use activities, the characterization of effects is necessarily deficient. For many of NFN's concerns, proposed mitigation and follow-up measures are either generic or undefined, or entirely absent.

This near-absent assessment of traditional land and resource use that appears to have been exclusively relied upon by the Proponent for addressing potential Project-specific and cumulative effects on treaty rights does not support meaningful consultation and accommodation between NFN and the Crown.
Link to Annex A1:
HE(1)-01
HE(1)-33
HE(1)-35
HE(1)-38
HE(1)-43
HE(1)-47

IR-1 Reference #: AC(1)-346
Page #: 10
Section 5 Concern/EA Process Item: Aboriginal Consultation
Comment:

• Ch. 8 Aboriginal and Public Engagement- 8.9 Aboriginal Concerns: This section is supposedly based on "Aboriginal concerns [that] have been identified to Treasury at meetings between Treasury and representatives of the Aboriginal communities, by means of letters sent by communities to Treasury and by means of comments made by communities to the CEA Agency which have been relayed to Treasury by the CEA Agency."  However, all concerns have been lumped together, with no distinct listing of concerns for each individual First Nation. This is contrary to recent practice by the CEA Agency, requiring greater distinction for each First Nations of concerns and potential adverse effects. NFN calls for CEAA to follow-up with requests for greater disaggregation of information that can lead to independent effects characterization for each affected First Nation.               

Link to Annex A1:
AC(1)-01

IR-1 Reference #: AC(1)-347
Page #: 10
Section 5 Concern/EA Process Item: Aboriginal Consultation
Comment:

• Aboriginal Consultation Report: Appendix DD: The sub-section that discusses the extent of consultation with NFN is only 2 pages long. The consultation log provided as an annex to the report indicates that only two preliminary meetings have been held with NFN's current Chief and Council.
• The report implies that NFN is too far away to have any treaty rights in the "project area" and that any concerns that NFN members may have related to water quality in Wabigoon Lake are unfounded and unwarranted. This is absolutely not the case. This gap in the Proponent's knowledge is troubling to NFN, as is the Proponent's willingness to make a liberal estimation of potential impacts on rights even without strong enough knowledge about our rights and interests in the Project-affected area (as opposed to a conservative/precautionary approach, the more proper way to estimate effects in the face of uncertainty - or better yet, the Proponent could seek engagement with the First Nation itself).
• This section is not informed by any TK or TUS studies. The Proponent notes as a "next step" potential TK studies with the Metis Nation of Ontario, Wabigoon Lake Ojibway Nation and Eagle Lake First Nation, but no reference is made to undertaking such studies with NFN or other Treaty 3 Nations involved in the EA.

Link to Annex A1:
AC(1)-01
EA(1)-01
HE(1)-38

IR-1 Reference #: AC(1)-348
Page #: 11
Section 5 Concern/EA Process Item: Fish and Fish Habitat
Comment:

• Effects on Fishing: The proposed Project is located within the Lower English-Wabigoon River Section of the Lake Wabigoon Ecoregion (potentially already historically contaminated). Further studies and assessment on effluent levels discharging into Wabigoon, other water bodies and downstream effects, is required. There is no evidence that thresholds related to contamination from tailings effluent into Blackwater Creek and Wabigoon Lake system has been properly discussed with NFN or other Treaty 3 Nations.

Link to Annex A1:
 SW(1)-19

IR-1 Reference #: AC(1)-349
Page #: 11
Section 5 Concern/EA Process Item: Current Use of Lands and Resources for Traditional Purposes
Comment:

• Effects on Hunting and plant harvesting: The EIS overlooks net adverse effects on Treaty 3 rights to hunting and plant harvesting in the vicinity of the Project area, and as mentioned previously instead relies upon a "go hunt elsewhere" rationale for assessing adverse effects as minimal and not significant. Potential for increased non-Aboriginal hunting & trapping pressure is acknowledged, however no mitigation, monitoring or follow-up measures are proposed (e.g., access management plan). This type of "catch and release" environmental assessment, where a potential impact is acknowledged, but never acted upon with any sort of plan, policy or other action to avoid, reduce, or compensate for the effect, is unacceptable to NFN, especially when critical Treaty rights are at risk.

Link to Annex A1:
HE(1)-38
HE(1)-43

IR-1 Reference #: AC(1)-350
Page #: 11
Section 5 Concern/EA Process Item: Accidents and Malfunctions
Comment:

• Accidents and Malfunctions: Breach of the Tailings Storage Facility (TSF): The EIS fails to either identify or address any potential adverse effects of a TSF breach on the treaty rights, current use of lands and resources for traditional purposes, and socio-economic conditions of NFN (and other Treaty 3 Nations). The EIS includes a TSF failure

model illustrating the extensive contamination that such an event would cause to Wabigoon Lake, especially Kelpyn Bay. Nonetheless, the EIS does not NFN's concerns in this regard are summarily dismissed by the Proponent as a remote possibility. The EIS makes no reference to any need for monitoring or a contingency/follow-up plan involving NFN (and other Treaty 3 Nations).
Link to Annex A1:
AM(1)-04

IR-1 Reference #: AC(1)-351
Page #: 11,12
Section 5 Concern/EA Process Item: Cumulative effects
Comment:

• NFN's initial review of the EIS did not have enough funding or time to fulsomely critique the Proponent's approach to cumulative effects. However, it is notable that there does not appear to be a comprehensive projects inclusions list (a list of all the other current and reasonably foreseeable future projects that might have impacts on the same VCs as Goliath) included in the EIS. Only 1 project (Wataynikaneyap Power, a proposed 300-km 230- kV transmission line that falls within the defined spatial boundaries of the cumulative effects study area) is identified as having potential to interact with potential effects of the Project. It is likely no other projects are identified primarily as a result of the Regional Study Area (RSA) being so small that few other projects are within its boundaries. Funding and time for additional review is required for NFN to conduct a close examination of cumulative effects. This type of effects assessment is especially important for NFN as we have been subject to Treaty rights infringements in other portions of our territory that have made our Nation both more reliant on the "Goliath" area and which have created long-standing and potentially significant pre-existing adverse effects on our Treaty rights.

Link to Annex A1:
CE(1) - 02

IR-1 Reference #: AC(1)-352
Page #: 12
Section 5 Concern/EA Process Item: Aboriginal Health and Socio-economic Conditions
Comment: Initial Conclusions About the Adequacy of the EIS
Gaps and flaws in the EIS include but are not limited to the following.
Overall, the approach the EIS appears to take is that NFN's rights and interests are centred too far afield from the Project and Project-affected area to merit close attention in this EA. This is far from the truth and NFN needs to be provided time, funding and opportunity to correct the record prior to the CEA Agency making any determinations on this proposed Project. This letter is only an initial step in that direction and cannot be read as adequate in terms of NFN's required examination of the EIS or a record of its concerns.
We contest the conclusion that "the Project will provide an economic net benefit to the local, Aboriginal, regional, and provincial economies and will not result in adverse impacts to Aboriginal and Treaty Rights or related interests." This claim is unfounded given that no socio-economic assessment on NFN has been conducted; no clear links have been made to benefits; and risks to the commercial fishery at Wabigoon Lake has been ignored.
Link to Annex A1:
HE(1)-37

IR-1 Reference #: AC(1)-353
Page #: 12
Section 5 Concern/EA Process Item: Aboriginal Physical and Cultural Heritage
Structure, site, or thing of historical, archaeological, paleontological or architectural significance to Aboriginal groups
Comment: The very limited archaeology study conducted to date is an inadequate basis upon which to make the assertion that "the Project is not expected to result in any significant adverse residual effects on the environment or heritage/cultural resources."
Link to Annex A1:
HE(1)-47
HE(1)-49

IR-1 Reference #: AC(1)-354
Page #: 12, 13
Section 5 Concern/EA Process Item: Accident and Malfunctions
Aboriginal Health and Socio-economic Conditions
Comment: A catastrophic break in the TSF has been modelled to bring significant contamination into Wabigoon Lake. This stands in stark contrast to the assertion that "any accidents or malfunctions that might occur as a result of the Project are not expected to result in significant adverse residual environmental or socioeconomic effects." Such an event would have significant adverse effects on the natural environment, socio-economic conditions, and our treaty rights.
Link to Annex A1:
AM(1)-01

IR-1 Reference #: AC(1)-355
Page #: 13
Section 5 Concern/EA Process Item: Cumulative effects
Comment: Finally, without proper baseline and effects assessments on human VCs and treaty rights, the claim that "the Project is not expected to result in any significant adverse cumulative effects on the environment or heritage/cultural resources" is simply not supportable.
Link to Annex A1:
HE(1)-37
HE(1)-43

IR-1 Reference #: AC(1)-356
Page #: 14
Section 5 Concern/EA Process Item: Aboriginal Health and Socio-economic Conditions
Aboriginal Consultation
Aboriginal Physical and Cultural Heritage
Current Use of Lands and Resources for Traditional Purposes
Comment: The CEA Agency and the Proponent must use this opportunity to ad dress gaps and deficiencies that place NFN's treaty rights and interests at risk. To do so, they must undertake a full assessment of:

1. Socio-Economic conditions
2. Health Conditions
3. Current use of lands and resources for traditional purposes
4. Cultural Heritage resources

Link to Annex A1:
AC(1)-01
HE(1)-01
HE(1)-33
HE(1)-38
HE(1)-43

IR-1 Reference #: AC(1)-357
Page #: 14
Comment: Further work is required to understand the intersection of NFN values with Project­ specific and cumulative effects pathways. We would like funding and opportunity to conduct community meetings to socialize the E IS and gather members' information about potential adverse effects (and benefits that may accrue).
These studies must be fully funded by the Proponent (or CEA Agency), conducted with NFN's full involvement and facilitated by a consultant of NFN's choosing. They must also include a potential scenario of a catastrophic release of TSF into both Blackwater Creek and Wabigoon Lake.
Link to Annex A1:
AC(1)-01

IR-1 Reference #: AC(1)-358
Page #: 14
Section 5 Concern/EA Process Item: Cumulative effects
Comment: In addition, the Regional Study Area (RSA) must be revised in order to permit proper consideration of cumulative effects and potential adverse effects of accidents and malfunctions on Wabigoon Lake. Currently the RSA only includes a small portion of the lake, however it is clear that potential effects on fish and water quality, as well as related traditional and commercial harvesting activities, need to be assessed throughout the entire lake system.
Link to Annex A1:
 CE(1)-01

IR-1 Addendum to Annex A3 September 11, 2015

Addendum to Annex A3 - Comments on the April 2015 Environmental Impact Statement for the Goliath Gold Project from Aboriginal Communities and Groups

The following tables include additional written submissions received by the Agency on the Environmental Impact Statement from Wabauskang First Nation, as follows:

• Table 6 – Agency Disposition of Written Comments Submitted by Wabauskang First Nation on the Environmental Impact Statement
• Table 7 – Agency Disposition of Written Comments Submitted by Wabauskang First Nation (Appendix A- Wabauskang First Nation EIS Technical Review)

Table 6- Agency Disposition of Written Comments Submitted by Wabauskang First Nation on the Environmental Impact Statement (Letter by Technical Consultant – on behalf of Wabauskang First Nation)

IR 1 Reference #: AC(1)-359
Page #: 1
Section 5 Concern/ EA Process item:  Aboriginal Consultation
Summary of Comment: The Wabauskang First Nation have conducted a review of the Project including the following documents: Environmental Impact Assessment guidelines "EISG" and the Environmental Impact Statement "EIS". The Goliath Gold Project is located within the territory of the Wabauskang First Nation, throughout which we hold Aboriginal Rights including treaty rights, title and interests. Engagement with us is an integral component of our consultation process to ensure that our rights are not impacted in a way that compromises our constitutional rights as identified in Section 35. We have a right to ensure and protect our "way of life" including the recognition of the interconnection between all living things within our Territory for future generations.
Link to Annex A1:
AC(1)-01

IR 1 Reference #: AC(1)-360
Page #: 1
Section 5 Concern/ EA Process item:  Aboriginal Consultation,
Current Use of Lands and Resources for Traditional Purposes
Summary of Comment: While our specific comments are summarized below and provided in the attached table in Appendix A, we also summarize our comments in the following statements:

• Lack of understanding of the lands and the importance to the Aboriginal peoples in the area
• Lack of Traditional Knowledge in all aspects of the Project and Project Design
• Lack of Traditional Land use in all aspects of the Project and Project Design

Link to Annex A1:
AC(1)-01
EA(1)-01
HE(1)-38

IR 1 Reference #: AC(1)-361
Section 5 Concern/ EA Process item:  Current Use of Lands and Resources for Traditional Purposes
Summary of Comment:

• Inadequate understanding of the local and regional environments
• Inadequate Environmental Baseline Data
• Lack of Environmental Management Plan

Link to Annex A1:
EA(1)-02
EA(1)-07

IR 1 Reference #: AC(1)-362
Section 5 Concern/ EA Process item:  Aboriginal Physical and Cultural Heritage
Summary of Comment:

• Inadequate Heritage Resources Information

Link to Annex A1:
HE(1)-47

IR 1 Reference #: AC(1)-363
Page #: 2
Section 5 Concern/ EA Process item:  Current Use of Lands and Resources for Traditional Purposes,
Fish and Fish Habitat
Summary of Comment:
Baseline Studies: Inadequacies and Data "Gaps"
The technical review of the baseline studies completed for the Goliath Gold Project revealed the following four major faults with the studies:

• The baseline studies were found to be inadequate given the scope and proximity to critical wildlife, fisheries and aquatic habitat.
• Generally, the data was found to be inconsistent and not comparable and no "control" sites were used. Two different consultants were used to set up baseline programs and it is unclear if the same methodologies were used. It was evident in some of the studies that different sample locations were used.
• There were a number of follow up recommendations made by the consultants and it remains unclear if the proponent completed the recommendations.
• There is no indication of on-going baseline studies.

Link to Annex A1:
HE(1)-45
FH(1)-02
FH(1)-04
FH(1)-10
FH(1)-11
WL(1)-01
WL(1)-02
WL(1)-03
WL(1)-05
WL(1)-08
WL(1)-10
WL(1)-11
WL(1)-12
WL(1)-14
WL(1)-16
WL(1)-19

IR 1 Reference #: AC(1)-364
Page #: 2,3
Section 5 Concern/ EA Process item:  
Summary of Comment:
Climate
The climate data provided in the EIS was developed from Environment Canada data stations with the closest station approximately 12 km away from Project site with no project specific climate data. There does not appear to be 2 years of Project specific continuous data as data used in the study spans from different years. When considering this data in an EIS, it does not demonstrate how it represents current weather conditions on the site and when considering this data for model development and predictions, it creates significant risk as it introduces very broad assumptions to the model. When considering TMF operations or water quality predictions, it could lead to very unpredictable results which may result in significant impact to the local environment and WFN rights and interests. Additional data collection with new weather stations should be implemented.
EIS Observations, three sites were used:

1. Dryden (1914-1997) 16 km away from Project site
2. Dryden A (1970-2005) 12.9 km away from Project site
3. Sioux Lookout A 65 km away (1938-2007)

Questions:

• Are the Elevations of these stations different from the project site?
• Some rainfall data is from 1915-1936. How is that relevant to the region today?
• No ongoing baseline data collection was evident in the EIS. Is there a plan for ongoing baseline data collection and where will the stations be located?

Link to Annex A1:
EE(1)-06
SW(1)-09
SW(1)-34

IR 1 Reference #: AC(1)-364
Page #: 3
Section 5 Concern/ EA Process item:  Fish and Fish Habitat
Summary of Comment:
Hydrology
Through our review of the hydrology studies provided in the EIS, it was found that the majority of information gathered was done through literature review. Further detail regarding our findings can be found in the table in Appendix A. Based on our findings we were unable to complete a detailed assessment of potential impacts as the information provided in the EIS was incomplete and not site specific.
EIS Observations:

1. 2010/2011 information does not include a full two years of data.
2. Only one sample collected in December 2010.
3. Only one full year of data

Questions:

• Have methodologies changed? If so, how can the data be comparable? It appears the methodologies changed in March 2011
• No ongoing baseline data collection was evident in the EIS. Is there a plan for ongoing baseline data collection?

Link to Annex A1:
SW(1)-29

IR 1 Reference #: AC(1)-365
Page #: 3
Section 5 Concern/ EA Process item:  Fish and Fish Habitat
Summary of Comment:
Water Quality
Our review of the water quality baseline data provided have identified a number of data gaps and concerns regarding water quality predictions related to the project. Overall, we found the number of sampling locations to be limited and the data sample collection to be incomplete. Another important aspect of scientific analysis including the collection and interpretation of water quality data is the establishment of a control location. Through our review and analysis, we were not able to determine if a control sample location as established for the water quality program. Given the close proximity of the Project to water sources of importance to both local communities and the WFN, additional work is required to establish a reasonable baseline data set for impact predictions.
EIS Observations:

1. 7 sample locations (4 on Black Water Creek)
2. 2010/2011 information does not include a full two years of data. Only one sample collected in December 2010.
3. Only one full year of data
4. No control sample location
5. No ongoing baseline data collection

Link to Annex A1:
SW(1)-20

IR 1 Reference #: AC(1)-366
Page #: 3,4
Section 5 Concern/ EA Process item:  Fish and Fish Habitat
Summary of Comment:
Hydrogeology
In our review of the EIS, we found limited hydrogeology data. Further details of our review are provided in Appendix A.
EIS Observations:

1. Feb 2011 one site visit
2. 12 soil test pits

Link to Annex A1:
GW(1)-01
GW(1)-22

IR 1 Reference #: AC(1)-367
Page #: 4
Section 5 Concern/ EA Process item:  Current Use of Lands and Resources for Traditional Purposes
Summary of Comment:
Wildlife
Wildlife studies and predictions in the EIS lacked traditional knowledge data to determine importance of wildlife values to WFN. Additional details regarding our review are provided in Appendix A.
EIS Observations:

1. Did not find any 2010 results
2. Local Study Area only 5 km
3. Oct 13 /Oct 15 2011 song bird count-would this be a good time of year for this? should be completed in spring?
4. May 12 2011 and June 16 2011-June 14 2011 & July 12 2011 Marsh and Waterfowl Survey
5. Mammal Field Sign recorded when at site-no mammals observed
6. Amphibian Survey June 12 & 16, 2011
7. Bats survey June 2011
8. Historical Literature review

Questions:

• Did not see any discussion on Caribou? are they present in this area?

Link to Annex A1:
EA(1)-01
HE(1)-45
WL(1)-01
WL(1)-08
WL(1)-10
WL(1)-11
WL(1)-12
WL(1)-14
WL(1)-19

IR 1 Reference #: AC(1)-368
Page #: 4
Section 5 Concern/ EA Process item:  Current Use of Lands and Resources for Traditional Purposes
Fish and Fish Habitat
Summary of Comment:
Wetland Survey
The EIS provided very little information regarding the wetland values in the area of the Project. The wetlands are home to many species that hold significant value to WFN. The lack of compensation planning for the proposed alteration of wetland areas is a significant gap in the EIS.
EIS Observations:

1. June 2011 & August 2011
2. Significant vegetation communities found
3. Thunder Lake, BW Creek and Nugget Creek Wetlands provide habitat, wild rice, staging for waterfowl and spawning and nursery habits for fish.
4. Provincially rare species-Floating Marsh Marigold

Link to Annex A1:
EA(1)-01
FH(1)-11
HE(1)-45
WL(1)-02
WL(1)-03
WL(1)-07

IR 1 Reference #: AC(1)-369
Page #: 4,5
Section 5 Concern/ EA Process item:  Current Use of Lands and Resources for Traditional Purposes,
Fish and Fish Habitat
Summary of Comment:
Fisheries
A number of observations were made regarding fisheries data and studies provided in the EIS. Details regarding our specific concerns are provided in Appendix A. Generally, it was observed that the fisheries information and conclusions provided lacked traditional knowledge from the local First Nations including WFN. Given the significant data gaps and lack of traditional knowledge, it was difficult to determine impacts related to the Project on fisheries values.
EIS Observations:

• Field work focused on LSA and Regional Study Area (RSA) only literature review
• Nov 15-19 2010 (5 days not a full year of data in 2010)
• 2011-66 samples-No winter samples
  • May 9-13 2011
  • June 13-17 2011
  • July 10-17 2011
  • August 3-9 2011
  • Oct 13-19 2011
• Benthic Invertebrates Oct 16-17 2011
• Wabigoon Lake (creek mouth) designated Provincial Fish Sanctuary to protect spawning Walleye and fishing is prohibited during Walleye spawning season.
• 24-27 fish species
• Sediment Sampling 5 sampling locations Oct 16 and 17th 2011 - no seasonal variation?

Link to Annex A1:
EA(1)-01
FH(1)-06
FH(1)-10
FH(1)-20
HE(1)-38
HE(1)-43

IR 1 Reference #: AC(1)-370
Page #: 5
Section 5 Concern/ EA Process item:  Fish and Fish Habitat
Summary of Comment:
Aquatics Baseline
Our review of the aquatics baseline data provided have identified a number of data gaps and overall concerns. We found the number of sampling locations to be limited, the data sample collection to be incomplete and the program lacked a control location. Given the close proximity of the Project to fisheries values of importance to both local communities and the WFN, additional work is required to establish a reasonable baseline data set for impact predictions.
EIS Observations:

• 2 years data but not consistent sample site locations and different consultants and no control sites.
• 2011 & 2012 some comparable data but some data collected at different locations
• 2013 only habitat mapping

Link to Annex A1:
FH(1)-04
FH(1)-06
FH(1)-10
FH(1)-20

IR 1 Reference #: AC(1)-371
Page #: 5
Section 5 Concern/ EA Process item:  Aboriginal and Treaty rights, Current Use of Lands and Resources for Traditional Purposes
Summary of Comment:
Potential Environmental Impacts from the Goliath Gold Project
Based on our review, we find that the EIS is currently deficient in both WFN information as well as baseline data to be able to assess potential impacts to the local environment and WFN rights and interests. There are a number of aspects of the project which we feel requires further work to address data gaps as well as concerns that have been identified by WFN and other Treaty 3 Nations potentially impacted by the Project. In this section, we have identified a number of specific areas for consideration as we find that the potential impacts could have significant effects on WFN rights and interests.
Link to Annex A1:
HE(1)-01
HE(1)-23
HE(1)-33
HE(1)-35
HE(1)-38
HE(1)-39
HE(1)-45 

IR 1 Reference #: AC(1)-372
Page #: 5
Section 5 Concern/ EA Process item:  Fish and Fish Habitat
Summary of Comment: The operation of the TMF and the proposed location and proximity could impact water quality, fish and aquatic environments in both Wabigoon Lake (drainage south to Wabigoon) and Thunder Lake (drainage west to Thunder Lake).
Link to Annex A1:
MW(1)-02
MW(1)-23
GW(1)-03
GW(1)-07
SW(1)-02
SW(1)-04
SW(1)-25

IR 1 Reference #: AC(1)-373
Page #: 5
Section 5 Concern/ EA Process item:  Alternatives Assessment
Summary of Comment: There is a lack of technical data to support alternative assessment of TMF location (including TMF effluent discharge). For example TMF #3 and Hartman Lake reasoning for excluding these two locations were economics but a comparison of detailed environmental benefits were not found or was a detailed economic review.
Link to Annex A1:
AA(1)-11

IR 1 Reference #: AC(1)-374
Page #: 5
Section 5 Concern/ EA Process item:  Accidents and Malfunctions
Summary of Comment: The potential for a Tailings Dam breech could cause irreversible significant environmental effects to water quality, fish and aquatic habitats.
Link to Annex A1:
AM(1)-04
AM(1)-05

IR 1 Reference #: AC(1)-375
Page #: 5
Section 5 Concern/ EA Process item:  Current Use of Lands and Resources for Traditional Purposes, Fish and Fish Habitat
Summary of Comment: During the construction of the Project, 9 wetlands will be destroyed and altered. The EIS did not identify a wetland compensation plan (3 provincially significant avian species at 5 of the wetlands). Also, there is less than one year of baseline work completed so there is a lack of understanding of the wetland ecosystem (Thunder Wetland is considered significant).
Link to Annex A1:
PD(1)-01
WL(1)-03
FH(1)-11

IR 1 Reference #: AC(1)-376
Page #: 6
Section 5 Concern/ EA Process item:  Fish and Fish Habitat
Summary of Comment: The majority of waste rock has been classified as Potentially Acid Generating (PAG) there are limited closure and remediation plans to ensure this material remains stable long term and post closure.
Link to Annex A1:
MW(1)-11
MW(1)-14

IR 1 Reference #: AC(1)-377
Page #: 6
Section 5 Concern/ EA Process item:  Current Use of Lands and Resources for Traditional Purposes
Summary of Comment: Inadequate Environmental Management System Framework and Environmental Management Plan outline. (For example did not find a frame work for a Construction Management Plan (CEMP) Operational Management Plan (OEMP)).
Link to Annex A1:
EA(1)-07

IR 1 Reference #: AC(1)-378
Page #: 6
Section 5 Concern/ EA Process item:  Current Use of Lands and Resources for Traditional Purposes
Summary of Comment: We have concerns regarding the protection of traditional food sources (i.e. wild rice- Black water Creek 2.4 ha wild rice exists currently-Thunder Creek 5.1 ha wild rice exists currently).
Link to Annex A1:
HE(1)-38
HE(1)-45

IR 1 Reference #: AC(1)-379
Page #: 6
Section 5 Concern/ EA Process item:  Aboriginal Health and Socio-economic Conditions
Summary of Comment: We have concerns regarding the potential contamination of wild meat due to lack of any wildlife (large mammal) baseline studies and identification of pathways.
Link to Annex A1:
HE(1)-01
WL(1)-05

IR 1 Reference #: AC(1)-380
Page #: 6
Section 5 Concern/ EA Process item:  Cumulative Effects
Summary of Comment: No linkage between mining and forestry cumulative effects. (i.e. roads and fragmentation or sediment and erosion effects).
Link to Annex A1:
CE(1)-02

IR 1 Reference #: AC(1)-381
Page #: 6
Section 5 Concern/ EA Process item:  Aboriginal Consultation
Summary of Comment:
Recommendations             
Based on our review and findings, we are recommending the following actions:

• WFN consultation protocol be implemented by both CEAA and Treasury Metals
• A plan to address all data gaps, questions and concerns be developed and provided to WFN for review and comment
• Once all information requests have been addressed, a suitable period of time should be provided to WFN to review information provided

Link to Annex A1:
EA(1)-01
AC(1)-01

Table 7- Agency Disposition of Written Comments Submitted by Wabauskang First Nation (Appendix A- Wabauskang First Nation EIS Technical Review)

IR 1 Reference #: AC(1)-382
Number: 0.0
Section Title: Executive Summary
Title: 4.0 Project Overview
Page#: 11
Gap: No First Nations Map in this section
Comment: Should have a First Nations Map in the beginning of the document so readers fully understand the proximity of the Project to local communities.

IR 1 Reference #: AC(1)-383
Number: 0.0
Section Title: Executive Summary
Title: 4.0 Project Overview
Page#: 11
Gap: No First Nations Overview in this section
Comment: Should have a First Nations overview in the beginning of the document. A written summary of distance to project in the beginning of document so readers fully understand potential impacts.

IR 1 Reference #: AC(1)-384
Number: 0.0
Section Title: Executive Summary
Title: 4.0 Project Overview
Page#: 11
Sub-title: 2
Gap: Project design list does not include design for continual remediation for LOM

IR 1 Reference #: AC(1)-385
Number: 0.0
Section Title: Executive Summary
Title: 4.0 Project Overview
Page#: 11
Sub-title: 2
Gap: Project design list does not include "to minimize potential impacts to Aboriginal communities and traditional lifestyles
Comment: This should be highlighted as a critical component of the Project design considerations.

IR 1 Reference #: AC(1)-386
Number: 0.0
Section Title: Executive Summary
Title: 4.2 Open Pit Mine
Page#:
Sub-title: Figure ES 4.4 Aerial View of Proposed Open Pit Area
Gap: 4.2.2 Surface and Mine Water Management
Is there sufficient baseline
to support the statement" there are no permanent ponds or lakes that require dewatering"
Comment: Picture shows what appears to be a large pond/ wetland or bog but the paragraph states that there are no permanent ponds or lake dewatered? Is that one of the nursery ponds? Please explain
Link to Annex 1: PD(1)-01

IR 1 Reference #: AC(1)-387
Number: 0.0
Section Title: Executive Summary
Title: 4.5 Processing
Page#: 27
Sub-title: 4.5.1.1 Water Supply
Gap: How does the Proponent expect to have nil water consumption at closure while committing to ensuring the PAG rock remains submerged so acidic conditions won't occur post closure?
Comment: Need clarification on how this will be monitored?
Link to Annex 1: MW(1)-13
SW(1)-17
SW(1)-25

IR 1 Reference #: AC(1)-388
Number: 0.0
Section Title: Executive Summary
Title: 4.5 Processing
Page#: 30
Sub-title: 4.5.4.3 Reagent Mixing and Storage
Gap: Waste Management Plan
Comment: Will there be a Waste Management Plan developed? Will the tree nursery be upgraded to handle these reagents? What mitigation and emergency response management processes will be implemented?
Link to Annex 1: AM(1)-01
RG(1)-21

IR 1 Reference #: AC(1)-389
Number: 0.0
Section Title: Executive Summary
Title: 4.6 Tailings Storage Facility (TSF)
Page#: 36/ 39
Sub-title: 4.6.3 Seepage Control
Gap: Seepage Management Plan (SeMP)
Comment: SeMP should be developed in consultation with WFN to ensure all WFN interests are understood and any impacts can be mitigated? If water quality started to deteriorate in Thunder Lake what would the mitigation plan be? Considering it is only 1.5 KM from Thunder Lake it could cause potential adverse effects to the lake.
Link to Annex 1: MW(1)-11
GW(1)-03
GW(1)-07
SW(1)-02
SW(1)-06
SW(1)-25

IR 1 Reference #: AC(1)-390
Number: 0.0
Section Title: Executive Summary
Title: 4.6 Tailings Storage Facility (TSF)
Page#: 38/ 39
Sub-title: 4.6.6 Monitoring
Gap: Tailings Storage Facility Management Plan (TSFMP)
Comment: A TSFMP should be developed in consultation with WFN to ensure all WFN interests are identified and any potential impacts to these interests are addressed through mitigation.
Link to Annex 1: EA(1)-06

IR 1 Reference #: AC(1)-391
Number: 0.0
Section Title: Executive Summary
Title: 4.7 Water Management
Page#: 40
Sub-title: 4.7.2 Water Supply for Process Plant Operations
Gap: Tree Nursery Irrigation Ponds water supply
Comment: Do these ponds naturally recharge? What if there is a drought year?
Link to Annex 1: GW(1)-21

IR 1 Reference #: AC(1)-392
Number: 0.0
Section Title: Executive Summary
Title: 4.7 Water Management
Page#: 42
Sub-title: 4.7.5 Final Effluent Discharge
Gap: Provide effluent water quality parameters after treatment?
Comment: Need to know the predicted water quality after treatment prior to discharge to Black Water Creek?
Link to Annex 1: SW(1)-19

IR 1 Reference #: AC(1)-393
Number: 0.0
Section Title: Executive Summary
Title: 4.8 Fuel and Chemical Management
Page#: 44
Sub-title: 4.8 Fuel and Chemical Management
Gap: Waste Management Plan/Wildlife Effects Management Plan
Comment: Will the fuel be kept in double walled tanks and a lined berm? Will fuel and chemicals be kept in appropriate locations and stored so wildlife is not attracted to it and cannot access it?

IR 1 Reference #: AC(1)-394
Number: 0.0
Section Title: Executive Summary
Title: 4.13 Closure and Decommissioning
Page#: 49
Sub-title: 4.13.1 Open Pit Mine
Gap: Waste Management Plan/Wildlife Effects Management Plan
Comment: Will the fuel be kept in double walled tanks and a lined berm? Will fuel and chemicals be kept in appropriate locations and stored so wildlife is not attracted to it and cannot access it?

IR 1 Reference #: AC(1)-395
Number: 0.0
Section Title: Executive Summary
Title: 4.13 Closure and Decommissioning
Page#: 50
Sub-title: 4.13.1 Open Pit Mine
Gap: Waste Rock Management Plan/Closure and Remediation Plan
Comment: How will the water levels after closure be maintained to ensure PAG rock is not exposed over the long term?
Link to Annex 1: MW(1)-13

IR 1 Reference #: AC(1)-396
Number: 0.0
Section Title: Executive Summary
Title: 5.2 Project Phases
Page#: 56
Sub-title: 5.2.1 Site Preparation Phase
Comment: Bullet 2 mentions that the dewatering of ponds and wetlands will occur during this phase but in the project overview it states no dewatering required? Please clarify. How will the loss of wetlands be compensated for?
Link to Annex 1: PD(1)-01

IR 1 Reference #: AC(1)-397
Number: 0.0
Section Title: Executive Summary
Title: 5.2 Project Phases
Page#: 57
Sub-title: 5.2.1 Site Preparation Phase
Gap: Environmental Management (Policies, plans monitoring, reporting, internal audits etc?) Site Preparation Environmental Management Plan (SPEMP)
Comment: What and where are the existing environmental protection and plans? Is there an environmental monitor on?site for these activities and how will the workers be trained?
Link to Annex 1: EA(1)-07

IR 1 Reference #: AC(1)-398
Number: Number: 0.0
Section Title: Executive Summary
Title: 5.2 Project Phases
Page#: 57
Sub-title: 5.2.1 Site Preparation Phase
Gap: Environmental Management-(Policies, plans, monitoring, reporting, internal audits etc?)
Construction Environmental Management Plan (CEMP)
Comment: Need clarification on how/when this will be developed, managed and executed?
Link to Annex 1: EA(1)-07

IR 1 Reference #: AC(1)-399
Number: 0.0
Section Title: Executive Summary
Title: 5.2 Project Phases
Page#: 58
Sub-title: 5.2.1 Site Preparation Phase
Gap: Environmental Management?(Policies, plans, monitoring, reporting, internal audits etc.?)
Closure Environmental Management Plan (CL
Comment: Need clarification on how/when this will be developed, managed and executed?
Link to Annex 1: EA(1)-07

IR 1 Reference #: AC(1)-400
Number: 0.0
Section Title: Executive Summary
Title: 6.0 Description of the Environment
Page#: 64
Sub-title: 6.6 Hydrogeology, and Groundwater Quality
Gap: Seepage and Groundwater Management Plan
Comment: It is indicated in the second paragraph that the water wells are 1.5KM on Thunder Lake? Are these sample wells or drinking wells? What are the on?going monitoring plans to ensure that Groundwater and seepage do not potentially impact Thunder Lake and Wabigoon Lake other Groundwater?
Link to Annex 1: GW(1)-15
GW(1)-17

IR 1 Reference #: AC(1)-401
Number: 0.0
Section Title: Executive Summary
Title: 6.0 Description of the Environment
Page#: 64
Sub-title: 6.6 Hydrogeology, and Groundwater Quality
Predicted Effects on Groundwater TMA and WRSA Leakage
Gap: Inadequate ground water baseline (6 samples in 2013)
Lack of Management and mitigation plans to address the potential of impacts to Hoffman's Bay Tributary, Thunder Lake Tributary # 3 and Blackwater Creek and ultimately Thunder Lake given the close proximately to Thunder Lake and Wabigoon Lake and related high value fisheries.
Comment: Insufficient data to complete effects assessment.
Further data collection is required.
Link to Annex 1: GW(1)-01
GW(1)-22
EA(1)-01

IR 1 Reference #: AC(1)-402
Number: 0.0
Section Title: Executive Summary
Title: 6.0 Description of the Environment
Page#: 66
Sub-title: 6.6 Hydrogeology, and Groundwater Quality
Predicted Effects on Groundwater TMA and WRSA Leakage
Comment: The ground water samples that exceeded the Canadian Environmental Quality Guidelines (CEQG) what is the cause is it a natural exceedance due to mineralization?

IR 1 Reference #: AC(1)-403
Number: 0.0
Section Title: Executive Summary
Title: 6.0 Description of the Environment
Page#: 66
Sub-title: 6.7 Vegetation
Gap: Consideration of the impact of potentially contaminating the wild rice (Country Food) with the transfer of mine impacted groundwater.
Comment: Insufficient data to complete effects assessment.
Further data collection is required.
Link to Annex 1: HE(1)-45

IR 1 Reference #: AC(1)-404
Number: 0.0
Section Title: Executive Summary
Title: 6.0 Description of the Environment
Page#: 67
Sub-title: 6.8 Wildlife
Gap: Inadequate wildlife baseline studies
Comment: Given the lack of observations of wildlife the survey methodology should be reviewed and on?going baseline studies should be conducted to ensure a solid understanding of the wildlife populations within the project area (i.e. grazing areas, calving, migration, etc.)
Link to Annex 1: HE(1)-45
WL(1)-08
WL(1)-10
WL(1)-11
WL(1)-12
WL(1)-14

IR 1 Reference #: AC(1)-405
Number: 0.0
Section Title: Executive Summary
Title: 6.0 Description of the Environment
Page#: 67
Sub-title: 6.9 Aquatic Biology
Gap: Inadequate aquatic and fisheries baseline studies
Comment: Given the projects close proximity to high value aboriginal fisheries (Wabigoon Lake) and Thunder Lake (in addition to multiple small tributaries, creeks) and the potential for lasting adverse impacts requires a complete understanding of the local aquatic and fisheries habitat. Additional and on?going baseline studies should be required. It also appears in 2011 more sample sites were visited then in 2012? Were they the same locations? Is the data consistent and comparable?
Link to Annex 1: FH(1)-04
FH(1)-06
FH(1)-10
FH(1)-20

IR 1 Reference #: AC(1)-406
Number: 0.0
Section Title: Executive Summary
Title: 6.0 Description of the Environment
Page#: 68
Sub-title: 6.10 Land and Resource Use, Traditional Knowledge and Land Use
Gap: Traditional Knowledge and Traditional Land Use (TK/TU) Study should be completed and the information incorporated into the EIS/EA
Comment: The EIS lacks a traditional knowledge study of the WFN which is a gap throughout the EIS. A proper impact assessment of WFN aboriginal and treaty rights cannot be completed without an understanding of the baseline conditions before the mine and the potential impacts related to mine development.
Link to Annex 1: EA(1)-01
HE(1)-35

IR 1 Reference #: AC(1)-407
Number: 0.0
Section Title: Executive Summary
Title: 6.0 Description of the Environment
Page#: 68
Sub-title: 6.12 Archeology
Gap: Archaeological Assessment Investigation/Chance Find Procedure/Employee training
Comment: The proponent should seek confirmation from Aboriginal groups regarding Archaeological sites. Obtaining TK/TU information could assist in guiding the way to finding existing Archaeological locations.
Link to Annex 1: HE(1)-47

IR 1 Reference #: AC(1)-408
Number: 0.0
Section Title: Executive Summary
Title: 9.0 Aboriginal Engagement
Page#: 80
Sub-title: 9.2 Effects on Fishing
Gap: Inadequate aquatic and fisheries baseline studies
Comment: The statement that there will be no impacts to fishing identifies a significant data gap and lack of understanding of the local fish and aquatic habitat. Although treated water will be discharged to Blackwater creek the migration of untreated groundwater from Waste rock and the TSF could have definite potential adverse impacts to fishing (i.e. fish populations and fish health).
Link to Annex 1: FH(1)-06
GW(1)-02
GW(1)-03
GW(1)-17

IR 1 Reference #: AC(1)-409
Number: 0.0
Section Title: Executive Summary
Title: 9.0 Aboriginal Engagement
Page#: 81
Sub-title: 9.3 Effects on Hunting and Trapping
Gap: Inadequate wildlife baseline studies
Comment: The change in landscape with the development of a gold mine for animals requires more understanding of the wildlife and habitat on a larger scale. Metal bioaccumulation in wild meat needs to be monitored.
Link to Annex 1: HE(1)-01
HE(1)-45
WL(1)-01
WL(1)-05

IR 1 Reference #: AC(1)-410
Number: 0.0
Section Title: Executive Summary
Title: 9.0 Aboriginal Engagement
Page#: 81
Sub-title: 9.4 Gathering Plants and Berries
Gap: Inadequate TK/TU information/Country Foods Baseline
Comment: WFN have not been contacted regarding their practices for gathering plants and berries. This activity is an aboriginal right and the lack of specific details provided in the EIS does not provide reasonable information to undertake a proper impact assessment of this important activity. Additional investigation through a TK/TU study of the project area is required.
Link to Annex 1: EA(1)-01
HE(1)-38

IR 1 Reference #: AC(1)-411
Number: 0.0
Section Title: Executive Summary
Title: 14.0 Monitoring
and Environmental Management Plans
Page#: 129
Gap: It is understood that the EMP list is not exhaustive at this point but critical EMPs should be highlighted in the EIS such as Aquatic Effects Monitoring Plan (AEMP), Fisheries Effects Monitoring Plan, Water Quality Management and Monitoring Plan.
Comment: Cultural Awareness is listed under EMP but should belong under the training component of the EMS?(CEMP/OEMP)

IR 1 Reference #: AC(1)-412
Number: 1.0
Section Title: Introduction & Project Overview
Title: 1.1 The Proponent
Page#: 3
Sub-title: 1.1.1 Corporate Management Structure
Comment: What exactly are the 2 environmental positions listed?

IR 1 Reference #: AC(1)-413
Number: 1.0
Section Title: Introduction & Project Overview
Title: 1.1 The Proponent
Page#: 4
Sub-title: 1.1.4 Environmental Management Plan (EMP)
Gap: Inclusion of an EMP Structure and plan overview
Comment: Further details regarding the EMP are required. It is the bullets listed appear to be referring to the company's "guiding environmental policy" not an EMP
Link to Annex 1: EA(1)-07

IR 1 Reference #: AC(1)-414
Number: 1.0
Section Title: Introduction & Project Overview
Title: 1.1 The Proponent
Page#: 5
Sub-title: 1.1.4 Environmental Management Plan (EMP)
Gap: Is the Project going to become eligible for ISO14001 Certification and on?going environmental audits?

IR 1 Reference #: AC(1)-415
Number: 1.0
Section Title: Introduction & Project Overview
Title: 1.1 The Proponent
Page#: 5
Sub-title: 1.1.4 Environmental Management Plan (EMP)
Gap: Will an information system be used to assist in the management and monitoring of the EMS?

IR 1 Reference #: AC(1)-416
Number: 2.0
Section Title: Alternatives Description
Title: 2.3 Project Alternatives?Construction and Operations
Page#: 32
Sub-title: 2.3.7.3 Nearby Lakes
Gap: Has Hartman Lake been fully assessed as an option for TSF discharge? Is it fish bearing would it be a better alternative environmentally than Black Water Creek even if the monetary cost is higher?
Comment: Request for further investigation & information
Link to Annex 1: MW(1)-04

IR 1 Reference #: AC(1)-417
Number: 3.0
Section Title: Project Description
Title: 3.2 Project Phases & Schedule
Page#: 8
Sub-title: 3.2.2 Construction Phase
Gap: Construction Environmental Management Plan
Comment: Plan should be developed and provided.
Link to Annex 1: EA(1)-07

IR 1 Reference #: AC(1)-418
Number: 3.0
Section Title: Project Description
Title: 3.7 Tailings Storage Facility
Page#: 31
Sub-title: 3.7.3 Seepage Control
Gap: Seepage Management and Monitoring Plan
Comment: Plan should be developed and provided.
Link to Annex 1: GW(1)-02

IR 1 Reference #: AC(1)-419
Number: 3.0
Section Title: Project Description
Title: 3.8 Water Management
Page#: 52
Sub-title: 3.8.8 Water Management Structures
Gap: "Surface water runoff from the processing plant site not expected to require treatment"
Comment: Could this not potentially cause changes to the water chemistry in Black Water Creek and couldn't a catchment be installed as a preventative measure in this case?                 
Link to Annex 1: SW(1)-19

IR 1 Reference #: AC(1)-420
Number: 3.0
Section Title: Project Description
Title: 3.8 Water Management
Page#: 53
Sub-title: 3.8.10 Aquatic Habitat Rehabilitation
Gap: Will the loss of wetlands throughout the project area be included in the compensation plan?
Comment: Wetlands are a critical component of this ecosystem this project will permanently remove 9 from the ecosystem.
Link to Annex 1: PD(1)-01
WL(1)-03
WL(1)-11

IR 1 Reference #: AC(1)-421
Number: 5.0
Section Title: Existing Environment
Title: 5.8 Aquatic Resources
Page#: 57
Sub-title: 5.8.1 Surface Water Quality
Gap: Limited and inconsistent WQ baseline program.
Comment: Is there on?going baseline studies? Was the control sample only sampled once?
Link to Annex 1: SW(1)-22

IR 1 Reference #: AC(1)-422
Number: 5.0
Section Title: Existing Environment
Title: 5.8 Aquatic Resources
Page#: 58
Sub-title: 5.8.1 Surface Water Quality
Gap: Figure 5.8.1 ? Why were no samples collected further out in Thunder Lake, Wabigoon Lake and on Thunder Creek?
Comment: Further explanation is required.
Link to Annex 1: SW(1)-20

IR 1 Reference #: AC(1)-423
Number: 5.0
Section Title: Existing Environment
Title: 5.8 Aquatic Resources
Page#: 69
Sub-title: 5.8.2 Sediment Samples
Gap: Figure 5.8.2 ?Why were no sediment samples taken on Thunder Creek? Only one year of sediment sampling baseline
Comment: Incomplete baseline data collection. Additional baseline data collection is recommended.           
Link to Annex 1: SW(1)-20

IR 1 Reference #: AC(1)-424
Number: 5.0
Section Title: Existing Environment
Title: 5.8 Aquatic Resources
Page#: 75
Sub-title: 5.8.4.2. Fish Presence
Gap: Was the fish sampling done in the same sample locations each year?
Where all of these fish caught or what percentage of the results presented were from a historical literature review? Was 2 years of field work completed?
Comment: It is unclear if a continuous baseline dataset was established. Additional baseline data collection or further explanation is required.              
Link to Annex 1: FH(1)-06

IR 1 Reference #: AC(1)-5
Number: 5.0
Section Title: Existing Environment
Title: 5.8 Aquatic Resources
Page#: 86
Sub-title: 5.8.4.8 Species at Risk & Species of Management Concern
Gap: Seven (7) species of fish are Species of Management Concern?Northern Pike, Smallmouth Bass, Walleye, Muskellunge, Lake Whitefish, Lake Trout and White sucker.
Link to Annex 1: FH(1)-06

IR 1 Reference #: AC(1)-426
Number: 5.0
Section Title: Existing Environment
Title: 5.8 Aquatic Resources
Page#: 94
Sub-title: 5.9.3.2. Assessment Methods
Gap: 9 wetlands are potentially being disturbed will there be a wetland compensation plan developed?       
Comment: 3 provincially significant avian species were identified during the wetland survey
Link to Annex 1: PD(1)-01
WL(1)-03

IR 1 Reference #: AC(1)-427
Number: 5.0
Section Title: Existing Environment
Title: 5.8 Aquatic Resources
Page#: 95
Sub-title: 5.11.5.1 Vegetation
Gap: Requirement for TK/TU information for Country foods
Comment: Absence of baseline data collection and study for country foods. WFN based traditional knowledge study is required to understand WFN traditional knowledge and use activities as it relates to country foods.
Link to Annex 1: EA(1)-01
HE(1)-01
HE(1)-38

IR 1 Reference #: AC(1)-428
Number: 6.0
Section Title: Effects Assessment and Mitigation
Title: 6.4 Effects Assessment
Page#: 34/39
Sub-title: 6.4.1.12 Fish and Fish Habitat
Gap: Sediment and erosion & control plan? CEMP/OEMP, Operator training, environmental audits, on?going monitoring
Comment: Lack of sufficient detail to determine if proposed plan will mitigate effects of project.
Link to Annex 1: FH(1)-07

IR 1 Reference #: AC(1)-429
Number: 6.0
Section Title: Effects Assessment and Mitigation
Title: 6.4 Effects Assessment
Page#: 46
Sub-title: 6.4.2.4 Heritage Resources
Gap: Have First Nations had input into the Archaeological site information? Chance Find Procedure
Comment: Archaeological reports and studies do not relate information to WFN who have and continue to occupy the lands in the region. Concerns that the
archaeological reports do not represent interests of
WFN as they were not consulted on the study.
Link to Annex 1: HE(1)-47
HE(1)-48

IR 1 Reference #: AC(1)-430
Number: 6.0
Section Title: Effects Assessment and Mitigation
Title: 6.4 Effects Assessment
Page#: 48
Sub-title: 6.4.2.5 Aboriginal People
Gap: How will Treasury Metals ensure fish, wild meat and country foods are not impacted by mine related activities? Will there be specific management plans and strategies to protect traditional Aboriginal food sources?
Link to Annex 1: HE(1)-01
FH(1)-11

IR 1 Reference #: AC(1)-431
Number: 6.0
Section Title: Effects Assessment and Mitigation
Title: 6.4 Effects Assessment
Page#: 68
Sub-title: Table 6.4.2 Environmental Effects Assessment for Operational Phase
Gap: Why is the follow up and monitoring to only monitor the health of wild rice populations periodically during the first years of operations? It should be the life of mine through post closure (including all country foods)
Link to Annex 1: EA(1)-06
HE(1)-46

IR 1 Reference #: AC(1)-432
Number: 6.0
Section Title: Effects Assessment and Mitigation
Title: 6.4 Effects Assessment
Page#: 77
Sub-title: Table 6.4.3 Environmental Effects Assessment for Closure Phase
Gap: It has been identified that the project will most likely have "Potential change in abundance and health of wild rice downstream of Project" but there is no follow up or monitoring required?
Comment: Lack sufficient mitigation to address potential impacts. Further work is required to develop a sufficient mitigation plan.
Link to Annex 1: EA(1)-06
HE(1)-46

IR 1 Reference #: AC(1)-433
Number: 6.0
Section Title: Effects Assessment and Mitigation
Title: 6.4 Effects Assessment
Page#: 83
Sub-title: Table 6.4.6 Socio Economic Effects Matrix for the Construction phase
Gap: Archaeological sites?Chance Find Procedure all phases of mine
Link to Annex 1: HE(1)-49

IR 1 Reference #: AC(1)-434
Number: 7.0
Section Title: Cumulative Effects Assessment
Title: 7.2 Scope of Cumulative Effects Assessment
Page#: 5
Sub-title: 7.3.8 Wildlife and Wildlife Habitat
Gap: Why has there been no linkage between forestry cumulative impacts and mining cumulative effects. (i.e roads and fragmentation and alternation of the landscape, changes to water quality and degradation of fish habitat?)
Comment: Current cumulative effects assessment lacks is deficient. Additional work is required to address deficiencies including: list of projects including foreseeable project, current developments including forestry and consideration for effects to aboriginal rights, interests and treaty rights should also be included.
Link to Annex 1: CE(1)-02

IR 1 Reference #: AC(1)-435
Number: 9.0
Section Title: Commitment Registry
Title: Table 9.0.1 Treasury Commitments for the Project
Page#: 1
Gap: No overall commitment to environmental excellence
(ISO14001 certification, environmental policies, procedures,
training, auditing)

IR 1 Reference #: AC(1)-436
Number: 9.0
Section Title: Commitment Registry
Title: Table 9.0.1 Treasury Commitments for the Project
Page#: 1
Gap: No commitment to training Aboriginal people

IR 1 Reference #: AC(1)-437
Number: 9.0
Section Title: Commitment Registry
Title: Table 9.0.1 Treasury Commitments for the Project
Page#: 1
Gap: No commitment to a complete list of Project specific EMP's
Link to Annex 1: EA(1)-06

IR 1 Reference #: AC(1)-438
Number: 11.0
Section Title: Conceptual Closure
Title: 11.4 Post?Closure Site Conditions
Page#: 7
Sub-title: 11.5.2 Chemical Stability and Biological Monitoring
Gap: Concern with pit and TSF effluent discharge/runoff post closure which would migrate to Black Water Creek then into Thunder Lake in the Wabigoon Watershed. This could potentially cause adverse environmental impacts to the watershed. Why has the company only committed to a monitoring program for three years post closure?
Link to Annex 1: SW(1)-19

IR 1 Reference #: AC(1)-439
Number: 12.0
Section Title: Safety, Health and Environmental Management Plan
Title: 12.2 Objectives and Context
Page#: 1
Gap: No apparent framework included to guide the implementation of a Environmental Management Plan or EMS. Policies, guiding principles, company responsibility chart, communication plan, environmental audit, information systems, training and procedures not identified this is only an explanation of the environmental monitoring plan.
Link to Annex 1: EA(1)-06

IR 1 Reference #: AC(1)-440
Number: 13.0
Section Title: Environmental Monitoring Program
Title: 13.4 Surface Water and Aquatics
Page#: 4
Sub-title: 13.4.2 Monitoring Methods
Gap: Where are the actual monitoring methods and plans located?
Are the baseline studies on?going?
Link to Annex 1: SW(1)-20

IR-1 Annex A4

Annex A4 – Comments on the April 2015 Environmental Impact Statement for the Goliath Gold Project from the Public

Table 1 includes a summary of comments received from members of the public including: Emails and letters submitted to the Canadian Environmental Assessment Agency (the Agency); and Meetings held during the comment period on the environmental impact statement (EIS), including public information sessions in the Town of Wabigoon, and the City of Dryden. The Agency has summarized comments by potential environmental effect or environmental assessment (EA) process item.

Note that comments received in writing have been separated into topic of concern and edited to remove identifying information, but are otherwise included verbatim to ensure that the intent of the comment is accurately communicated to the proponent.

Fish and Fish Habitat

IR-1 Reference #: PC(1)-02
Community/Group: City of Dryden, Thunder Lake, and Village of Wabigoon residents
Summary of Comment: Identified fish and fish habitat are important to the community, including a large fish industry. Questions and comments about potential impacts to fish and fish habitat including: concerns with the fish studies, asked TMI to explain the methodology for the collection of fish data; identify if there will be compensatory fish habitat; impacts of effluent quality discharging into Blackwater Creek; identify the mitigation measures that will protect fish habitat; clarify whether fish habitat in Thunder and Wabigoon Lakes and provincial baseline data has been considered, and potential long term effects on aquatic life due to blasting and vibrations.
Link to Annex A1: FH(1)-06; FH(1)-10; SW(1)-19; AE(1)-22

IR-1 Reference #: PC(1)-03
Community/Group: Member of the public
Summary of Comment: More information is needed regarding impact on fisheries. The fisheries baseline studies in the EIS state no spawning fish were found in Kelpyn's Bay. While that may be the case, it is known to locals and MNRF that Christie Island is fish spawning habitat which is very close to Kelpyn's Bay. Explain why there is no spawning studies conducted around Christie Island and will fish studies be redone.
Link to Annex A1: FH(1)-06

IR-1 Reference #: PC(1)-04
Community/Group: Village of Wabigoon residents
Summary of Comment: Asked whether there are toxins are in the mud and rock.
Link to Annex A1: HE(1)-03

IR-1 Reference #: PC(1)-05
Community/Group: Village of Wabigoon; City of Dryden and Thunder Lake residents
Summary of Comment: Questions and comments about the design of the tailings storage facility and potential impacts to fish and fish habitat due to seepage, including: a description of soil composition and the depth of the tailings pond is needed; will the tailings stay in Blackwater Creek basin permanently; concerns about leakage from tailings storage facility of 20 000 gallons/ day into open pit, Thunder Lake and Blackwater Creek. Explain why there is an abundant amount of seepage from tailing storage facility and how seepage will be controlled; the decrease and contamination of fish; and what is the predicted water quality of seepage, and will it meet water quality guidelines.
Link to Annex A1: SW(1)-25

IR-1 Reference #: PC(1)-06
Community/Group: Thunder Lake residents
Summary of Comment: The topic of seepage from the tailings catchment pond at the site of the proposed Goliath Gold Mine Project is just one of the many concerns that the landowners on Thunder Lake are considering. It would appear from the information and proposed evidence provided by Goliath that they have everything in hand, and that the damage to the surrounding tailings catchment pond area will be minimized by their safeguards that will be in place at that time. It is of great concern that due to the information given by Goliath at the public meetings, that every eight weeks of operation approximately 2.5 million liters of seepage (equivalent to that of total fluid capacity in an Olympic sized swimming pool) will escape and leach into the ground and area around the tailings pond.
Link to Annex A1: GW(1)-03; GW(1)-07; GW(1)-17

IR-1 Reference #: PC(1)-07
Community/Group: Village of Wabigoon; City of Dryden and Thunder Lake residents
Summary of Comment: Comments and questions about the decommissioning and abandonment of the pit and tailings, including: who is liable 10-20 years down for the tailing pond; concerns about the water quality of the pit lake after closure, and whether it will be contaminated; Identified potential for accidents if people sneak into mine once it is closed, and asked what security provisions will be set in place to prevent accidents.
Link to Annex A1: FH(1)-13; SW(1)-17

IR-1 Reference #: PC(1)-08
Community/Group: City of Dryden and Thunder Lake residents; Member of the public
Summary of Comment: Comments and questions about waste rock management, including: potential for acid generation, including what is the sulphide content and iron pyrite in ore and waste rock; impacts of acid generating potential of waste rock pile on fish habitat; will waste rock will be separated based on acid generating potential; with regards to the waste pile what will be done to mitigate the potential large amounts of acidic rock that will end up in Thunder Lake; and will potentially acid generating rock be removed, or will it go into nearby water ways.
Link to Annex A1: MW(1)-08

IR-1 Reference #: PC(1)-09
Community/Group: City of Dryden and Thunder Lake residents
Summary of Comment: Clarify if cyanide can be quantified in pH not PPM and whether the treatment is similar to the treatment used at Red Lake. Describe the methods of cyanide destruction that have been proposed.
Link to Annex A1: SW(1)-23

IR-1 Reference #: PC(1)-10
Community/Group: City of Dryden and Thunder Lake residents
Summary of Comment:  Asked where the water samples are taken from and if groundwater samples are amongst the samples taken. Community members expressed interest in providing samples.
Link to Annex A1: GW(1)-02

IR-1 Reference #: PC(1)-11
Community/Group: Member of the public
Summary of Comment: The proponent lists the ability for upstream wetlands to retain water will be compromised but later says that this ecological service will be required to buffer impacts of high water and high rain events on the TSF. Please explain this discrepancy.
Link to Annex A1: EE(1)-01

IR-1 Reference #: PC(1)-12
Community/Group: City of Dryden and Thunder Lake residents
Summary of Comment: Comments and questions on the water supply for the Project, including: will the water be recycled or is new water being retrieved; how often the water will be discharged; why can't all the water be recycled; how many gallons of water will the mine use; where will water come from during the winter (everything frozen); and will water be taken from the tributary ponds to Thunder Lake.
Link to Annex A1: SW(1)-26

IR-1 Reference #: PC(1)-13
Community/Group: City of Dryden and Thunder Lake residents
Summary of Comment: Questions and comments about the reverse osmosis treatment process, including: will waste from reverse osmosis go back into the tailing storage facility that will be seeping; concerns about the impacts of discharging purified water into the aquatic environment; and is distillation a better treatment option versus reverse osmosis.
Link to Annex A1: SW(1)-18

IR-1 Reference #: PC(1)-14
Community/Group: City of Dryden and Thunder Lake residents
Summary of Comment: Identified that there is a dam on the reservoir from MNRF that goes to Hoffstrom's Bay.
Link to Annex A1:

IR-1 Reference #: PC(1)-15
Community/Group: Village of Wabigoon; City of Dryden and Thunder Lake residents
Summary of Comment: Asked what mitigation measures will be put in place to ensure that water levels in Thunder Lake are not affected due to drawdown. Question raised about whether Thunder Lake could drain into the open pit due to an unanticipated geological crack caused by blasting.
Link to Annex A1: FH(1)-05

IR-1 Reference #: PC(1)-16
Community/Group: Thunder Lake residents
Summary of Comment: What about the moratorium on no more new construction residences on Thunder Lake due to septic leaching. What is the difference between that and leaching from mining processes?
Link to Annex A1:

IR-1 Reference #: PC(1)-17
Community/Group: Member of the public
Summary of Comment: In section 6.4.1.1, there is this statement: "At closure the TSF will be covered and vegetated and the surrounding forest is expected to colonize the surface." I have heard that tree roots compromise the clay cover, so wouldn't allowing trees to grow on the surface cause the "water shedding cap" to fail? If this is true, how will trees be kept off the site over the long term?
Link to Annex A1: MW(1)-10

IR-1 Reference #: PC(1)-18
Community/Group: Member of the public
Summary of Comment: What happens if the closure plan fails? For example, if the "water shedding cap" breaks down over time, or the clay lining under the tailings storage area or waste rock area deteriorate, won't acid rock drainage get into the ground water and surface water? If this happens far into the future (20 years, 200 years, etc.) what will the impacts be to people's wells, and the nearby lakes, and who will be responsible for cleaning it up?
Link to Annex A1: MW(1)-10

IR-1 Reference #: PC(1)-19
Community/Group: Thunder Lake residents
Summary of Comment: How can this mine not negatively impact and affect Thunder Lake or the surrounding waterways; it is not possible. There are many "maybes about water being pulled from the lake". We would like a clear and definite answer on this.
Link to Annex A1: SW(1)-26

Migratory Birds

IR-1 Reference #: PC(1)-20
Community/Group: City of Dryden, Thunder Lake, and Village of Wabigoon residents
Summary of Comment: Asked whether the tailings pond will be lit and concerns about 24/7 light pollution from the project site.
Link to Annex A1: AE(1)-16

IR-1 Reference #: PC(1)-21
Community/Group: Thunder Lake residents
Summary of Comment: Bird bangers are known to be used to keep birds away from tailings ponds. These are extremely noisy and need to be constantly used to be effective. What is going to be used at this project?
Link to Annex A1: WL(1)-05

Socio-economic Conditions and Human Health  

IR-1 Reference #: PC(1)-22
Community/Group: City of Dryden and Thunder Lake residents
Summary of Comment: Concerns about potential impacts to drinking water from seepage from the tailings storage facility.
Link to Annex A1: GW(1)-15

IR-1 Reference #: PC(1)-23
Community/Group: City of Dryden resident
Summary of Comment: Section 9.2 Appendix DD, Page 20, Section 5.1.4.6 - The response to the comment submitted has not been fully realized. Concerns over the drinking water and mortgaged home concerns are not included in the response provided in Appendix DD page 20, Section 5.1.4.6.
Link to Annex A1: AC(1)-01

IR-1 Reference #: PC(1)-24
Community/Group: City of Dryden, Thunder Lake, and Village of Wabigoon residents
Summary of Comment: Asked how potential impacts to human health were identified, including whether the following indicators were considered: exposure to carcinogens and toxins; percent highly annoyed; and quality of life.
Link to Annex A1: HE(1)-02; HE(1)-08; HE(1)-25; HE(1)-35; AE(1)-27; AE(1)-28; AE(1)-29

IR-1 Reference #: PC(1)-25
Community/Group: Village of Wabigoon residents
Summary of Comment: There is also concern that the air quality around this site will exceed the provincial limits; yet it is unclear how much it will exceed. We are almost positive that this concern is going to directly impact our lifestyle and our health. Not to mention our animals; that have no voice. Will Treasury Metals cover the cost of our veterinary bills, as well as our health expenses when this should affect us?
Link to Annex A1: AE(1)-07

IR-1 Reference #: PC(1)-26
Community/Group: Member of the public, City of Dryden, Thunder Lake, and Village of Wabigoon residents
Summary of Comment: Questions and concerns about visual impacts of the mine on local landscape. Certain concerns include the height of the rock piles and whether or not they will be seen as part of the northwest view of Thunder Lake. Another concern would be the revegetation of caps and the impacts roots will have on their ability to retain the tailings. The caps can't be fully re vegetated (i.e. with trees) because the roots will compromise their ability to retain the tailings. How will this impact aesthetics to Thunder Lake residents?
Link to Annex A1: HE(1)-36; MW(1)-10

IR-1 Reference #: PC(1)-27
Community/Group: Thunder Lake residents
Summary of Comment: There is an argument that Red Lake, Kirkland Lake and Sudbury have residences around sites. They built the towns around these sites. People moved there knowing about the existing mine operations. We purchased our property on East Thunder Lake Road away from the mill sounds and smells from Dryden. Not to have a mine open up in our back yard.
Link to Annex A1: HE(1)-35

IR-1 Reference #: PC(1)-28
Community/Group: City of Dryden and Thunder Lake residents
Summary of Comment: The mine is close to residential areas as well as recreational and aquatic areas. Comments and questions about potential air quality impacts, including: potential odors from the tailings; Blastomycosis fungus is well known to be in the area. There have been many documented cases found within dogs on our road. This fungus is prevalent in the soil and will be stirred up/exposed with the mine project; concerns of air pollution from road and air traffic, including helicopters that have increased at early morning hours; compressed air release from plants and equipment. There was no mention of any dangerous gas releases during emergency situations; how air quality will be tested with regards to prevailing winds; concerns about impacts from dust and blasting; and clarification of the methodology for the dust assessment modelling, including area modelled, and how potential changes in wind direction were taken into consideration.
Link to Annex A1: AE(1)-06; AE(1)-07; AE(1)-08; AE(1)-10; AE(1)-12; AE(1)-13

IR-1 Reference #: PC(1)-29
Community/Group: Thunder Lake residents
Summary of Comment: Additional comments and questions on potential impacts from dust include: the amount of dust that is expected; how toxic the dust will be; concerns about dust pollution, acid rain as a result of dust, and possible carcinogens. Carcinogenic dust will be air borne and settle all over everything. Other remote mine sites are required to have dust monitoring stations that record the dust produced from a plant. There was no mention of this in the report. Illnesses will develop– it's inevitable; who and how will this be monitored; how often will it be monitored; and will the monitoring results be made available for the public.
Link to Annex A1: AE(1)-01; AE(1)-02; AE(1)-06; AE(1)-13

IR-1 Reference #: PC(1)-30
Community/Group: Thunder Lake residents
Summary of Comment: Page 9 of the Acoustic Environment Study describes forty-two noise-sensitive receptors that are houses. Was the cottage, located at Parcel 24750 SEC DKF Part of Broken Lot 9, Concession 4, Part 4 Plan KR764 considered in the Acoustic Environment Study as one of the forty-two houses? This is important because Treasury Metals considers any area with surface mining rights secured as a non-sensitive noise receptor and Treasury Metals has yet to acknowledge the cottage inside the mine boundary.
Link to Annex A1: AE(1)-10

IR-1 Reference #: PC(1)-31
Community/Group: Village of Wabigoon, City of Dryden and Thunder Lake residents;
Summary of Comment: Community expressed concerns with noise and vibration levels associated with blasting and machinery, including the following comments and questions: identified Thunder Lake is a serene environment that may be affected by noise travelling across the lake from the mine; current noise levels very low; what are the noise level associated with and the timing of blasting; would Treasury Metals consider setting up an email notification system to alert those interested of blasting activities on a weekly or monthly schedule; what are the noise regulations, including the decibel range for day vs. night; how was annoyance from noise considered; how were noise impacts determined, including whether the model included road and rail noise; how many pieces of equipment will be operating at once; vibrations from several packers. Because of the rock it will radiate; there was no mention of the 24/7 bird deterrent cannon noise; how will potential impacts from back-up beeping of trucks that are exempt from the noise regulations (at least 120 dB) be mitigated; identified potential impacts to real estate values from noise and blasting; with a 24/7 365 operation, what noise will be heard at all hours of the day; what recourse will there be if the noise is found to be unacceptable; identified potential impacts to house foundations and groundwater wells from blasting, and asked who will  pay for any damages; and will there be blasting in a ramped shaft underground that can be felt on the surface; and how will noise levels be monitored.
Link to Annex A1: AE(1)-22; AE(1)-23; AE(1)-28; AE(1)-31

IR-1 Reference #: PC(1)-32
Community/Group: City of Dryden, Thunder Lake, and Village of Wabigoon residents
Summary of Comment: Community members expressed concern over the potential impacts to water quantity in private wells from the project, including the following questions and comments: concerns over potential for wells to be dewatered due to drawdown from the open pit, lack of notification of possibly affected residents, and likelihood that dewatering will happen; will the results from water quantity monitoring be made available to public; identified that potentially affected wells in East Thunder Lake are not included in the assessment provided in the EIS; will there be insurance or compensations for private wells; what are the mitigation measures to ensure that wells do not run dry; offering to drill a new well would not suffice as the time frame that we would be out of water would be life altering; is there a possibility the well water will return, and if yes in what time frame; and would the open pit fill with water before affected wells. It was mentioned at the meeting that ground water moves slowly and could take 20 years for it to come back. Will Treasury Metals provide water if this becomes a reality?
Link to Annex A1: GW(1)-15

IR-1 Reference #: PC(1)-33
Community/Group: City of Dryden, Thunder Lake, and Village of Wabigoon residents
Summary of Comment: Community members expressed concern over the potential impacts to water quality in private wells from the project, including the following questions and comments: provide details of the groundwater monitoring program, specifically, what parameters will be sampled and tested, the reporting frequency and how to access the reports. This is especially important given the 70 m3/d to 90 m3/d seepage that is expected to migrate away from the tailings storage facility; where were water samples taken from; how often the samples will be taken from private wells; who will pay for sampling private wells; concerns about water table and quality of  well water; should home owners should sample their own wells to create a baseline; if private well water quality is affected by the mine what will be done; and will the results from water quality monitoring be made available to public
Link to Annex A1: GW(1)-15; GW(1)-17

IR-1 Reference #: PC(1)-34
Community/Group: Thunder Lake residents
Summary of Comment: Is the water quality and quantity of Thunder Lake going to be affected in such that our health and lifestyle may change or are in jeopardy?
Link to Annex A1: GW(1)-03; GW(1)-15; FH(1)-05

IR-1 Reference #: PC(1)-35
Community/Group: City of Dryden and Thunder Lake residents
Summary of Comment: Research on cyanide destruction process show an increase in bio-availability of mercury. Aware that Grassy Narrows First Nation is concerned about mercury exposure because of previous exposure.
Link to Annex A1: SW(1)-23

IR-1 Reference #: PC(1)-36
Community/Group: City of Dryden and Thunder Lake residents
Summary of Comment: Community member was trapping minnows in the irrigation pond on the site and was kicked off the property.
Link to Annex A1: HE(1)-38

IR-1 Reference #: PC(1)-37
Community/Group: City of Dryden, Thunder Lake, and Village of Wabigoon residents
Summary of Comment: Section 9.1.3 EIS Section Table 6.4.7, page 6-86 - Impacts to local real estate pricing are not considered in socio-economic discussion–this is a major concern for many residents.                
Link to Annex A1: HE(1)-35

IR-1 Reference #: PC(1)-38
Community/Group: Member of the public
Summary of Comment: The proponent at the information sessions (which should be on the public record) responded to a concerned citizen regarding her property value of a lakefront home in eye sight of the waste rock piles. The proponent endorsed that their local research was that property values would increase. Where is this research available? How robust is the information? Why did the proponent respond with an answer of increasing values which is a contradiction to their documents regarding Local residents and recreational users - Effect on property values: "Advantages: None Apparent. Disadvantages: Elevated Noise and visual disturbances over initial open pit mine life. Disadvantages: Some visual and audible disturbances during mining operations could potentially lower property values. "(Goliath Gold Project Environmental Impact Statement, Appendix X). The statements made at the information session are interpreted to be conveniently misleading especially at an open session regarding what is contained in the EIS.
Link to Annex A1: HE(1)-35; HE(1)-36

IR-1 Reference #: PC(1)-39
Community/Group: City of Dryden, Thunder Lake, and Village of Wabigoon residents
Summary of Comment: Comments and questions about potential impacts to property values during mine operation and abandonment, including: potential decrease in property values due to the proximity of the mine; identify if there is an assurance or legal recourse if property values become valueless; will there be financial compensation for the depreciation of homes/farms; clarify if there will be insurance in case of property damage; and A local homeowner was required by his mortgage company to purchase insurance on his property for damage caused by the mine. This is very concerning to us who do not hold this type of insurance.
Link to Annex A1: HE(1)-35

IR-1 Reference #: PC(1)-40
Community/Group: City of Dryden, Thunder Lake, and Village of Wabigoon residents
Summary of Comment: Comments and questions about who will be paying for new roads and the wear and tear on existing roads that vehicles from the mine will use. State the number of vehicles that would be travelling down the road and the possibility of re-routing access roads.
Link to Annex A1: HE(1)-34

IR-1 Reference #: PC(1)-41
Community/Group: Village of Wabigoon residents
Summary of Comment: Concerns about the quiet country road will become mayhem (especially at shift change.) The road is also quite narrow, barely allowing two vehicles to pass each other, explain how a smaller vehicle and an oversized transport truck going to accommodate each other. Want to know how many vehicles would be travelling down the road, and how much cyanide would be hauled past homes. Is it was possible to reroute the access road by making a road behind existing homes extending Norman Road to Hwy 17?
Link to Annex A1: HE(1)-34

IR-1 Reference #: PC(1)-42
Community/Group: City of Dryden and Thunder Lake residents
Summary of Comment: Identify if the city will get revenue from the project.
Link to Annex A1:

IR-1 Reference #: PC(1)-43
Community/Group: City of Dryden, Thunder Lake, and Village of Wabigoon residents
Summary of Comment: Believe the mine will be a definite economic boom to the area and will provide much needed jobs and spin off. Comments and questions about the economic benefits to the area. Provide the number of local workers hired and the number of out of workers hired in the future.
Link to Annex A1: HE(1)-35

IR-1 Reference #: PC(1)-44
Community/Group: City of Dryden, Thunder Lake, and Village of Wabigoon residents
Summary of Comment: Concerns about potential impacts to local and regional tourism, particularly operations on Wabigoon Lake. Identified that changes in perception should be taken into consideration.
Link to Annex A1: HE(1)-35

IR-1 Reference #: PC(1)-45
Community/Group: City of Dryden, Thunder Lake, and Village of Wabigoon residents
Summary of Comment: Concerns regarding potential impacts to water quality and country foods. Community member from Wabigoon Lake Ojibway Nation concerned with impacts to water quality. Has fished in Wabigoon Lake and surrounding area. Basic needs for water should not be taken away.
Link to Annex A1: HE(1)-38; HE(1)-43

IR-1 Reference #: PC(1)-46
Community/Group: City of Dryden resident
Summary of Comment: Section 10.2 Appendix EE, Page 23, Section 5.2.2.2 - "Chanterelle mushroom picking activity has been documented within the LSA (Figure 5.1 and Figure 5.2). These areas will not be directly affected though Project development, although they will not be available to the public due to safety concerns. Upon closure of the Project this site will be available to the public and First Nation communities." Chanterelle mushrooms will be cut off for the project duration, how close are the sites to the project site? Are they close enough that perception of their safety to eat will be questioned? More discussion about this with the community is required.
Link to Annex A1: HE(1)-43

IR-1 Reference #: PC(1)-47
Community/Group: City of Dryden resident
Summary of Comment: Section 10.2 Appendix EE, Page 23, Section 5.2.2.3 - "Two locations of wild rice are documented with the regional area. Data on these locations was provided by the OMNRF (Figure 5.1 and Figure 5.2). These locations of wild rice fall within the discharge area of the Goliath Project. As detailed within Section 5.3 the Goliath Gold Project has been designed to discharge all effluent at PWQO guidelines. These guidelines are designed to protect aquatic life at all exposure levels. Therefore it will not adversely impact the gathering of wild rice within the local and regional area." Same comment as above only with wild rice. Will perception of harvesting wild rice near a mining effluent discharge point source alter perception of whether it's safe to eat?
Link to Annex A1: HE(1)-43

IR-1 Reference #: PC(1)-48
Community/Group: City of Dryden resident
Summary of Comment: Section 10.2 Appendix EE - Are blueberries, chanterelles, wild rice, game and furbearers the only country food with concerns expressed? Should any traditional medicines be considered in Appendix EE?
Link to Annex A1: HE(1)-38

IR-1 Reference #: PC(1)-49
Community/Group: City of Dryden and Thunder Lake residents
Summary of Comment: Information on land clearing and utilization of trees and soil is needed. The Dryden Forest Management Co. would like to work with Treasury Metals to ensure trees are properly utilized.
Link to Annex A1:

IR-1 Reference #: PC(1)-50
Community/Group: Village of Wabigoon residents
Summary of Comment: Proposed mine site is in service area (including fire services) of Wabigoon. Describe how TMI will provide fire suppression.
Link to Annex A1: EE(1)-02

IR-1 Reference #: PC(1)-51
Community/Group: City of Dryden and Thunder Lake residents
Summary of Comment: The impact on Aaron Provincial Park needs to be investigated further.
Link to Annex A1: HE(1)-35; HE(1)-45

IR-1 Reference #: PC(1)-52
Community/Group: Thunder Lake residents
Summary of Comment: There is already the issue of excessive throwing of garbage out of vehicles onto our property alongside the road, being negligent of human and animal safety by driving at high speeds and completely disregarding homes.
Link to Annex A1:

IR-1 Reference #: PC(1)-53
Community/Group: Member of the public
Summary of Comment: For Section 6.2.1.6 on climate, I think it would make more sense to compare the amount of carbon that would be emitted by the mine to a scenario where there is no mine, because I think this is a more accurate way of determining the effect on climate. Section 6.4.1.6 suggests that the duration will go away at closure (level 2), while GHG's emitted stay in the atmosphere and continue to cause climate impacts for much longer than that. It also says that the effects on climate will be readily reversible (level 1), which again, is not true because the GHG's stay in the atmosphere for a very long time.
Link to Annex A1: EE(1)-06; AE(1)-15

Structure, site, or thing of historical, archaeological, paleontological or architectural significance to Aboriginal groups

IR-1 Reference #: PC(1)-54
Community/Group: Member of the public
Summary of Comment: Is concerned about the potential for archeological findings and indicated that they have found evidence of indigenous habitation on their property and would assume it would be in the surrounding area as well.
Link to Annex A1: HE(1)-47

IR-1 Reference #: PC(1)-55
Community/Group: City of Dryden residents
Summary of Comment: Section 9.2 Appendix DD, Page 34, Section 5.5.1 - "As Naotkamegwanning is situated on Lake of the Woods, there is no direct link by water to the vicinity of the Goliath Site. Any traditional travel between Naotkamegwanning and the area near the Goliath site would have involved a complex series of lakes and portages to connect with Eagle Lake. Similar routes as used by aboriginal living in the Eagle Lake area would then have been used to reach the Wabigoon Lake area and the vicinity of the Goliath site." Travel did occur historically by means of complex series of portages. Communities traditionally met at Rice Lake which is just north of the Goliath site, historical travel routes could very likely have been via Thunder Creek, Thunder Lake and Blackwater Creek all of which fall within the area of impact.
Link to Annex A1: HE(1)-47

IR-1 Reference #: PC(1)-56
Community/Group: City of Dryden residents
Summary of Comment: Section 9.2 Appendix DD, Page 29, Section 5.4.1 - "Travelling by road (Highway 17 - Highway 105) Wabauskang First Nation is located approximately 135 km from the Goliath Gold site. Traditional travel between Wabauskang and the Goliath site would have been much more difficult. Wabauskang is not located on the Wabigoon River system. In order to travel between Wabauskang and Wabigoon Lake, it would have been necessary to canoe upstream through Perrault, Cedar and Cliff Lakes, and then follow the route through a series of smaller lakes and portages (Mystery, Evening, and Twilight) and then portage overland to reach the Wabigoon system at Clay Lake. From Clay Lake to Wabigoon Lake would still involve a long paddle upstream and portages around a number of rapids and waterfalls." Traditional travel routes shouldn't be considered from the mine site to present day community sites, the travel distances from the modern-day community to the project site are not altogether relevant in historical context. Community members from Wabauskang, Naotkamegwanning, etc. likely travelled far beyond the modern-day community sites. This comment could be applied to many other community sections in the document.
Link to Annex A1: HE(1)-47

IR-1 Reference #:
Community/Group:
Summary of Comment: Traditional travel routes shouldn't be considered from the mine site to present day community sites, the travel distances from the modern-day community to the project site are not altogether relevant in historical context. Community members from Wabauskang, Naotkamegwanning, etc. likely travelled far beyond the modern-day community sites. This comment could be applied to many other community sections in the document.
Link to Annex A1:

IR-1 Reference #: PC(1)-57
Community/Group: City of Dryden resident
Summary of Comment: Section 9.2 Appendix DD, Page 19, Section 5.1.4.8.1.3 - "Although not specified by WLON, it may be assumed that in times past, a route may have existed between Wabigoon Lake, Thunder Lake, Mavis Lake, Ghost Lake, and the wild rice gathering areas on Rice Lake. As there is no water connection between Mavis and Thunder Lakes, travel would have required lengthy overland portages between Thunder and Mavis Lake and Ghost and Rice Lake, with a shorter portage between Mavis and Ghost." Nothing is included to address whether there are potential impacts to historical travel routes to Mavis Lake and if so how those will be addressed.
Link to Annex A1: HE(1)-47

IR-1 Reference #: PC(1)-58
Community/Group: City of Dryden resident
Summary of Comment: Section 12.2 EIS Table 6.4.6, page 6-83 - Suggest working with communities as they maintain that there are sites of historical and archaeological significance within project site boundaries.
Link to Annex A1: HE(1)-47

IR-1 Reference #: PC(1)-59
Community/Group: Member of the public
Summary of Comment: For the cultural heritage assessment that is done to assess aboriginal values, is this shared with the aboriginal communities?
Link to Annex A1: HE(1)-47

Current Use of Lands and Resources for Traditional Purposes

IR-1 Reference #: PC(1)-60
Community/Group: Member of the public
Summary of Comment: Is concerned about the effects on medicinal plants growing in the area and the historical area called "Blueberry Camp" where people harvest blueberries for food and income.
Link to Annex A1: HE(1)-35; HE(1)-38

IR-1 Reference #: PC(1)-61
Community/Group: City of Dryden resident
Summary of Comment: Section 10.2 Appendix DD, page 11, Section 5.1.2.1 - "No specific areas associated with the Goliath Mine Project have been identified as areas from which blueberries have been gathered… Other plant species may require different conditions to thrive than do blueberries, but virtually all plant species have particular conditions (eco-site and stage of forest development) under which their abundance is optimal and other conditions where they may be absent from the site." Country food discussion in Appendix DD section 5.1.2.1 is too narrow – only blueberries are considered.
Link to Annex A1: HE(1)-38

IR-1 Reference #: PC(1)-62
Community/Group: City of Dryden resident
Summary of Comment: Section 12.2 EIS Table 6.4.2, page 6-68 - Wild rice is only considered in the tables, blueberries and chanterelles are discussed in the associated text.
Link to Annex A1: HE(1)-38; HE(1)-43

IR-1 Reference #: PC(1)-63
Community/Group: Thunder Lake residents
Summary of Comment: What about the pack of wolves living in the area in question? It wasn't mentioned in the environmental report. It does mention wildlife mortality.
Link to Annex A1: HE(1)-45

Accidents and Malfunctions

IR-1 Reference #: PC(1)-64
Community/Group: City of Dryden, Thunder Lake, and Village of Wabigoon residents
Summary of Comment: Concerns about potential for tailings dam breach (like Mount Polley), including: guarantee that accidental dam break won't occur; whether TMI has insurance to cover all the costs associated with clean up; where will the tailings go in the event of a tailings breach (i.e., Thunder lake or Blackwater Creek/Wabigoon Lake); and insurance fund for compensating residents.
Link to Annex A1: AM(1)-04; AM(1)-05

IR-1 Reference #: PC(1)-65
Community/Group: Thunder Lake residents
Summary of Comment: Provide details on the potential effects of a tailings storage facility failure on Thunder Lake. Failure modeling is limited to Wabigoon Lake, while long term seepage estimates of the tailings storage facility mainly focus on Thunder Lake and its tributaries.
Link to Annex A1:

Cumulative Effects

IR-1 Reference #: PC(1)-66
Community/Group: Member of the public
Summary of Comment: The Cumulative Effects section of the EIS does not discuss the Domtar pulp mill. It only looks at future proposed projects. Comments and concerns about the air and water quality impacts from the mill to which the mine will be adding. The mine will add to the environmental burden due to the pulp mill and there is virtually nothing in the EIS about this.
Link to Annex A1: CE(1)-02

Evaluation of Alternatives

IR-1 Reference #: PC(1)-67
Community/Group: Member of the public
Summary of Comment: The EIS discussed possible tailings options, including solid and slurry tailings options. Provide an explanation on whether solid tailings are safer than slurry. Perception is that cost is the deciding factor rather than the safety of people.
Link to Annex A1:

IR-1 Reference #: PC(1)-68
Community/Group: City of Dryden and Thunder Lake residents
Summary of Comment: Explain whether plastic or clay liner is the best option for tailings management.
Link to Annex A1: AA(1)-01

IR-1 Reference #: PC(1)-69
Community/Group: Member of the public
Summary of Comment: The proponent makes numerous references to using best practices. At the information sessions the proponent clarified that their concept of best practices and best available technologies were those that are meeting minimum standards and that they have to be based on cost. Engineering staff explained why they are proposing to use century old technology known to fail because they are cost effective and they were unclear of benefits of using best available technology. The proponent is proposing a project that is not of acceptable expectation of the people in the community. Why is the proponent not being a leader and heading the call of world renowned geotechnical engineering experts Dr. Norbert R. Morgenstern, CM, AOE, FRSC, FCAE, Ph.D., P.Eng., Mr. Steven G . Vick, M.Sc., P.E, Dr. Dirk Van Zyl, Ph.D ., P.E., P.Eng? These experts released their Independent Expert Engineering Investigation and Review Panel Report (IEEIRPR) on Mount Polley Tailings Storage Facility Breach on January 30, 2015. The proponents are not providing the citizens and the environment the best technologies or practices. The proponent published "Stakeholders have identified concerns regarding the plans to store mine rock (waste rock), and tailings specifically related to acid rock drainage, water quality, location, and size. As part of the alternatives assessment required for the Project, Treasury considered multiple locations for mine rock areas and tailings management facilities. Based on technical suitability, cost, and environmental effects, locations were narrowed down and selected (section 8.4). This method is unacceptable, nor is it explained well, and in opposition of far more experienced geotechnical engineers' opinions: "There are no overriding technical impediments to more widespread adoption of filtered tailings technology."(IEEIRPR, section 9.3.2), "While economic factors cannot be neglected, neither can they continue to pre-empt best technology." (IEEIRPR, section 9.3.2). The proponent's entire tailings storage facility is a tried-and-true design of inevitable failure, "In risk-based dam safety practice for conventional water dams, some particular level of tolerable risk is often specified that, in turn, implies some tolerable failure rate. The Panel does not accept the concept of a tolerable failure rate for tailings dams. To do so, no matter how small, would institutionalize failure. … best practices can only go so far in improving the safety of tailings technology that has not fundamentally changed in the past hundred years. … Improving technology to ensure against failures requires eliminating water both on and in the tailings: water on the surface and water contained in the interparticle voids. Only this can provide the kind of failsafe redundancy that prevents releases no matter what. … Simply put, dam failures are reduced by reducing the number of dams that can fail." (IEEIRPR, section 9.2).
Link to Annex A1:

Effects of Environment on Project

IR-1 Reference #: PC(1)-70
Community/Group: Village of Wabigoon, City of Dryden, and Thunder Lake residents
Summary of Comment: In the event of a flood, clarify if the tailings will get washed out.
Link to Annex A1: EE(1)-01

IR-1 Reference #: PC(1)-71
Community/Group: City of Dryden and Thunder Lake residents
Summary of Comment: Asked whether the tailings storage facility has been designed with the capacity to adapt to climate change. Describe what will be done to handle storms.
Link to Annex A1: EE(1)-06

Project Description

IR-1 Reference #: PC(1)-72
Community/Group: Member of the public
Summary of Comment: If the waste rock pile is potentially acid generating like the proponent claims it likely will be to some degree, why can it not be planned to be further from the lake? The current design shows the waste rock pile being very close to the lake. It could be moved much farther away for safety.
Link to Annex A1: AA(1)-12

IR-1 Reference #: PC(1)-73
Community/Group: City of Dryden and Thunder Lake residents
Summary of Comment: The Project has been identified to be close to residential areas. Clarify how far the mine is from the town of Wabigoon. Additional comments and concerns have been expressed about irrigation ponds being used as mixing facility is a concern.
Link to Annex A1:

IR-1 Reference #: PC(1)-74
Community/Group: Village of Wabigoon, City of Dryden and Thunder Lake residents
Summary of Comment: Comments and questions about the open pit include the following: what is the exposure area; how big is the open pit; the depth and width of the pit; how long will it take to fill the pit; what is the potential that rock will be simultaneously exposed to water and air and will acidify the man-made lake over that time period?; explain whether there will be an open pit and underground shaft at the same time; and comment and questions about possible mine expansion.
Link to Annex A1: MW(1)-13

IR-1 Reference #: PC(1)-75
Community/Group: City of Dryden, Thunder Lake, and Village of Wabigoon residents
Summary of Comment: The meeting in Wabigoon noted that the mine has no claims under Thunder Lake, and then, at the Dryden meeting it was mentioned that the mine does indeed have claims under Thunder Lake. This needs to be clarified. The information being presented is misleading. Justify what right does that give TMI to water and identify who owns mining claims next to the site.
Link to Annex A1:

IR-1 Reference #: PC(1)-76
Community/Group: City of Dryden, Thunder Lake, and Village of Wabigoon residents
Summary of Comment: Identify the capacity of the crusher. Identify the capacity of the mill and whether it is based on starting up slow with shaft on.
Link to Annex A1:

IR-1 Reference #: PC(1)-77
Community/Group: Village of Wabigoon, City of Dryden, and Thunder Lake residents
Summary of Comment: Comments and questions about the project timelines and design include the following: could the project last longer than 15-17 years; impacts if the mine goes beyond the proposed size; potential for mill use after the stated life of the mine and how will that impact the environment; and what will be the projected start of construction and proven reserves.
Link to Annex A1:

IR-1 Reference #: PC(1)-78
Community/Group: City of Dryden and Thunder Lake residents and other members of the public
Summary of Comment: Very thoroughly thought out. Extremely cautious regarding the environmental impact.
Link to Annex A1:

Aboriginal Consultation

IR-1 Reference #: PC(1)-79
Community/Group: City of Dryden resident
Summary of Comment: Section 12.2 EIS Table 6.4.1-6 - Unclear on how the effects for this VC were determined. Are these concerns specifically brought forward by Aboriginal communities?
Link to Annex A1: AC(1)-01

IR-1 Reference #: PC(1)-80
Community/Group: Member of the public
Summary of Comment: In section 10.1.2 of Appendix EE, I felt that this should include a map of Treaty #3 for reference.
Link to Annex A1: HE(1)-38

IR-1 Reference #: PC(1)-81
Community/Group: Member of the public
Summary of Comment: In Appendix DD, Section 2.1, page 5, there is a lengthy description of the land claim between Wabigoon Lake Ojibway Nation and MNRF. Why was this information included? It doesn't seem relevant to the consultation discussion.
Link to Annex A1: HE(1)-38

Public Consultation

IR-1 Reference #: PC(1)-82
Community/Group: City of Dryden, Thunder Lake, and Village of Wabigoon residents
Summary of Comment: Concerns that potentially affected homeowners, in particular those whose wells may be impacted and those that live on East Thunder Lake Road, have not been notified of potential impacts or consulted by TMI. Questions and comments about the lack of consultation with community, including lack of responsiveness to questions submitted to the proponent.
Link to Annex A1: PC(1)-01

IR-1 Reference #: PC(1)-83
Community/Group: City of Dryden resident
Summary of Comment: Section 12.2 EIS Table 6.4.6, page 6-83 - Baseline studies are mentioned but there is no mention of consultation. Is it worth noting that consultation for this project is ongoing and not complete?
Link to Annex A1: PC(1)-01

IR-1 Reference #: PC(1)-84
Community/Group: City of Dryden and Thunder Lake residents
Summary of Comment: Concerns that nearby residents were not notified prior to commencement of drilling program.
Link to Annex A1:

IR-1 Reference #: PC(1)-85
Community/Group: City of Dryden and Thunder Lake residents
Summary of Comment: Identified that more information is received during question and answer sessions, and identified that this format should be available for future meetings. Questions and comments about if TMI will be holding additional meetings.
Link to Annex A1: PC(1)-01

IR-1 Reference #: PC(1)-86
Community/Group: Village of Wabigoon, City of Dryden, Thunder Lake residents and other members of the public
Summary of Comment: The public would appreciate more time for the comment period, as this is a whole lot of information that one could not possibly make sense of by May 24, 2015.
Link to Annex A1:

IR-1 Reference #: PC(1)-87
Community/Group: Village of Wabigoon resident
Summary of Comment: Comments and questions about the baseline studies not reflecting the impacts on the environment. The town site should be included as a stakeholder.
Link to Annex A1: PC(1)-01

Other Comments

IR-1 Reference #: PC(1)-88
Community/Group: City of Dryden and Thunder Lake residents
Summary of Comment: A petition has been launched for a provincial EA because the community feels the federal process does not require TMI to consult with property owners. Asked why TMI has not volunteered for provincial EA and if a provincial EA is still possible.
Link to Annex A1:

IR-1 Reference #: PC(1)-89
Community/Group: Village of Wabigoon residents
Summary of Comment: Concerns about the economic viability of the project (only $140 million).
Link to Annex A1:

IR-1 Reference #: PC(1)-90
Community/Group: Village of Wabigoon residents
Summary of Comment: Describe the stock options available for community development (i.e. stock options for village of Wabigoon).
Link to Annex A1:

IR-1 Reference #: PC(1)-91
Community/Group: City of Dryden resident
Summary of Comment: Section 9.1.3 EIS Table 6.4.6, page 6-83 - How will Treasury Metals support their surrounding communities? Is community support a part of the company's vision statement?
Link to Annex A1:

IR-1 Annex B

Annex B - Goliath Gold Project IR-1 Companion Sheet

In addition to the EIS Guidelines for the Goliath Gold Project issued on February 21, 2013, the procedural direction provided in this Companion Sheet is intended to guide the proponent in preparing a satisfactory set of responses to the First Information Request Package. By following these procedural steps, both the Canadian Environmental Assessment Agency (the Agency) and Treasury Metals Inc. (the proponent) ensure that the next phase of the federal environmental assessment process is effective and efficient. These procedural steps are being proposed in part due to the size, scale and scope of the First Information Request Package.

Annex B1 - Deliverables for Inclusion in the Response to the First Information Request (IR-1) Package

1. Draft responses to all Annex A1 information requests for review and feedback from the Canadian Environmental Assessment Agency (the Agency) prior to formal submission of the responses (see Important Note 1).
2. Final responses to all Annex A1 information requests presented in a revised EIS document package, which must include all sections of the EIS and appendices with updated information and results   (see Important Note 2 and Annex B2 for further instructions);
3. Aboriginal engagement report, a standalone document that is submitted as an appendix to the EIS and includes the responses to the comments tabled in Annex A3 (see Annex B3 for specific instructions on Aboriginal engagement);
4. Table of concordance to act as a checklist of where to find the clarifications and revisions in the revised EIS that are linked to each information request ; and
5. Detailed roadmap to describe the approach taken to duly respond to each information request in a manner that takes into account the summary of comment/rationale behind the request; the roadmap must also explain what information was retained from the April 2015 EIS, what new information is provided, and how the response is integrated into the EIS in a manner that is intuitive, logical, and simple to follow.

IMPORTANT NOTES:

1. The proponent shall submit a draft IR-1 response package– draft responses to the information requests, table of concordance, and roadmap–to the Agency for review and feedback on the revised EIS documentation prior to the official submission of the IR-1 response package.
2. Upon formal submission of the response package, the Agency will complete a conformity review to ensure that the response package is complete. Time taken by the proponent to complete its work is not calculated in the legal timeframe within which the Minister of the Environment must issue a decision statement on the Project.  Although the timeline is stopped while a proponent is completing its work, work by Agency officials on the environmental assessment of the Project continues.

Annex B2 - Instructions for Addressing Information Requests Tabled in Annex A1 of IR-1

Section 3.2 of the EIS Guidelines states: "All significant gaps in knowledge and understanding related to key conclusions presented in the EIS must be identified. The steps to be taken by the proponent to address these gaps will also be identified." The information requests stemming from the EIS review identify gaps that require clarification of the baseline, effects assessment, mitigation, follow-up, and Aboriginal interests. As a result, the Agency outlines the following approach for Treasury Metals Inc. (the proponent) to address the information requests.

(I) Participate, in collaboration with the proponent's consultants, in a series of meetings led by the Agency with other government reviewers on the various thematic areas of IR-1. This will assist the proponent in clarifying the expectations of the government reviewers for the proponent's responses to IR-1. The thematic areas include, but are not limited to:

• Aboriginal engagement;
• Potential impacts to Aboriginal and Treaty rights;
• Aboriginal health effects assessment;
• Atmospheric environment (air quality, light, noise);
• Geochemistry, groundwater, surface water;
• Fish and fish habitat, migratory birds, wildlife and wildlife habitat; and
• Effects assessment methodology.

Schedule and conduct further technical meetings with the Agency and other government reviewers as the proponent prepares its responses to ensure that information requirements are met.

(II) In developing the proponent's response, take into consideration the summary of comment/rationale linked to the information requests.

(III) With respect to the information requests applicable to Aboriginal and public comments:

1. consider and incorporate all primary data, traditional and community knowledge provided in the proponent's responses and revision of the EIS or provide rationale to explain why the information is not required; and
2. respond in writing and through other engagement activities to all Aboriginal concerns documented in Annex 3, including those that are not related to an information request. 

(IV) Conduct and complete all data and sample collection, handling, analysis, and verification. Report findings and conclusions using best practices that must be executed by qualified persons with prior training and experience in the relevant subject matter.

(V) Ensure environmental studies for the purposes of the federal environmental assessment are conducted in accordance with best practices and current guidance. Where professional standards dictate, ensure that the studies are reviewed and signed off by qualified persons with third party attestation statements that deem the qualified persons are independent parties with respect to the Project and the proponent.

(VI) Engage with all potentially affected Aboriginal groups ^[1] on the following, at a minimum:

• baseline conditions, including potential or established Aboriginal and Treaty rights that may be affected by the Project;
• alternatives assessment;
• project components and related activities;
• effects assessment, including valued components, spatial and temporal boundaries for the assessment, and adverse impacts to potential or established Aboriginal and Treaty rights;
• mitigation measures, including Aboriginal accommodation measures to address impacts on Aboriginal and Treaty rights;
• residual effects, including identification of outstanding Aboriginal issues; and
• the follow-up monitoring program.

(VII) Ensure feedback, information, and studies, including Aboriginal traditional knowledge stemming from Aboriginal engagement completed by the proponent, are incorporated in the EIS.

Annex B3 - Instructions for Aboriginal Engagement Requests of IR-1

The proponent shall adhere to section 11.2 of the EIS Guidelines in structuring and executing the Aboriginal engagement activities: "The proponent will structure its Aboriginal engagement activities to provide adequate time for Aboriginal groups to have reviewed the relevant information in advance and to ensure there are sufficient opportunities for individuals and groups to provide oral input in the language of their choosing. Consultation activities must be appropriate to the groups' needs and should be arranged through discussions with the groups."

In consultation with the Aboriginal groups and after reviewing the EIS, the Agency determined that the proponent's engagement activities to-date is inadequate. Thus, as per section 9.2 of the EIS Guidelines, the Agency provides the minimum expectations for the additional engagement activities for the proponent.  

(VIII) Aboriginal engagement deliverables include:

• Meetings, workshops, and other communication approaches on the lists identified in Annex B2 above, designed and executed in a manner and timeframe that is acceptable to the potentially affected Aboriginal groups;
• Use of plain language documentation and materials during engagement activities;
• Written report on all engagement activities that includes the information exchanged between the proponent and the participants, feedback received, which communities provided that feedback, how the information and outcomes are incorporated in the effects assessment, mitigation and accommodation measures, significance determination, and follow-up programs;

(IX) Engage all potentially affected Aboriginal groups on the following, at a minimum:

• Items identified in Annex B2 (VI);
• Aboriginal comments on the EIS (in Annex A3) and the Project; and
• Revised EIS the proponent plans to submit as the response to IR-1, which includes how feedback and input from the Aboriginal communities are incorporated in the revised EIS.

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^[1] Eagle Lake First Nation, Wabauskang First Nation, Wabigoon Lake Ojibway Nation, Whitefish Bay First Nation, Aboriginal People of Wabigoon (not affiliated with other Métis groups in the province), Métis Nation of Ontario (represented by Region 1's consultation committee), Grassy Narrows First Nations, and Lac Seul First Nation.