RAGLAN MINE PROJECT - PHASES II AND III GUIDELINES FOR OF THE PREPARATION OF THE ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT

Transcription

1 RAGLAN MINE PROJECT - PHASES II AND III GUIDELINES FOR OF THE PREPARATION OF THE ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT APRIL 2015

2 TABLE OF CONTENTS 1. INTRODUCTION Kativik Environmental Quality Commission Inclusion of sustainable development objectives MAJOR ISSUES Biophysical Issues Social and community issues Cumulative effects Restoration issues COMMUNICATIONS AND CONSULTATIONS CONTENTS OF THE IMPACT STATEMENT Context Project Description Description of the environment Study area Description of the biophysical environment Description of the human environment Socioeconomic aspects Quality of life and cultural environment Heritage and archaeology Land use Impacts analysis Biophysical impacts Human impacts Economic benefits Quality of life and cultural environment Heritage and archaeology Land use Cumulative impacts anaylsis Restoration Mitigation and residual impacts compensation measures Accident management Monitoring and follow-up programs PRESENTATION OF THE IMPACT STATEMENT APPENDIX A - COMPONENTS OF THE PROJECT DESCRIPTION

3 1. INTRODUCTION On December 1, 2014, the Ministère du Développement durable, de l Environnement et de la Lutte contre les changements climatiques (sustainable development, the environment and the fight against climate change, MDDELCC) received preliminary information on phases II and III of the Raglan mine project in Nunavik. These phases consist in extending Glencore Canada Corporation s Raglan mine project for 20 years or more. The information was transmitted to the Kativik Environmental Quality Commission on December 5, 2014, for recommendation on the scope of the information to be provided by the proponent in its impact study. The mine project is automatically subject to the environmental and social impact assessment and review procedure as established in paragraph 1, Schedule 1, of section 23 of the James Bay and Northern Québec Agreement (JBNQA), as well as in paragraph (a), Schedule A of Chapter II of the Environment Quality Act. The Commission is of the opinion that this particular project requires an adapted directive for the implementation of the environmental and social impact assessment study. The Commission will then analyze the study and make a decision in regard to the project s environmental and social acceptability. The project s Phase II consists in opening two new underground mines (Mine 14 and Donaldson) for operation from 2019 to Phase III consists in opening three new underground mines (Mine 8, Boundary and West Boundary) and developing them gradually between 2023 and Ore production for both phases will remain at the Raglan mine s current annual rate of 1.32 metric tonnes. Most of the infrastructure already in place will be used for phases II and III, i.e. the concentrator, the accommodation facilities for mine employees, the dock at Deception Bay, the tailings storage facility, the Donaldson airport, the domestic wastewater treatment system, the drinking water supply system, and the road network throughout the Raglan mine property. This directive sets out instructions for the project description and for the description and assessment of its major issues. The impacts, benefits and experiences of the project over the past 15 years constitute a source of information that could to anticipate the for the next 20 years. All the information, based on the preliminary information and the lessons learned from phase I, will inform the Commission s analysis of the environmental and social repercussions of each of the project s major issues. This analysis will provide an overall assessment of the acceptability of the anticipated environmental and social impacts. The current directive must not be considered exhaustive. The proponent must include in the impact study any additional information it deems relevant. This directive describes the Commission, sustainable development and the major issues approach. A list of the points that Glencore Canada Corporation must include in the environmental and social impact study is then provided

4 1.1. Kativik Environmental Quality Commission The Kativik Environmental Quality Commission was established under Section 23 of the JBNQA and is governed by sections 181 to 213 of the Environment Quality Act. The Commission is responsible for evaluating and examining development projects under provincial jurisdiction, occurring on land governed under the JBNQA and located north of the 55th parallel. The Provincial Administrator of the JBNQA transmits to the Commission preliminary information on projects proposed by proponents. If a project is automatically subject to the assessment procedure, the Commission prepares a directive specifying the scope of the impact study to be undertaken by the proponent. This directive is transmitted to the Administrator, who forwards it to the proponent, with or without modifications. For grey zone 1 projects, the Commission decides for each whether or not it is subject to the assessment procedure. If subject to review, it prepares a directive for the impact study to be undertaken by the proponent. The Commission analyzes the impact studies transmitted to it and may hold public consultations with the communities affected by a project. It renders decisions on whether or not to authorize projects, with or without conditions. The Commission makes impact studies and related reports or documents available on its web site ( This site can also be used by individuals to express their comments or opinions on projects reviewed by the Commission Inclusion of sustainable development objectives The goal of sustainable development is to meet the needs of the present without compromising the ability of future generations to meet their own needs. Its three objectives are preserving environmental integrity, improving social equity and boosting economic efficiency. With this in mind, projects in the planning and decision-making process must strive to incorporate and balance these three objectives while also including the input of residents. As well, projects and their variations must take into account relationships and interactions between the components of ecosystems and must fulfill the needs of communities without encroaching on those of future generations. In developing the project, the proponent is required to take into account sustainable development objectives and detail its responsible management program objectives, including the concrete and measurable objectives it plans to implement for environmental protection, economic efficiency and social equity. The proponent must also present its own sustainable development policy. The 1 Projects that are not listed in either Appendix 1 or 2 of Section 23 of the JBNQA

5 impact assessment must summarize the proponent s sustainable development approach and explain how the project s design takes this aspect into account. 2. MAJOR ISSUES Since the project was authorized in 1995, the original certificate of authorization has been amended over a dozen times. In 2013 for example, a change was granted to increase concentrator production, expand the maximum storage capacity of waste rock and increase the population at Katinniq. The proponent has conducted and continues to conduct follow-ups on the project s impacts in conformance with the requirements of the certificate of authorization and its amendments, and also implements follow-ups on its own initiative. As part of the new environmental and social impact study to be conducted, the proponent must describe the project as it operates today and as it will operate during the proposed phases II and III. The proponent must also outline the lessons learned from phase I, especially in regard to the social environment. The proponent must present the anticipated impacts and benefits of phases II and III based on baseline conditions, i.e. the project as authorized with its monitoring and follow-up program, commitments (including the impact and benefit agreement), mitigation and compensation measures, and the restoration plan. This must be followed by an explanation of how the impact assessment will lead to adjustments of mineral exploration activities over the next twenty years. To that end, the proponent will explain how it intends to reduce impacts by modifying mitigation measures and offsetting residual impacts through compensation measures, where needed, and how the follow-up and restoration plan will be affected accordingly. The proponent must also detail the cumulative effects of the project and those caused by other users of the environment or its resources. The impact assessment must be built around the project s major issues. These may be defined as the components of the project that will most likely form the basis for consideration of the authorization application, and for which a value will be assigned. The goal of this approach is to ensure that the impact assessment is structured in order to be user-friendly for decision makers and the general public. Accordingly, the proponent will ensure that sensitive components are highlighted in the impact assessment. This focus must be enhanced by explanations that will lead to effective use of the assessment in the approval process and in disseminating information to the general public

6 Activities of the Raglan mine affect some communities or land users more than others, namely Salluimiut. Some impacts of the mine may also affect Nunavik as a whole. The proponent s analysis must take that into account. Under no circumstances must the major issues approach be construed as a license to streamline the study. All the necessary information for decision-making must be included. On the other hand, highly technical information, although essential for checking legal conformance, must not detract the reader from the major issues surrounding the project s impacts on the environment. Where appropriate, the proponent may place such information in a footnote or in an appendix. The major issues approach must address the mitigation and compensation measures that the proponent proposes to implement. This analysis will help determine the follow-up program, especially if there is uncertainty surrounding some of the issues. Although the Commission has targeted major issues, it expects the proponent to also define these based on its experience and the public consultations held with the affected communities. During this process, the proponent must pay particular attention to information given about values and traditional knowledge. Although no major change in infrastructure is planned and the project is restricted mainly to opening new underground mines and closing others, major issues, mainly of a biophysical, social and community-related nature, must nonetheless be considered. Other issues to address include cumulative impacts and the restoration of the mine site Biophysical Issues For phase I of its project, the proponent has implemented numerous mitigation measures. Nonetheless, impacts persist, for example in the form of dust emissions on the road near Deception Bay and the tailings storage facility. The management of acid-generating tailings and their maintenance in a permafrost setting despite climate change conditions continues to be a concern and will be exacerbated by the continuation of mining activities. Dust management at Deception Bay and the tailings storage facility, the management of waste rock, and the management and protection of water, fauna and flora have been identified as major issues Social and community issues Without minimizing the importance of the preceding issues, social acceptability is a critical issue in phases II and III of the Raglan mine project. Land use has been modified for many years by mining activities in the area. For example, navigation in Deception Bay has modified access to subsistence and harvesting areas. Jobs held by Inuit have positive as well as negative impacts

7 Social acceptability and the very acceptability of mining development in Nunavik are conditioned by the project s financial and social impacts and Inuit s perception of these impacts. The pursuit of mining activities by Glencore Canada Corporation will continue to generate social and economic impacts for the communities involved. They will also have cumulative effects on their health and well-being. The impact study must therefore specifically address these issues Cumulative effects The Plan Nord is designed to encourage the development of mining projects in Nunavik. Canadian Royalties Inc., which mines for nickel in the same area as Glencore, has recently begun shipping concentrate from its new dock at Deception Bay. The cumulative effects linked to shipping on Deception Bay are but one example of the combined effects that are likely to arise in the region as projects are carried out or added. As the Raglan mine has been in operation for more than 15 years, the issues surrounding the continuation of mining operations also include the pressure the project could exert on the environment and on local communities over the long run. In essence, the impacts on the physical, biological and human environments identified in 1995 and cited as temporary at the time will now be prolonged for 20 years or more. Accordingly, the proponent s impact study must take into account the cumulative impacts, over time and in space, of adding infrastructure, including the human environment, and those arising from the presence of other projects Restoration issues The transition from open pit to underground mining is an opportunity for progressive restoration. The proponent, while being engaged in other activities, will have the opportunity to restore the mine site in areas where operations have ended or will be ending soon. The restoration of the Raglan mine site is a major issue that must be addressed with innovative methods, especially in view of climate change. The proponent must plan to adapt the management of the restoration work to the prevailing medium- and long-term conditions. For example, planning should address tailings integration in permafrost as well as the natural regeneration of some areas

8 3. COMMUNICATIONS AND CONSULTATIONS One chapter of the impact statement must address and analyze the consultations held as part of the project s phase II and II planning. The proponent will present an overview and analysis of the results of the communication and consultation program carried out during the project's first phase including the results of the existing agreement between the proponent and Inuit communities. It will describe the communication mechanisms including the Raglan Committee. The analysis will review the issues perceived as most important by the land users and the communities involved. Then, the proponent will present the communication and consultation strategy used in the planning of Phase II and III of the project. It must present the analysis results obtained, accompanied by a section on communications with the communities that harvest the wildlife and flora in the mine project area. This section must capture the communities perceptions of the project, including its mitigation measures. The proponent is advised to adopt a new communications plan for the project, launch the consultation process quickly and convene all the parties involved, i.e. individuals, groups and communities as well as government departments and public and parapublic organizations, especially those based in the administrative region concerned

9 4. CONTENTS OF THE IMPACT STATEMENT Using the major issues approach proposed in the introduction, the proponent shall present an impact statement with the following sections Context The proponent will begin with a background description of phase 1 and then describe the components of phases II and III. This section must include: A short presentation of the proponent; The project justification, including a discussion on the project s rationale (highlighting environmental, social, economic and technical aspects at the local and regional levels, as well as at the national and international levels, if any); A summary of the reference state, including a map at a suitable scale detailing existing main and related infrastructures and the project in its current state; The solutions envisioned for phases II and III, highlighting information gained in phase I (e.g., justification of mining choices in light of problems encountered during phase I and the solutions applied); Neighbouring facilities related to other projects or activities Project Description The proponent must describe the components of the project with a level of detail that clearly frames the issues. The alternatives and variations of the components must be presented by comparing phase I infrastructure and methods to those of phases II and III. In this way, the proponent will demonstrate that the choices for phases II and III will be made in light of experiences gained since the approval of the Raglan mine project. General components required for the project description are presented in Appendix A Description of the environment Study area The proponent will identify a study area and justify its boundaries. If necessary, the study area may comprise sections of variable scale according to the impacts studied. As a whole, the area must be large enough to accommodate all of the activities planned for phases II and III and must encompass all the direct and indirect impacts of the overall project on the biophysical and human - 7 -

10 environments. Hence, the location must be justified, along with the size of the study area and the technical, economic and social constraints. The proponent must locate the proposed project in relation to current patterns of land use. The location must be large enough to include all human (Salluit and Kangiqsujuaq communities) and biophysical aspects on which the project and its associated infrastructure are likely to have an effect. The study area should be large enough to offer a choice of sites for future infrastructure while accommodating current infrastructure and including previously disturbed sites. The proponent must justify the inclusion or exclusion of Puvirnituq, or other communities, with those of Salluit and Kangiqsujuaq already specifically considered for this project Description of the biophysical environment The proponent will describe the current state of the environment as it appears in the study area today. Using both qualitative and quantitative inventories, the proponent must describe as factually as possible the components of the biophysical and human environments that are likely to be affected by the project. If the data available from government, municipal, Inuit or other agencies are insufficient or are no longer representative, the proponent must complete the description of the environment with inventories consistent with industry best practices. Given the many years of monitoring, these descriptions could be based on data collected by the proponent s monitoring programs since the early 90s. These data must represent current conditions and trends observed since the establishment of the mine. The following list details the main components to be described. The list is based on the components relevant to the issues and impacts of the project. General geology and topography of the land, presence of permafrost, and areas susceptible to erosion and ground movement; Rivers and lakes and their physical, chemical and bacteriological properties, uses downstream from discharge points and water budget (flow, bathymetry, etc.); Sediments in the receiving water body (organic matter, particle size and metals); Banks, wetlands (marshes, swamps and bogs), flood zones; Hydrogeological context; Climate conditions: annual temperature values, frost periods, level of average and maximum rainfall over 10 years and, if available, over return periods of 20, 30, 40 and 100 years, estimates of annual evaporation (mm), map of prevailing winds and specific conditions observed in the study area such as fog risk and microclimate areas; Vegetation cover, indicating the presence of fragile or exceptional plant communities; - 8 -

11 Wildlife and plant species (terrestrial and aquatic) and habitats of these species, with particular emphasis on threatened or vulnerable species or those likely to be so designated; in the case of wildlife, migration patterns, particularly of caribou; Mining residues dust dispersion at the mining sites and Deception Bay; Surface water quality and temperature of the Deception River; Arctic charr populations of the Deception River; Fauna and flora in Deception Bay; Biophysical conditions in the reservoir created by the Katinniapik dam; Concentrations of particulates and other contaminants emitted by the incinerator; State of rehabilitated sites Description of the human environment The proponent must describe the human environment for the entire project, taking into account related components and the different project phases. The human environment consists of Inuit and non-native communities located within the study area. The main elements of the human environment include, namely, socioeconomic aspects, quality of life, cultural context, heritage, archeology and land use. More specifically, the proponent will address the themes of family, education, health, housing, poverty and cost of living, employment and community development. These need to be addressed at the community level, but also in a regional perspective. If necessary, other issues deemed relevant to the assessment of the project may be described. Given that the mining industry has been established in the sector for several decades, the impact assessment must highlight its main effects observed on the human environment, and especially on socioeconomic development and quality of life in the region Socioeconomic aspects The proponent must present the demographic profiles, demographic outlook and economic profiles of the communities currently in the study area (jobs, industries, sources of income, etc.) The proponent must also describe the labour pool and the Inuit enterprises qualified to fulfill contracts in connection with the current and anticipated mining activities and the construction of the project, and with due consideration to other existing or anticipated mining projects. In collaboration with the Kativik School Board (KSB), the proponent will describe Nunavik s school system with the support of statistics on the number of students, the level of education, the number of graduates, the success rate and drop-out rate, etc. The discussion will include a - 9 -

12 description of existing training programs for both youth and adults as well as joint training programs related to the mining sector with KSB or other organizations. Specific details on the training, recruitment and integration of Inuit in the workforce pool must made available. More specifically, the proponent will present a portrait of the evolution of Inuit employment at the mine site since the beginning of its activities (number of Inuit workers by gender and type of job - and retention rate over the years, layoffs and rehiring, banishments, etc.),. He will describe the training programs that have been set up for the Inuit since the opening of the mine, and analyze their strengths, weaknesses and outcomes. He will present the strategy for the worker s integration of new employees and measures in support of their promotion measures. Finally, the proponent will produce a report of all the employment measures that were implemented, with explanations of their success or failure and their level of success. Based on these analysis, the proponent will clearly present the measures that will continue to be implemented be reconducted for phases II and III for matters related to training, integration and job retention and the new ones Quality of life and cultural environment Including the Inuit point of view, the proponent must document quality of life and cultural factors for the communities in the study area, including but not limited to the social structure of households based on Inuit cultural values such as families, termed ilagiinniq in the Inuit language, number of people, intergenerational aspects, community life that can include social relations, consumption habits, subsistence and harvesting activities, political and social dynamics at the local and regional levels, sense of community or collectivity and the biophysical environment. In addition, the cultural environment specific to these communities must be described. Culture refers mainly to knowledge, beliefs, values, norms, roles, lifestyles, and behaviours acquired by individuals as members of a group, community or specific society. The proponent must address the issue of global health including non-medical factors that can influence the physical and mental health of people such as alcohol and drug abuse, housing conditions, work discrimination and poverty. Alcohol and drug abuse is a major problem in Nunavik and may affect employment in the mines. The proponent will present the company s policy on drugs and alcohol at the mine site and provide statistics on the number of people who were laid-off in connection with this policy. He will indicate whether or not he offers support programs for employees with alcohol or drug consumption problems and or he intends to develop such programs. The proponent will also describe existing programs related to the consumption of drugs and alcohol in communities concerned by the project, and specify whether or not the company is involved in them

13 The proponent shall present the housing situation (quality, quantity, occupancy rate, etc.) in the communities of Salluit and Kangiqsujuaq. In addition, the proponent will address the issue of discrimination between workers at the mine site, for different levels and types of jobs. He will present, where appropriate, discrimination cases against women or cases of sexual harassment. The proponent will mention, where appropriate, existing programs, measures or actions that have been undertaken to raise the awareness of discrimination to the staff, or deal with problems related to it. The proponent will outline and comment on the effectiveness of these programs, measures or actions. Finally, the project, as proposed by the proponent in the preliminary information, is likely to cause impacts in all Nunavik communities. In this regard, the Commission is aware that an impact and benefit agreement, signed between the proponent and third parties for Phase I of the project, included mitigation measures for social and environmental impacts, as well as commitments on monitoring and surveillance. A review of the effects of the agreement on the concerned communities must be presented in order to make a connection with the "Mitigation and residual impacts compensation measures" section of the new Environmental and social Impact study and propose the necessary adjustments Heritage and archaeology The proponent must describe the prehistoric, historic and spiritual sites in the study area and areas of particular interest such as burial grounds and sacred or significant places. In addition, the proponent must perform detailed archaeological studies to thoroughly characterize the archaeological potential of the area by identifying known archaeological sites, areas with archaeological potential and other areas with heritage interest, whether or not they are protected by the Cultural Property Act. Note that the Avataq Cultural Institute has expertise in this area and is an appropriate reference for this purpose Land use The proponent is required to address current land use. The following items must be described, after consultation with the appropriate stakeholders: Tenure and boundaries of Category I, II and III lands; Significance of the affected watersheds for land users; Traditional travel routes and their periods of use, including those located in the Deception Bay area; Territories where Inuit conduct subsistence and harvesting activities in the study area, including associated infrastructure (road, trails, camps, etc.);

14 Designated protected and conservation areas (temporary or final status) and other proposed protected areas; Location and description of dwellings, structures and buildings in the vicinity of the project; Location and description of areas for mineral exploration and exploitation, quarries and sand pits, outfitting and other types of land use, including vacation leases. Water supply sources. The proponent must elaborate on the social environment affected by the project by explaining the limitations of the data in the proponent s possession. The description of the social environment should make it possible to arrive at an overall assessment of the likely changes in lifestyles for the communities affected by the expansion of the project Impacts analysis This section focuses on the identification and assessment of the direct and indirect impacts of the project, both positive and negative, as well as measures to reduce or eliminate the negative impacts, to compensate for unavoidable residual impacts and those designed to maximize its positive effects. The proponent shall, in the appropriate sections, pay particular attention to the links between the old monitoring programs, the restoration plan and the certificate of authorization, with the programs to be developed. He will explain the reasons for such changes or for maintaining certain elements of the programs. In order to take into account construction phases, installation of infrastructure and operation of new extraction areas, the analysis should address short-, medium- and long-term impacts. Identification of impacts should correlate with the items in the "Description of the environment" section. When forecasting and assessing the consequences of the project, the proponent must indicate important details and clearly state the elements and functions of the environment that may be affected, as well as where, to what extent, for how long and with what overall effect. As mentioned previously, the project under consideration is, in fact, a later phase in a larger project that was implemented around 20 years ago. A more general assessment of the project s overall impacts shall be presented, especially the impacts from phases II and III. This assessment must deal with the major issues identified in the introduction and those identified by the proponent

15 The proponent shall provide a detailed assessment of these impacts and describe intended mitigation measures. The degree of validity of the data and the accuracy of projections should be indicated, emphasizing the choice and scope of mitigation measures and the identification of components that will be the subject of a new environmental and social monitoring program (or the continuation of a current monitoring program that has been approved by the MDDELCC). Based on current community resources, land use and occupancy, site suitability and the carrying capacity of the environments, the proponent should assess environmental losses and changes in natural conditions of equilibrium. Moreover, the proponent should determine thresholds of irreversibility for all impacts, giving particular consideration to the impacts of expanding the project on current and future land use Biophysical impacts The proponent s analysis should include, inter alia: The quality of receiving waters affected by the extraction of ore in the new mines combined with current extraction activities or the expansion of waste rock and tailings piles; Maintenance of fish populations, taking into account possible and prolonged toxicity of effluents and the life cycles of the species involved (especially if effects have already been documented); The survival and movement of terrestrial wildlife and birds, especially caribou, the destruction of preferred habitats or the possible destruction of rare or endangered species; Impacts on the aquatic or terrestrial environment from the use of melters or abrasives on roads and bridges or from accidental spills of petroleum products or any other chemical used; Drainage, runoff or wind erosion; Based on a permafrost distribution map, impacts resulting from the risk of subsidence and erosion tied to permafrost melt at the borders of the scheduled facilities; Effects on air quality from dust emission and transport Human impacts Regarding the social environment, the proponent must consider all the social impacts of the project so as to highlight the major issues. This section will be an overall assessment of the effects of long-term changes on the lifestyles of the concerned communities by the project. To

16 this end, the proponent should refer to phase I of the project and other similar projects in the region, highlighting and providing a report on the experience gained. The proponent will include, but is not limited to, the following impacts: Economic benefits Number and type of temporary and permanent jobs created for Inuit and non-natives, by project phase; Contracts given to Inuit and Inuit enterprises; Expected short- and long-term economic benefits for local businesses; Development prospects in related sectors for local communities or the region Quality of life and cultural environment Presence of many non-native workers on Inuit communities in the study area (social relations problems, conflicts between groups of individuals, emergence of social problems, etc.); Nuisance sources such as noise, dust and vibrations; Increase in air traffic; Impacts of the lengthy absences of Inuit workers on family, ilagiinniq, and communal life; Changes in Inuit lifestyles and living conditions, in particular: subsistence and harvesting activities, monetary inflows and outflows of Inuit families and consumption habits due to paid work; Perception and fears of Inuit in regard to the possible contamination of the environment, especially from the deposition of dust on water bodies from ground transportation; Visual impact of the intrusion of new elements in the visual field and esthetic changes to the landscape, including light pollution; Alcohol and drugs consumption. To the extent possible, the proponent will assess the influence that the mine had on the Inuit quality of life since its opening (life habits, social relations, values, behaviors, etc.) Heritage and archaeology Impacts on prehistoric, historic and spiritual sites in the study area, areas of particular interest such as burial grounds, sacred or significant places and archaeological sites

17 Land use Presence of terrestrial and maritime roads on Inuit travel routes and on land use by Inuit; Change in subsistence and harvesting activities along the road infrastructure and in navigable waters; Existing or planned conservation areas (national parks, biodiversity reserves, etc.); Wildlife use by sport hunters and fishers. In the analysis, the proponent will specify the items that can be made the subject of an impact and benefit agreement with the communities, in particular new economic, environmental and social initiatives. He we detail the status of discussions to that effect Cumulative impacts analysis The proponent will justify the geographic boundaries of the cumulative effects assessment. Note that these may vary from one component to another. The proponent shall identify and assess the cumulative environmental and social effects of the three phases of the projects, combined with the effects of other work or activities underway or reasonably expected to be implemented in the same area. The proponent shall propose and justify the projects and activities selected for the cumulative effects assessment. The components for the cumulative environmental and social effects assessment must be related to the major issues. In this regard, the proponent should consider the following list, without being limited to its items: Phase I of the current project and its relationship to phases II and III; Other current or future projects, especially mineral exploration or conservation (caribou calving area, biodiversity reserve, etc.). The proponent must identify the environmental components that will be the subject of the cumulative effects assessment. In this regard, the proponent must consider the following items, without being limited to them: Endangered animal and plant species; Fish and their habitat; Birds and their habitat; Terrestrial wildlife and their habitat;

18 Inuit quality of life; Land use by the Inuit, including in Deception Bay; Tourist and recreation activities, especially sport hunting and fishing; Impacted watersheds and protection of their use Restoration With specific respect to mitigation measures for the mine operation, the proponent should provide separate explanations of measures that were already taken, those that will be taken during production and those that will be implemented at the decommissioning phase of the mine. To help conduct this exercise, appropriate mapping support should be provided. In particular, the document must describe: The gradual restoration strategy, with details on the sites, calendar, work sequence, etc.; The level of restoration of the decommissioned facilities, or in the process of being decommissioned, associated with Phase I of the project; The progressive restoration program during operations, the containment and monitoring program during temporary shutdowns and the overall final restoration program; The conditions for reconfiguring tailings sites and stabilizing them against wind or runoff erosion created by conditions of climate change; The return of waste rock to the galleries; The possibility of using overburden for restoring decommissioned sites; The recovery of some equipment and facilities or their transfer of property Mitigation and residual impacts compensation measures The proponent should describe the mitigation measures already implemented or to be implemented that are intended to mitigate the project s new environmental and social negative impacts. This discussion will highlight the proponent s choice of mitigation measures in relation to the experience acquired during phase I of the Raglan project. The proponent will demonstrate that the selection of methods will be based on knowledge gained during operations of the Phase I of the project and through dialogue with the communities. The proponent must pay particular attention to measures designed to reduce or eliminate discrimination and harassment problems or other conflicts between mine employees

19 The proponent will also describe proposed measures to maximize the project s positive impacts such as those directed towards Inuit hiring, land access or economic benefits. Lastly, the proponent should explain the nature and extent of residual impacts likely to remain after implementation of mitigation measures. Development and compensation proposals and commitments for offsetting the loss of wildlife habitat must be provided Accident management Given the remote location of the mine site, the proponent should continue to apply emergency response measures in the event of technological disasters, spills, etc. The proponent will provide an update of the emergency response plan Monitoring and follow-up programs For all new underground mines, roads and infrastructure, the proponent should explain its intended monitoring mechanisms to ensure that the stated mitigation measures are followed. The proponent should incorporate them into existing follow-up measures and propose new measures, in particular for social aspects. The proposed follow-ups should comply with Directive 019 and current follow-up directives issued by the different provincial departments. The proponent shall submit recommendations on the scope and extent of environmental and social follow-ups, and the community s involvement. These measures will become an integral part of the project and should be formulated so as to convey knowledge on genuine phenomena that occur as a result of the pursuit of this type of development in a northern environment. Lastly, the proponent will detail a strategy to disseminate and provide a layman s version of its environmental and social monitoring and follow-up reports

20 5. PRESENTATION OF THE IMPACT STATEMENT The impact study must be written in a clear and concise manner and be limited to the ideas that are necessary to a solid understanding of the project and its impacts. As mentioned previously, more technical elements should not be included in the main document unless they are essential to reader comprehension. Information that can be diagrammed or mapped must be presented in that format and at the appropriate scale. Project components must be displayed in thematic as well as composite maps. To the extent possible, the information must be analyzed in light of the appropriate documents. The Commission encourages the proponent to use photographs to illustrate the salient points of the impact study. The proponent should also assess the availability and quality of the data used. All sources of information must be given in the reference section. The methods used for the impact study such as inventories, investigations, interviews and comparative analyses must be presented and explained. To encourage public participation in general in the environmental and social impact assessment and review procedure established under Section 23 of the JBNQA, and during public consultations in particular, and to facilitate the work of the Commission, Nunavik authorities and the communities concerned by the project, the proponent should: Submit the main impact study document in French and in English. Prepare a summary containing all the topics addressed in the impact study and including illustrations and maps that explain the operations planned for phases II and III of the Raglan mine project in a manner that is easy to grasp. This summary should be submitted in French, English and Inuktitut. The above documents must be submitted in hard copy and PDF (Portable Document Format), along with their accompanying documents. The Commission may request the submission of English versions of documents other than those named above, or of their summaries. The Commission will make available on its website all the documents submitted by the proponent in order to inform the public consultations that will be held in the concerned communities during the analysis of the project

21 APPENDIX A - COMPONENTS OF THE PROJECT DESCRIPTION The description must include, but not be limited to: Preliminary activities (clearing, blasting, backfilling, watercourse diversion, etc.), including a description of sites, quantities, boundaries, and collection, transportation and disposal methods; Permanent facilities and infrastructure (access ramps, crushing equipment, if required, waste rock, overburden and ore stockpiles, discharge points in the receiving environment, etc.); Average and maximum extraction rates, projected duration of the operation and potential for other development phases; Mining method(s) that generate less waste rock, with justification of selected extraction methods (open pit vs. underground); Mineralogy of the various types of waste rock and ore, including percentage of classes, subclasses and mineral groups in their composition (sulfides, oxides, carbonates, etc.) and identification of all major and trace minerals based on representative samples; Type of explosives used, their in-situ fabrication, approximate amount required per amount of ore extracted, and the principal residual chemical products resulting from their use and their quantitative relationships; Amount, nature and storage location of overburden and topsoil to be displaced and topsoil reuse methods, if any; If relevant, determination of ore storage sites, reasons for choosing these sites, leachate treatment options and storage capacity and maximum storage time (e.g. temporary stockpiles vs. storage of low-grade ore for more than one year); Noise and other nuisance sources such as machinery and related infrastructure, etc.; Methods used to prevent wind and water erosion of stockpiles; Energy generating equipment, including location, generating capacity, and other features; If required, garages, machine and equipment maintenance shops, washers, dryers and storage areas for reagents, hydrocarbons, chemicals, explosives, etc.; Layout of transport roads, access roads, service roads and other thoroughfares; Transport and shipment of the ore concentrate; - 1 -

22 For each component of the mine, construction and operations schedule information; The mine lifespan. Waste rock management Total volume of waste rock to eliminate (order of magnitude in the thousands of m 3 ); Mineralogy of the various types of waste rock, including percentage of classes, subclasses and mineral groups in their composition (sulfides, oxides, carbonates, etc.) and identification of all major and trace minerals based on representative samples; If required, assessment of the potential for acid mine drainage from waste rock and the quantity of waste rock with this potential; Assessment of the surface area for stockpiles, justification of the selected location(s), especially in light of hydrogeological and drainage conditions, and detailed description of management and control conditions; If applicable, conditions for using waste rock as fill material and a more general description of stockpile restoration efforts, including returning waste rock to the galleries, the preferred method used in phase I (see "Mitigation and restoration measures"). Related Infrastructure The technical characteristics of the main work to be conducted for existing road repair and the construction of new access roads; The choice of road design criteria (design speed, width of thoroughfare, load capacity, etc.) according to intended use and road safety, among other criteria. The alternative designs and drawings and the lifespan of the roads built for extraction of the ore; The general characteristics of roads by segment and the sources of borrow material; The location, type and size of all bridges and culverts to be built over streams and rivers; Road construction criteria and methods; The maintenance methods (snow removal, culvert de-icing) Road safety improvement measures; Control measures of dust generated by road transport; - 2 -

23 The costs of implementing the different phases of project construction and maintenance, with a breakdown by section. Accommodation infrastructure New drinking water supply facilities; Wastewater management methods and discharge areas, including dilution rates, if applicable; Types and new volumes of residual materials generated, elimination methods and locations, and location and conditions of existing or future sites for solid waste management. The proponent will indicate the volume of waste anticipated, the expected lifespan of the proposed site, the facilities planned, and the method for managing sludge produced by the wastewater treatment systems; Recovery and recycling of residual materials and reduction of waste at source, i.e. before products are transported over the project area; Nature of hazardous materials and management method; Power supply method (capacity of generators, location, etc.). Fuel and hazardous materials storage sites The proponent will indicate if the location and type of structures, equipment and facilities for the storage and containment of chemicals, hydrocarbons or explosives have changed, and will state the product quantities that will be stored. If there are changes The proponent will demonstrate that these products conform to current laws and regulations, and indicate the safety and emergency measures developed. Borrow pits The proponent shall state specifically the intended use of the borrow pits required for the project, i.e. for the mine itself as well as for the construction of access roads or any other aspect of the project. Water Management The proponent will provide a comprehensive water balance for water used and discharged (m 3 /day and m 3 /year) for mining operations during phases II and III of the project. The water balance must be established and detailed for a full year to account for seasonal variations. More specifically, the proponent will provide the following information: - 3 -

24 Description of the flow pattern and rates of water used in extraction operations, specifying recirculation systems and annual and daily rates of water consumption for activities, specifying its use; Water supply sources, specifying amounts required; Uncontaminated runoff entering the mine site s water management system. Treatment and discharge of contaminated water The proponent will present and justify treatment methods for all mining wastewater (sedimentation, chemical and biological treatment, etc.) and present a detailed description of treatment methods including: Physical and chemical characteristics of the wastewater to be treated; Design criteria and maximum treatment capacity; Capacity and holding time of the various ponds; Treatment control techniques to ensure the good condition and optimal operation of equipment used or installed; Management of treatment by-products; Effectiveness anticipated (percentage reduction in contaminants, lack of toxicity); For the design of the retention pond, consideration of probable maximum precipitation, i.e. the most restrictive maximum for a six-hour or a 24-hour period, combined with average snowmelt over 30 days, using a 100-year return period. Final Effluent The proponent shall review its final effluents and provide the following information: Description of final effluent discharge standards (conduits, pipes, pumping, diffuser) and the anticipated average daily volumes and flow of the final effluent; Location of the final effluent discharge point on a map and the path leading to the receiving water. If the final effluent is discharged via a pipe: Bathymetry at the discharge point; Pipe diameter; - 4 -