ESRD AND CEAA RESPONSES

Transcription

1 Frontier Oil Sands Mine Project ESRD and CEAA Responses ESRD AND CEAA RESPONSES October 2014

2 ESRD and CEAA Responses Frontier Oil Sands Mine Project October 2014

3 Frontier Oil Sands Mine Project ESRD and CEAA Responses Acronyms 1 ACRONYMS The following acronyms are used in this Supplemental Information Request. AAAQO Alberta Ambient Air Quality Objectives ACFN Athabasca Chipewyan First Nation ADMF Acid Deposition Management Framework AER Alberta Energy Regulator BWS Basal Water Sands CEAA Canadian Environmental Assessment Agency CEMA Cumulative Environmental Management Association COPC Chemicals of Potential Concern EC Environment Canada EIA Environmental Impact Assessment ERCB Alberta Energy Regulator ESRD Alberta Environment and Sustainable Resource Development FHCL Fish Habitat Compensation Lake HHRA Human Health Risk Assessment ILCR Incremental Lifetime Cancer Risk km kilometre LCC Land Capability Classification LSA Local Study Area m metre MCFN Mikisew Cree First Nation ML Métis Local MNA R1 Métis Nation of Alberta Region 1 PAA Project Assessment Area PAD Peace Athabasca Delta PAI Potential Acid Input PDA Pre-Disturbance Assessment PRM Pierre River Mine October 2014 ESRD/CEAA Page 1

4 ESRD and CEAA Responses Acronyms Frontier Oil Sands Mine Project RSA RWI SIR TOR TRV Regional Study Area River Water Intake Supplemental Information Request Terms of Reference Toxicity Reference Value ESRD/CEAA Page 2 October 2014

5 Frontier Oil Sands Mine Project ESRD and CEAA Responses Alberta Energy Regulator 2 ALBERTA ENERGY REGULATOR The responses to SIRs in the Alberta Energy Regulator Section will not be considered as part of the EIA completeness decision made by Alberta Environment and Sustainable Resource Development. Note: Responses to all Round 3 SIRs received from AER are provided in the first part of this submission. October 2014 ESRD/CEAA Page 3

6 ESRD and CEAA Responses Alberta Energy Regulator Frontier Oil Sands Mine Project ESRD/CEAA Page 4 October 2014

7 Frontier Oil Sands Mine Project ESRD and CEAA Responses Air 3 AIR 3.1 Dispersion Modelling Question 1 Volume 2, Appendix 7a.1, Section , Page 3-3 Volume 1, ERCB SIR 1, Page 6 Teck states in Appendix 7a.1 that there is No change to Volume 4, Section , which indicates there is no change to the receptor grid. However, in response to ERCB SIR 1, Teck states that The revisions within this document reflect appropriate updates to the receptor grid associated with the Project that reflect changes in the Project. a. Clarify if there are changes to the receptor grid associated with the updated dispersion modelling. Response 1 a. Volume 4, Section , Pages 3-25 to 3-27 of the provides general information about the method used to develop the nested Cartesian receptor grid used in the air quality assessment. Based on revisions to the Project resulting from the Teck Shell asset exchange (for details, see the response to ERCB Round 2 SIR 1), Section of the revised air quality assessment (see the response to ESRD/CEAA Round 2 SIR 7, Appendix 7a.1) should state: Discussion of Change: The receptors are located in the LSA and the RSA with grid spacing that ranges from 20 m along the Project s MDA [main development area] plant limits and along the Project area boundary.... This text replaces the statement No change to Volume 4, Section The same method (described in Volume 4, Section , Pages 3-25 to 3-27) was used to develop a revised receptor grid following removal of the south development area (SDA) from the Project. Detailed information about the revised receptor grid is provided in the response to ESRD/CEAA Round 2 SIR 7, Appendix 7a.1, Attachment 7A.1D, Section 3D A total of 12,788 gridded receptors were used for the revised air quality assessment, compared to 15,011 for the original assessment (see Volume 4, Appendix 3D, Section 3D.3.2.1, Pages 3D-5 to 3D-6). October 2014 ESRD/CEAA Page 5

8 ESRD and CEAA Responses Air Frontier Oil Sands Mine Project As indicated, the receptor grid was revised to account for removal of the SDA from the Project. The revised grid was used in the dispersion model for the revised air quality assessment (see the response to ESRD/CEAA Round 2 SIR 7, Appendix 7a.1). Changes to the receptor grid are evident by comparing Figure 3D-1 in the (see Volume 4, Appendix 3D, Page 3D-7) with Figure 3D-1R in the revised assessment (see Appendix 7a.1, Attachment 7a.1D, Page 3D-4). The Project Update (see response to AER Round 3 SIR 1) will provide details of any additional changes to the receptor grid associated with the updated dispersion modelling. ESRD/CEAA Page 6 October 2014

9 Frontier Oil Sands Mine Project ESRD and CEAA Responses Air 3.2 Air Quality Assessment Question 2 Volume 1, ESRD/CEAA Figure 9a-1, Page 16 Volume 1, ESRD/CEAA Figure 9a-2, Page 17 Volume 2, Appendix 7a.1, Attachment 7a.1A, Figure 3-13R a. Provide Figures 9a-1 and 9a-2 overlaid with the concentration isopleths from Figure 3-13R. Response 2 a. This information request refers to the annual average NO 2 concentrations associated with the Application Case. The Application Case is when emissions from the Project are expected to be the greatest. The information request references three figures: Figure 9a-1 represents a smaller (34 km x 50 km) area centered on the Frontier Project and shows the mine plan for mid Figure 9a-2 represents a smaller (34 km x 50 km) area centered on the Frontier Project and shows the mine plan for The mine plan for 2035 nominally corresponds to the Application Case. Figure 3-13R shows Application Case annual NO 2 concentration contours on the local study area (LSA) base map, which represents a 110 km x 110 km area centered on the Frontier Project. Revisions to Figure 9a-1 and Figure 9a-2 are provided (see Figures 2a-1 and 2a-2). Figure 2a-1 shows annual NO 2 concentration contours associated with the Application Case predictions (from Figure 3-13R) overlaid on Figure 9a-1. The NO 2 concentration contours from Figure 3-13R do not match the mid-2021 mine plan shown in Figure 9a-1. Therefore, the mine plan and the contours shown are not correlated. Candidate passive monitoring locations 1, 2 and 3 were selected to provide an early indication of the maximum annual average NO 2 concentrations that could occur along the mine perimeter. Figure 2a-2 shows annual NO 2 concentration contours associated with Application Case predictions (from Figure 3-13R) overlaid on Figure 9a-2. Candidate passive monitoring locations 4, 5, 6 and 7 are where annual average NO 2 concentrations are predicted to be the greatest. Therefore, monitoring locations 1 to 3 provide an early measure of annual average NO 2 concentrations resulting from mining operations, and monitoring locations 4 to 7 provide a measure of annual average NO 2 concentrations due to peak year mining operations. October 2014 ESRD/CEAA Page 7

10 PRP RW PUMP HO US E T102 R12 W4 R11 Unna med Creek 18 Unnamed Creek 17 Unnamed Creek 16 R10 R9 Unnamed Cree k 19 T101 Unnamed Waterbody 12 RMS C Redclay C reek 284m 282m 280m T OSSP OPP Corridor OPP Ore Stockpile MAIN PIT RMS B RMS A 3 ETA Unnamed 1 Waterbody CSTA m EDA 1 305m 284m 284m 284m 286m 286m Tailings ETA 1 Corridor TTA PLANT SITE 284m U n na med Creek 2 Lodge Unnamed Creek 7 Redclay Creek Athabasca River Big Creek RMS D Unnamed Creek 6 Eymundson Creek T99 Asphalt Creek First Cr eek Unnamed Waterbody 15 PRP RWI Unnamed Waterbody 8 T98 U n named Creek 1 Unnamed Waterbody 7 Unnamed Waterbody 10 Candidate Passive Monitoring Location Figure 3-13R Annual NO2 Concentrations in µg/m 3 (Application Case) Mine Disturbance Pierre River Township Defined Watercourse Undefined Watercourse Waterbody KILOMETRES 1:200,000 UTM Zone 12 NAD 83 Acknowledgements: Base data: AltaLIS, Hydrology ground truthed by Golder (2009), Contours provided by Stantec (2014). Date: File ID: Author: CS Checked: CES (Original page size: 8.5X11) Figure 2a-1: Candidate Passive Monitoring Locations Mine Plan Mid-2021 Frontier Project Response to Supplemental Information Request: Round 3 ESRD/CEAA

11 335m 325m 315m PRP RW PUMP HO US E T102 R12 W4 R11 Unna med Creek 18 Unnamed Creek 17 Unnamed Creek 16 R10 R9 Unnamed Cree k 19 T101 Unnamed Waterbody 12 TLDA 1 RMS C Redclay C reek 325m RMS B RMS A EDA 1 335m Unnamed ETA 1 Waterbody 13 CSTA 319m 329m Redclay Creek Athabasca River OPP T m 270m 260m OPP 265m Corridor 260m 260m Dyke 1 270m 310m Tailings Corridor PLANT SITE Perimeter Dyke ETA 1 TTA 329m Unnamed Creek m 335m 340m 290m MAIN PIT Dyke 2 Dyke 3 310m 280m EDA 3 U n na med Creek 2 Lodge Aerodrome RWI Pipeline RWI Big Creek 5 RMS D Unnamed Creek 6 350m 345m Re-route Eymundson Creek 6 7 T99 Asphalt Creek First Cr eek Unnamed Waterbody 15 Mine Access PRP RWI Unnamed Waterbody 8 T98 U n named Creek 1 Unnamed Waterbody 7 Unnamed Waterbody 10 Candidate Passive Monitoring Location Figure 3-13R Annual NO2 Concentrations in µg/m 3 (Application Case) Mine Disturbance Pierre River Township Defined Watercourse Undefined Watercourse Waterbody Acknowledgements: Base data: AltaLIS, Hydrology ground truthed by Golder (2009), Contours provided by Stantec (2014). KILOMETRES 1:200,000 UTM Zone 12 NAD 83 Date: File ID: Author: CS Checked: CES (Original page size: 8.5X11) Figure 2a-2: Candidate Passive Monitoring Locations Mine Plan 2035 Frontier Project Response to Supplemental Information Request: Round 3 ESRD/CEAA

12 ESRD and CEAA Responses Air Frontier Oil Sands Mine Project Question 3 Volume 1 ESRD/CEAA SIR 27, Page 4-43 Volume 2, Appendix 7a.1 a. In regard to the revised air quality assessment as presented in Appendix 7a.1, discuss whether the response to Round 1 SIR 27 is still applicable. b. Update this response as required. Response 3 a. The CALPUFF and CALMET model options used in the revised air quality assessment (see the response to ESRD/CEAA Round 2 SIR 7, Appendix 7a.1) are identical to the model options used in the original air quality assessment (see Volume 4, Section 3). The response to ESRD/CEAA Round 1 SIR 27 is still applicable. b. Because the model assumptions are identical for both model options used, there is no need to update this response. ESRD/CEAA Page 10 October 2014

13 Frontier Oil Sands Mine Project ESRD and CEAA Responses Water 4 WATER 4.1 Water Management Question 4 Volume 1, ESRD/CEAA SIR 10, Pages 19 to 24 Volume 1, ESRD/CEAA SIR 34, Pages 147 to 150 In response to, SIR 10a (Page 23), Teck states that changes to the export of detritus to the Athabasca River due to Project-related diversions of tributaries are expected to be negligible for several reasons, including autochthonous production in diversion channels and pulsed inputs of detritus from the reclaimed landscape of the mine following reclamation. Teck also states that no effects on fish productivity are expected for the Athabasca River due to potential changes in detrital inputs. In response to SIR 34a.i, Teck indicates that Planned alterations in the Redclay Creek, Big Creek and Unnamed Creek 19 watersheds are expected to have negligible effects on detritus inputs to the Athabasca River. This assertion is made, not withstanding, that the flows in Red Clay Creek will be reduced by about 15-16%. a. Given that the mean annual flow of Red Clay Creek will decrease by 15-16% and this flow will enter the fish habitat compensation lake (FHCL), demonstrate by modelling the (FHCL) to support the assertion of a negligible change in detritus input to the Athabasca from Red Clay Creek. b. Assuming Teck s postulation that the mass of detritus production and delivery will remain roughly the same as pre-development levels proves to be correct, explain why there will be no effect on the suitability of the fish habitat in the 24 km reach of the Athabasca which will be deprived of detritus input as an end-leave result of the Project. Response 4 a. Modelling that quantifies the specific characteristics of detritus inflow and transport in the fish habitat compensation lake (FHCL) has not been completed because detailed characteristics and engineering design for the FHCL are not yet available. Detailed characteristics and engineering design of the FHCL is required for a modelling exercise to be informative. A qualitative assessment that provides reasonable predictions of the potential effects on detrital inputs at this stage of a Project was provided in response to ESRD/CEAA Round 2 SIR 10. October 2014 ESRD/CEAA Page 11

14 ESRD and CEAA Responses Water Frontier Oil Sands Mine Project As described in the revised fish and fish habitat assessment (see the response to ESRD/CEAA Round 2 SIR 30a, Appendix 30a.1), the mean annual flow of Redclay Creek is predicted to decrease in some assessment snapshots, with the largest decrease (-14.8%) predicted to occur at maximum build-out (Application Case [Year 2057]). The natural Redclay Creek channel consists of a defined upper watercourse located upstream and in the western part of the Project disturbance area (PDA), a defined lower watercourse located downstream of the PDA and a wetland area in the eastern part of the PDA that separates the upper and lower watercourse sections (see the responses to ESRD/CEAA Round 1 SIR 108c and ESRD/CEAA Round 2 SIR 45a). The wetland area currently serves as a biological filter for organic matter and limits the export of detritus from the upper watercourse to the Athabasca River (for details, see the response to ESRD/CEAA Round 2 SIR 10a). During Project operation, the Redclay Creek diversion, and additional water diverted from the upper part of Unnamed Creek 17, will bypass the wetland area and connect the upper watercourse to the lower watercourse through the FHCL. The Redclay Creek diversion will convey flows and organic material from the upper watercourse, the diversion, and the lower watercourse to the Athabasca River. As described in response to ESRD/CEAA Round 2 SIR 10a: allochthonous inputs of terrestrial organic matter are commonly the dominant source of material and energy in stream ecosystems. This suggests that the ability of tributary streams to convey allochthonous organic matter to the Athabasca River is an important factor influencing detrital inputs. Transport distance of fine particular organic matter is generally related to discharge (Webster et al. 1999). The response to ESRD/CEAA Round 2 SIR 10a further states: It has been shown that the export of organic matter to downstream reaches is highly pulsed. Wallace et al. (1995) showed that 63% to 77% of organic matter export occurred during the 20 largest flood events in an area over a nine-year period. Therefore, although mean annual flow from Redclay Creek and Big Creek will decrease during Project operation (i.e., relative to predevelopment conditions for some assessment snapshots), most detrital input will continue to be transported to the Athabasca River. In combination with the establishment of connectivity between the upper and lower watercourses of Redclay Creek, potential changes in detrital delivery to the Athabasca River are expected to be negligible. Other factors and conditions that support the assertion that changes in detrital input will be negligible include the following: The 14.8% reduction in mean annual flows in Redclay Creek represents 0.008% of the mean annual flow to the Athabasca River, further indicating the negligible potential for effects on the productivity of the Athabasca River. ESRD/CEAA Page 12 October 2014

15 Frontier Oil Sands Mine Project ESRD and CEAA Responses Water The diversion channel itself is expected to contribute detritus to the lower Redclay Creek watershed as the landscape around the diversion channel matures and contributes allochthonous inputs from an area that is currently not contributing detrital inputs. Flows to the Athabasca River from the Redclay Creek drainage will return to near baseline at closure (i.e., predicted flow reduction of 0.3%), and the upper Redclay Creek watershed will remain connected to the lower watercourse through the FHCL at closure, providing permanent contributions of detritus from the upper watershed to the Athabasca River. b. There will be no time during Project operations or closure in which the Athabasca River will be deprived of flows or detrital inputs from tributary watercourses in the PDA, which include Redclay Creek, Big Creek and Unnamed Creek 19. The prediction that the mass of detritus production and delivery will remain roughly the same as predevelopment levels is consistent with the prediction of no effect on the suitability of the fish habitat in the Athabasca River. Flow from Redclay Creek, Big Creek and Unnamed Creek 19 will not be interrupted or lost because of Project development or watercourse diversions. Rather, watercourse diversions and other development activities associated with the Frontier Project are predicted to reduce mean annual flows during the various assessment snapshots. Flows at closure for Redclay Creek return to near-baseline conditions and flow reductions in Big Creek are less at closure than during operation. Detritus will continue to be delivered to the Athabasca River during and after development of the Project from all tributary watercourses in the PDA. REFERENCES Wallace, J.B., M.R. Whiles, S. Eggert, T.F. Cuffney, G.H. Lughart and K. Chung Long-term dynamics of coarse particulate organic matter in three Appalachian mountain streams. Journal of the North American Benthological Society 14: Webster, J.R., E.F. Benfield, T.P. Ehrman, M.A Schaeffer, J.L. Tank, J.J. Hutchens and D.J. D Angelo What happens to allochthonous material that falls into streams? A synthesis of new and published information from Coweeta. Freshwater Biology 41: October 2014 ESRD/CEAA Page 13

16 ESRD and CEAA Responses Water Frontier Oil Sands Mine Project ESRD/CEAA Page 14 October 2014

17 Frontier Oil Sands Mine Project ESRD and CEAA Responses Water 4.2 Hydrogeology Question 5 Volume 1, ESRD/CEAA SIR 12, Pages 27 to 35 In Response 12a, Teck provides core photos for cores collected from coreholes drilled near Waterways Formation wells 02-23D, 02-35D and 12-12D. The core photos are for the Waterways intervals in the wells that were interpreted as weathered based on drilling cuttings and drilling rate. Though the core has a nodular texture and appears massive, all three cores demonstrate frequent mostly bedding-parallel partings or fractures. If some of these fractures are natural, they could provide fracture permeability through which groundwater flow could occur. a. Describe the geometry, origin and type of fractures seen in the core photos. Indicate the criteria used to differentiate fractures representing core break-up due to stress release and fractures that are naturally occurring. For the natural fractures, discuss their capability to transmit groundwater. Response 5 a. Two types of fractures were observed in the carbonate cores representing the Waterways Formation: drilling-induced fractures naturally occurring fractures DRILLING-INDUCED FRACTURES Drilling-induced fractures are primarily related to stress-induced failure of the material in the core and to the amount of in-situ stress near the well bore bottom. Conditions that influence the stress field and can create local stress in the core at the well bottom include: torque loading (i.e., from frictional forces of the rotating core barrel) rate of penetration drill string weight drill mud weight Core disk fractures and sub-vertical petal fractures are common features of these local drillinginduced stresses. In carbonate cores collected from the Project area, this type of fracture usually occurs along weak clay partings and has a horizontal orientation along bedding planes within the carbonate strata (core disking). High angle, sub-vertical fractures (petal fractures) are less prevalent and reveal no evidence of movement along the fracture planes (e.g., slickenslides), planar feature October 2014 ESRD/CEAA Page 15

18 ESRD and CEAA Responses Water Frontier Oil Sands Mine Project offsets and mineral precipitation. Because these fracture types are not naturally present in the subsurface, they do not have the capability to transmit groundwater. NATURALLY OCCURRING FRACTURES Naturally occurring fractures in the Waterways Formation are sub-vertical and are often healed by mineral cements such as iron sulphides and carbonate cements. Naturally occurring fractures could provide secondary permeability to the formation; however, in the revised Project area, naturally occurring fractures in the Waterways Formation are cemented by mineral deposition and precipitation processes. Therefore, they do not have the capability to transmit groundwater. This conclusion is supported by the hydrogeologic observations of the monitoring wells 02-23D, 02-35D and 12-12D. As stated in the response to ESRD/CEAA Round 2 SIR 12, all of these wells were dry after completion and could not be developed (as typically would be done in more permeable strata). Subsequent monitoring has detected groundwater accumulations in the wells; however, the rate of equilibrium is very slow, indicating very low hydraulic conductivities. Question 6 Volume 1, ESRD/CEAA SIR 22, Pages 53 and 54 In Response 22a, Teck states that The selection of simulated drawdown contours to zero (or near zero) was considered to be beyond the numerical resolution of the groundwater model, as the simulated (theoretical) zero drawdown contours extend beyond the limits of the available information upon which the model is constructed (e.g., the geological distribution and hydraulic properties of the BWS are not as well constrained as within the aquatics LSA). Teck indicates that this is the reason for selection of minimum simulated drawdown contours of 1 m in the overburden and 10 m in the BWS. However, the stated lack of information for the BWS outside the LSA does not preclude the presentation of simulated contours to a lower level, particularly since the BWS is simulated within the RSA in the model. In SIR 22c, Teck is asked to provide maps showing simulated drawdown in Quaternary and BWS for both the LSA and RSA on the same figure. Teck did not provide the requested maps. In Response 22e, Teck states that Drawdowns of less than 10 m in the BWS from the Project would be expected to have minor to negligible effects to other developments in the groundwater RSA. Although effects are not expected to occur given discontinuities in the spatial distribution of the BWS between the Frontier Project and the larger groundwater RSA, drawdown of 10 m or less would be small compared to the amount of available head typically in the BWS (about 50 m or more). Teck s statement that drawdowns of less than 10 m in the BWS would have negligible impacts is not supported by the available data, since the simulated drawdown in areas outside the LSA is not ESRD/CEAA Page 16 October 2014

19 Frontier Oil Sands Mine Project ESRD and CEAA Responses Water presented. Drawdown of 10 m is approximately 20% of available head of 50 m, and could potentially negatively impact other developments outside the LSA. a. Provide maps showing drawdown contours to 1 m in the BWS. b. Provide maps showing drawdown contours for the Quaternary in the LSA and RSA on the same figure (i.e., combined drawdown in both areas). c. Provide maps showing drawdown contours for the BWS to 1 m in the LSA and RSA on the same figure (i.e., combined drawdown in both areas). d. Based on the simulated combined drawdown in the BWS in the LSA and RSA, discuss potential impacts to other developments. Response 6 a. Maps are provided (see Figures 6a-1 and 6a-2) that show the simulated drawdown contours extended to 1 m in the basal water sands (BWS). Figure 6a-1 compares drawdown in the Application Case and Base Case, and therefore reflects the incremental effects of the revised Project only. In Figure 6a-2, the simulated drawdown contours compare Application Case with predevelopment conditions, and therefore reflect the presence of other existing and approved developments that are incorporated in the Base Case. The Pierre River Mine (PRM) and other likely-to-be-approved developments are not included in the Base Case or Application Case. As noted in the response to ESRD/CEAA Round 1 SIR 67 and ESRD/CEAA Round 2 SIR 22, the simulated 1 m drawdown contour in the BWS (or, more correctly, at the base of the McMurray Formation given the discontinuous nature of the BWS unit) is of low accuracy. This is a function of two factors: The 1 m drawdown is simulated to occur beyond the limits of the revised aquatics LSA, where there is limited information about the presence, absence and continuity of BWS beyond the area mapped beneath the proposed Frontier Project and between the Project and other areas within the groundwater regional study area (RSA) (including those mapped for other developments). Where (and if) the BWS is present beyond the revised aquatics LSA, there is no direct information with which to constrain the hydraulic conductivity of the BWS. The values applied in the model have been inferred from the pumping test within the revised aquatics LSA (in a relatively thick portion of the BWS). October 2014 ESRD/CEAA Page 17

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22 ESRD and CEAA Responses Water Frontier Oil Sands Mine Project b. Figure 6b-1 provides simulated drawdown contours for the Quaternary, showing both the LSA and RSA on the same figure (again, with a minimum contour of 1 m). Figure 6b-1 compares drawdown in the Application Case and Base Case, and therefore reflects the incremental effects of the revised Project only. In Figure 6b-2, the comparison is between Application Case and predevelopment conditions. As such, these drawdown contours reflect the presence of other existing and approved developments that are incorporated in the Base Case. The PRM and other likely-to-be-approved developments are not included in the Base Case or Application Case. c. See the response to part a. Figures 6a-1 and 6a-2 show simulated drawdown contours in the BWS across both the LSA and RSA (i.e., both spatial areas are shown on the same figure). The RSA is essentially represented by the active extent of the MODFLOW groundwater model. d. At Application Case, the extent of drawdown in the BWS resulting from the Frontier Project is expected to occur primarily within (or close to) the LSA. Minor to negligible overlap of simulated drawdown cones is expected with other existing and approved developments in the groundwater RSA. Therefore, potential effects of the Project on other developments are expected to be negligible. ESRD/CEAA Page 20 October 2014

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25 Frontier Oil Sands Mine Project ESRD and CEAA Responses Water 4.3 Surface Water Quality Question 7 Volume 1, ESRD/CEAA SIR 11, Pages 24 to 25 Volume 1, ESRD/CEAA SIR 40, Page 5-10 SIR1 SIR 40b requested that Teck clarify the relationship between Red Clay Creek and the Shell PRM Fish Habitat Compensation Lake (FHCL); the response by Teck is contained in SIR2 response to SIR 11. The Project map and Agreement in Principle between Teck and Shell makes the physical configuration of the FHCL and the creek clear. The optimal management of fish habitat compensation is under discussion and negotiation between Teck and Shell as of October a. Provide a management plan to ensure compliance with Section of the TOR for the Project, which require Teck to Describe proposed mitigation measures to maintain surface water quality during the construction, operation, decommissioning and reclamation stages of the Project. Response 7 a. As discussed in the response to AER Round 3 SIR 1, Teck intends to update the for the Project to: recover additional resource from leases acquired from Shell during the Teck Shell asset exchange optimize the tailings management strategy in consideration of the current state of engineering practice and improved understanding of site-specific conditions reflect additional engineering studies and information obtained from Shell as part of the asset exchange consider input received from regulators and potentially affected Aboriginal communities during the review process A management plan that describes proposed mitigation measures to maintain surface water quality during the construction, operation, decommissioning and reclamation stages of the Project will be part of the Project Update. October 2014 ESRD/CEAA Page 23

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27 Frontier Oil Sands Mine Project ESRD and CEAA Responses Water 4.4 Aquatics Question 8 SIR1, Volume 1, Section 10, SIRs 72 and 73, Pages SIR1, Volume 1, Section 5.5, SIR 111a, Pages to SIR 112, Pages to SIR1, Volume 1, Section 10, SIR 71 b, Page 148 SIR2, Volume 1, Aquatics, SIR 30 Teck was asked to revise the aquatic ecology RSA boundary to better consider the regional mining context in which the Frontier Project has been proposed. Notable gaps in the aquatic ecology assessment information remain. a. Provide a comprehensive revision of the aquatic ecology assessment to include habitat, abundance, relative abundance, and diversity, supported by field data, analysis of baseline data, modeling and peer reviewed literature. Ensure uncertainty is addressed throughout the assessment and that appropriate connections are made to conclusions from other relevant or contributing disciplines. Teck states that the RSA used in the fish and fish habitat assessment is considered appropriate to evaluate the potential effects of the Frontier Project on aquatic resources, including the assessment of cumulative effects of the Project in combination with other operating, approved and planned developments. Together, the revised aquatics LSA and RSA encompass the relevant portion of the MOSA, including the drainage boundaries of watersheds in the Project area and an appropriate portion of the Athabasca River adjacent to and downstream of the revised LSA. Teck does not describe how this conclusion was rendered, what biological criteria and local and regional species presence and use were considered, and how peer-reviewed literature on aquatic ecological effects associated with development informed the spatial scope of the RSA chosen. For example, Teck does not appear to have considered that fish populations in the mineable oil sands access both the Athabasca River and its tributary habitats to meet their life history requirements. Development in the broader mineable oil sands area is influencing and will continue to influence aquatic habitat in many of the Athabasca River tributary watersheds. The Terms of Reference, Section [D] states: provide the scientific rationale used to define the spatial and temporal aspects, considering the location and range of probable Project and cumulative effects; b. Provide: i. A description of the biological connections and ecological interactions considered in determining RSA boundaries. October 2014 ESRD/CEAA Page 25

28 ESRD and CEAA Responses Water Frontier Oil Sands Mine Project ii. Discussion of and reference to scientific literature to explain the biological connections considered (or not considered) in defining the RSA boundaries. iii. Acknowledgement and consideration that fish are mobile and will access other Athabasca River tributaries, and a discussion of how this is accounted for in the RSA delineation. iv. Consideration that other development is underway or proposed in regional Athabasca River tributary watersheds and a discussion of how this was accounted for in the RSA delineation. v. A description of how the RSA is aligned with the biological criteria and how potential ecological interactions were considered. vi. A description of any potential biological or aquatic ecological connections that were not considered and a rationale for why they were excluded from the RSA delineation. vii. An updated RSA and aquatic ecology assessment, as appropriate. The broader mineable oil sands area will experience substantial land use change as current and proposed mining. Watershed scale investigations of less intensive land use change such as forestry and fire suggest aquatic ecological effects associated with these activities/events are complex and persist for years. The Frontier Project may influence substantial portions of several watersheds. c. Provide a comparison of watershed scale findings in response to land use change, how land use change responses were considered and how they are or are not relevant to the mine. d. Provide a discussion of whether the land use change associated with the mine might result in greater or lesser aquatic ecological change than what is reported in the literature and explain how Teck has come to their conclusions. e. Describe whether and how the land use changes in the broader mineable oil sands area and their potential influence on aquatic ecology will act in concert with expected land use change associated with the Frontier Project. Response 8 a. A revision of the aquatic ecology assessment is not necessary. The assessment, in combination with the information provided in response to supplemental information requests (SIRs) (Rounds 1 to 3), provides a comprehensive assessment of potential impacts to fish habitat, fish abundance, and fish and fish habitat diversity, including potential effects on benthic invertebrate communities. The response to ESRD/CEAA Round 3 SIR 42a summarizes the assessment, including: the effects pathways assessed linkage validation results integration of hydrology and water quality modelling results conclusions and confidence levels fish and fish habitat assessment conclusions ESRD/CEAA Page 26 October 2014

29 Frontier Oil Sands Mine Project ESRD and CEAA Responses Water relevant mitigation measures assessment confidence levels, uncertainties and knowledge gaps The assessment is complete and meets the terms of reference for the Frontier Project aquatic ecology assessment issued by Alberta Environment (AENV 2009; Section 3.6) as well as the requirements outlined by the Government of Alberta in the environmental impact assessment (EIA) preparation guidelines available at the time the assessment was completed (Alberta Government 2011). The fish and fish habitat assessment was revised in 2013 because of changes to the Project resulting from the Teck Shell asset exchange (see the response to ESRD/CEAA Round 2 SIR 30, Appendix 30a.1). Teck will consider updating the assessment in 2015 to reflect planned changes to the Project (for details, see the response to AER Round 3 SIR 1). Any update that is completed will follow the same assessment methods used previously. These methods align with the terms of reference for the Project as well as current requirements as outlined in the EIA preparation guide (Alberta Government 2013). b. i. As specified in the terms of reference for the Frontier Project (AENV 2009), the aquatics RSA delineated the area where an effect can be reasonably expected and in which there is the potential for cumulative effects. The scientific rationale is based on the location and range of probable Project and cumulative effects. The aquatics RSA for the Frontier Project also includes the area within which aquatic ecological interactions are expected to occur that might experience cumulative effects. A variety of biological connections and ecological interactions were considered in determining the RSA boundaries, including: changes in streamflows changes in water quality changes in aquatic health direct Project effects on aquatic habitat (i.e., diversions and landscape changes) effects on primary production (i.e., algae production and detrital inputs) effects on secondary production (i.e., benthic invertebrate communities and drift) effects on fish populations (i.e., species composition, distribution, life stage requirements, sensitivity and behavioural responses) These changes apply to all the local watercourses and waterbodies where there is a reasonable potential for immediate environmental impacts from Project activities, and downstream habitats in the Athabasca River. October 2014 ESRD/CEAA Page 27

30 ESRD and CEAA Responses Water Frontier Oil Sands Mine Project The aquatics RSA includes the areas where effects can reasonably be expected, including the local watersheds and the Athabasca River adjacent to these watersheds. The biological connection and potential interactions with developments in other Athabasca River tributary watersheds were considered based on: the potential for these developments to affect the productivity of the Athabasca River; for example, through ecological interactions for productivity (i.e., detrital inputs, benthic invertebrate drift) use of these watersheds by the same fish populations that use watersheds in the aquatics LSA. Fish populations and their potential use of watersheds in the aquatics LSA were determined based on the assessment predictions for the other oil sands mining developments (see the response to ESRD/CEAA Round 3 SIR 9a). Because no residual effects were predicted for fish populations in other tributary watersheds, the location and range of probable cumulative effects with the Frontier Project are limited to the portion of the Athabasca River that overlaps the aquatics RSA. The need to consider the regional context and the full influence of oil sands development on fisheries and aquatic ecosystems in the lower Athabasca River watershed was recognized in the Joint Review Panel report for the Shell Jackpine Mine Expansion. As described in response to ESRD/CEAA Round 2 SIR 30b, the Joint Review Panel report concluded that: a cumulative effects assessment for fish habitat in the lower Athabasca River watershed should not be the responsibility of a single proponent The Joint Review Panel noted Alberta and Canada have established the Joint Canada-Alberta Implementation Plan for Oil Sands Monitoring (JOSMP) to monitor the oil sands and ensure environmentally responsible development of the oil sands resource, and this initiative will help promote a better understanding of cumulative effects in the Lower Athabasca region. Teck agrees with the findings of the Joint Review Panel and supports the JOSMP. Teck will continue to support collaborative initiatives to assess cumulative effects for fish habitat in the lower Athabasca watershed. ii. Various biological connections were considered in defining the boundaries of the aquatics RSA, including: connections related to primary productivity These connections were considered based on information about the nature of primary production and detrital inputs (Odum 1956; Wallace et al. 1995; Webster et al. 1999; Abelho 2001) and possible effects of changes in land use or water temperature (Kevern and Ball 1965: Murphy and Hall 1981; Webster and Waide 1982; Webster et al. 1990; Garmin and Moring 1991; Heede 1991; Carignan et al. 2000). connections related to benthic invertebrate communities and downstream drift These connections were considered based on the importance of benthic invertebrate communities in fish habitat productivity (Rosenberg and Resh 1993) and the potential for invertebrate drift to ESRD/CEAA Page 28 October 2014

31 Frontier Oil Sands Mine Project ESRD and CEAA Responses Water supplement productivity in downstream habitats (Siler et al. 2001; Svendson et al. 2004; Wipfli and Musselwhite 2004). connections to fish populations These connections were considered based on the specific life stage requirements, sensitivity and behavioural responses of fish species in the aquatics LSA (Bond and Machniak 1979; Detenback et al. 1992; Hamel et al. 1997; Paragamian and Wakkinen 2008). iii. As described in response to ESRD/CEAA Round 2 SIR 52: Large-bodied fish species are present in the lower portions of Redclay Creek and Big Creek, and these species are likely part of migratory populations from the Athabasca River that use tributary habitats on a seasonal basis... Historical fish tagging studies (Machniak et al. 1980; Machniak and Bond 1979; Bond and Machniak 1979) have shown that some largebodied species from the Athabasca River demonstrate a homing tendency, using the same tributary watercourse in more than one year; however, these same species (as well as other large-bodied species) use more than one tributary watercourse from year to year. Therefore, migratory large-bodied species that use the limited portion of the revised aquatics LSA described above would also be expected to use other Athabasca River tributaries in the region to some extent. This biological connection was considered in delineating the aquatics RSA (as described in the response to part b-i) and makes it possible that cumulative effects could occur for the Frontier Project and other developments because of effects in other Athabasca River tributary watersheds. However, there are no residual effects predictions for migratory large-bodied fish populations for any of these developments (see the response to ESRD/CEAA Round 3 SIR 9a). Therefore, cumulative effects via this biological connection are not probable, and as a result, these watersheds were not included in the Frontier Project aquatics RSA. iv. Other oil sands developments are underway in tributary watersheds of the lower Athabasca River that are outside the aquatics RSA. Residual effects predictions for these developments were included in the assessment of potential cumulative effects for the Frontier Project on the Athabasca River. v. A description of how the aquatics RSA is aligned with biological connections and ecological interactions is described in the response to part b-i to b-iv. vi. There were no potential biological or ecological connections that were not considered in the delineating the aquatics RSA. Some connections were not considered valid with respect to the aquatics RSA delineation given the lack of residual effects predictions and lack of probable cumulative effects. vii. An update to the aquatics RSA and aquatic ecology assessment is not appropriate for the reasons provided in the response to part a. Teck will consider updating the assessment in 2015 to reflect planned changes to the Project (for details, see the response to AER Round 3 SIR 1). October 2014 ESRD/CEAA Page 29

32 ESRD and CEAA Responses Water Frontier Oil Sands Mine Project c. Land use changes can result in changes to riparian vegetation, which in turn can affect detrital inputs by reducing the amount of detritus entering systems (Webster et al. 1994). Land use changes associated with forestry can alter breakdown rates of detritus (Webster and Waide 1982; Benfield et al. 1991) and increase export of materials from streams (Webster et al. 1990). For example, logged systems tend to have higher flow rates (Heede 1991) and temperature (Garmin and Moring 1991), as well as altered nutrient levels (Carignan et al. 2000), sedimentation rates (Garmin and Moring 1991) and level of primary production (Murphy and Hall 1981). Effects of land use changes associated with oil sand mining on the amounts of detritus entering systems have not been addressed in the literature. Oil sands mining is known to reduce stream drainage areas as new areas are used for mining. This change could result in reduced output of detritus to receiving waters. However, because depositional streams, which represent the dominant stream habitat type in the oil sands region, tend to accumulate large amounts of detritus in bottom sediments, removing portions of stream drainage areas might not have measurable effects on the delivery of detritus to the Athabasca River. Potential responses to land use changes were considered in the fish and fish habitat assessment in terms of potential changes in detrital inputs (see the responses to ESRD/CEAA Round 3 SIRs 25, 26 and 34a). d. The effects of land use changes associated with oil sands mining on aquatic ecology have not been extensively discussed in the literature and are expected to be different from those of forestry. Therefore, predictions of aquatic ecological effects of the Project were based, in part, on predicted changes in aquatic environments by other aquatic components (i.e., water quality, hydrology), and the expected responses of aquatic communities to those changes based on habitat associations of aquatic organisms. In evaluating potential changes in detrital inputs, Project effects were assessed based on: the nature of detrital inputs provided in the literature the specific characteristics of the landscape changes associated with the Project the physical characteristics of the affected watercourses For details, see the responses to ESRD/CEAA Round 3 SIRs 25, 26 and 34a. e. Land use changes in the broader Mineable Oil Sands Area (MOSA) are expected to consist largely of: removal of portions of drainage areas during mining altered drainage of remaining watercourses because of diversions additional road construction Following reclamation, the landscape within the areas of former oil sands developments will be altered to reflect reclamation activities. The cumulative effects of these activities on aquatic ecology in combination with the Frontier Project were assessed for the aquatics RSA. ESRD/CEAA Page 30 October 2014

33 Frontier Oil Sands Mine Project ESRD and CEAA Responses Water REFERENCES Abelho, M From litterfall to breakdown in streams: a review. The Scientific World Journal 1: AENV (Alberta Environment) Final Terms of Reference Environmental Impact Assessment Report for the Proposed UTS Energy Corporation/Teck Cominco Limited Frontier Oil Sands Mine Project. Issued by Alberta Environment. February Alberta Government Environmental Assessment Program: Guide to Preparing Environmental Impact Assessment Reports in Alberta. Government of Alberta. Updated February Alberta Government Environmental Assessment Program: Guide to Preparing Environmental Impact Assessment Reports in Alberta. Government of Alberta, Edmonton, Alberta. Updated March Benfield, E.F., J.R. Webster, S.W. Golladay, G.T. Peters and B.M. Stout Effects of forest disturbance on leaf breakdown in southern Appalachian streams. Verhandlungen der Internationalen Vereinigung für theoretische und angewandte Limnologie. 24: Bond, W.A. and K. Machniak An Intensive Study of the Fish Fauna of the Muskeg River Watershed of Northeastern Alberta. Prepared for Alberta Oil Sands Environmental Research Program by Environment Canada, Freshwater Institute. AOSERP Report 76. Carignan, R., P. D Arcy and S. Lamontagne Comparative impacts of fire and forest harvesting on water quality in Boreal Shield lakes. Canadian Journal of Fisheries and Aquatic Sciences 57: Detenbeck, N.E., P.W. DeVore, G.J. Niemi and A. Lima Recovery of temperate-stream fish communities from disturbance: a review of case studies and synthesis of theory. Environmental Management 16: Garmin, G.C. and J.R. Moring Initial effects of deforestation on physical characteristics of a boreal river. Hydrobiologia 209: Hamel, P., P. Magnan, M. Lapointe and P. East Timing of spawning and assessment of a degreeday model to predict the in situ embryonic developmental rate of white sucker, Catostomus commersoni. Canadian Journal of Fisheries and Aquatic Sciences 54: Heede, B.H Response of a stream in disequilibrium to timber harvest. Environmental Management 15: Kevern, N.R. and R.C. Ball Primary productivity and energy relationships in artificial streams. Limnology and Oceanography 10: October 2014 ESRD/CEAA Page 31

34 ESRD and CEAA Responses Water Frontier Oil Sands Mine Project Machniak K. and W.A. Bond An Intensive Study of the Fish Fauna of the Steepbank River Watershed of Northeastern Alberta. Alberta Oil Sands Environmental Research Program Technical Report. Alberta Environment, Environment Canada and Fisheries and Oceans Canada, Freshwater Institute. AOSERP Report 61. Edmonton, Alberta. Machniak, K., W.A. Bond, M.R. Orr, D. Rudy and D. Miller Fisheries and Aquatic Habitat Investigations in the MacKay River Watershed of Northeastern Alberta. Alberta Oil Sands Environmental Research Program Technical Report. Alberta Environment, Environment Canada and Fisheries and Oceans Canada, Freshwater Institute. AOSERP Report 93. Edmonton, Alberta. Murphy, M.L. and J.D. Hall Varied effects of clear-cut logging on predators and their habitat in small streams of the Cascade Mountains, Oregon. Canadian Journal of Fisheries and Aquatic Sciences 38: Odum, H.T Primary production in flowing waters. Limnology and Oceanography 1: Paragamian, V.L. and V.D. Wakkinen Seasonal Movement of Burbot in Relation to Temperature and Discharge in the Kootenai River, Idaho, USA and British Columbia, Canada. In American Fisheries Society Symposium, American Fisheries Society. Rosenberg, D.M and V.H. Resh Freshwater Biomonitoring and Benthic Macroinvertebrates. Chapman and Hall, New York. Siler, E.R., J.B. Wallace and S.L. Eggert Long-term effects of resource limitation on stream invertebrate drift. Canadian Journal of Fisheries and Aquatic Sciences 58: Svendson, C.R., T. Quinn and D. Kolbe Review of Macroinvertebrate Drift in Lotic Ecosystems. Washington Department of Fish and Wildlife, Wildlife Research Program. Olympia, Washington. October Wallace, J.B., M.R. Whiles, S. Eggert, T.F. Cuffney, G.H. Lughart and K. Chung Long-term dynamics of coarse particulate organic matter in three Appalachian mountain streams. Journal of the North American Benthological Society 14: Webster, J.R. and J.B. Waide Effects of forest clearcutting on leaf breakdown in a southern Appalachian stream. Freshwater Biology 12: Webster, J.R., S.W. Golladay, E.F. Benfield, D.J. D Angelo and G.T. Peters Effects of forest disturbance on particulate organic matter budgets of small streams. Journal of the North American Benthological Society 9: Webster, J.R., A.P. Covich, J.L. Tank and T.V. Crockett Retention of coarse organic particles in streams in the southern Appalachian Mountains. Journal of the North American Benthological Society 13: Webster, J.R., E.F. Benfield, T.P. Ehrman, M.A. Schaeffer, J.L. Tank, J.J. Hutchens and D.J. D Angelo What happens to allochthonous material that falls into streams? A synthesis of new and published information from Coweeta. Freshwater Biology 41: ESRD/CEAA Page 32 October 2014

35 Frontier Oil Sands Mine Project ESRD and CEAA Responses Water Wipfli, M.S. and J. Musselwhite Density of red alder (Alnus rubra) in headwaters influences invertebrate and detritus subsidies to downstream fish habitats in Alaska. Hydrobiologia 520: Question 9 SIR1, Volume 1, Section 10, SIRs 72 and 73, Pages SIR1, Volume 1, Section 5.5, SIR 111a, Pages to SIR 112, Pages to SIR1, Volume 1, Section 10, SIR 71 b, Page 148 SIR2, Volume 1, Aquatics, SIR 30 Teck is proposing an oil sands mine in the context of other oil sands mines. The Terms of Reference acknowledge this and direct Teck to discuss sources of information used, including, literature and previous EIA reports and environmental studies; operating experience from current, similar operations; industry study groups; traditional knowledge; and government sources. a. Compare Teck s predictions to EIA predictions associated with other, similar, mine Projects in operation. b. Assess and present publicly available data from monitoring programs and data collected for operating Projects to support/confirm Teck s effects predictions. For areas where monitoring indicates effects were substantially under or over-predicted, describe how this has been considered in Teck s effects predictions. Provide the biological rationale for the under/overprediction, or a considered and robust discussion of the uncertainty associated with the outcome presented. Teck does not appear to have considered historical and current fisheries data. Fish fences were operated in the Steepbank and Muskeg Rivers in the 1970 s (Bond). Fish fence data for the Muskeg and Steepbank Rivers, when compared with current monitoring data, suggest that fish have declined substantially in these watersheds. Despite different recent data collection methods for the Steepbank River and the resultant issue with comparability, the magnitude of the observed declines suggest similar declines are present to those observed in the Muskeg River. The declines appear for all species, not just those susceptible to domestic and recreational users. c. Update the assessment predictions to consider the effects observed in the Muskeg and Steepbank Rivers or present additional information to characterize what is different about the Frontier Project; explain why these data should not be considered in Frontier effects predictions. October 2014 ESRD/CEAA Page 33

36 ESRD and CEAA Responses Water Frontier Oil Sands Mine Project Response 9 a. Results of the fish and fish habitat assessment conducted for the Project are compared to the predictions made in assessments completed for other similar oil sands mines in operation (see Table 9a-1). However, directly comparing assessment predictions between developments even similar developments in the same region is problematic because of differences in development plans, which may be significant, and differences in the specific aquatic resources that occur in the development area. Given the time span encompassed by the developments listed in Table 9a-1, there are also important differences in assessment methodology, including differences in pathway or linkage definitions, key indicators (biotic and abiotic), measurement endpoints, assessment and classification criteria, and the modelling methodologies used by other disciplines that support the fish and fish habitat assessment (i.e., water quality and aquatic health). The fish and fish habitat assessment conducted for the Frontier Project was both project-specific and site-specific. As a result, the associated predictions were appropriate and specific to the Project. For example, one unique aspect of the Frontier Project is its location on the fluvial fan emanating from the Birch Mountains. This setting is different than the larger oil sands region and results in there being limited fish habitat because of high sediment loads, poorly defined watercourse channels and lack of connectivity to downstream fishbearing habitats. In spite of the preceding and to comply with the information request, a general comparison was conducted of the information available for oil sands mine assessments (see Table 9a-1) to identify major similarities and differences in the assessment results. Many of the oil sands assessment predictions for fish and fish habitat showed the following similarities: Negligible or no effects because of changes in sedimentation (i.e., suspended sediment and sediment deposition) due to project mitigation measures. Negligible or no effects because of changes in fishing pressure or fish harvest. Negligible or no effects because of changes in sediment quality or water quality, including key biological parameters (e.g., temperature and dissolved oxygen) as well as contaminants. Negligible or no overall effects on fish habitat productivity, fish abundance and fish and fish habitat diversity because fish habitat compensation or enhancement measures were incorporated into the project design. Compensation habitats are typically provided to compensate for potential effects on fish and fish habitat because of changes in habitat area, habitat accessibility, stream flows or water levels. Negligible or no effects to benthic invertebrate communities, diversity or drift because of changes in habitat area or stream flows. For some developments, this prediction depends on mitigation by habitat compensation measures. Negligible effect on the Athabasca River because of changes in flows associated with water withdrawals with implementation of the Phase 1Athabasca River Water Management Framework and proper intake screening. ESRD/CEAA Page 34 October 2014

37 Frontier Oil Sands Mine Project ESRD and CEAA Responses Water End pit lakes are predicted to develop habitats suitable to support aquatic life with water quality conditions below threshold effects criteria for aquatic health or similar to local baseline conditions. Assessment predictions for the Frontier Project align with these key similarities. The one exception is that effects on fish habitat productivity for the Frontier Project were not assessed as negligible, but were classified as having a low-level effect on fish habitat with a low environmental consequence because the Project will result in loss of fish habitat that will require the development of new habitats to compensate for the loss (see Volume 5, Section 5.5.7, Pages 5-34 to 5-35). Similar to the assessments conducted for other oil sands mines, the fish and fish habitat assessment for the Frontier Project identifies fish habitat compensation measures that are expected to fully mitigate potential effects on fish habitat productivity, fish abundance, and fish and fish habitat diversity. Although a portion of the habitat compensation for the Frontier Project includes replacing some affected watercourse habitats with waterbody habitats, productive capacity will be maintained. This habitat change will be redressed during future reclamation of the watercourses that will form the closure drainage system. Key differences in EIA predictions for fish and fish habitat were noted for specific oil sands mine developments (see Table 9a-1). For example: Reduced benthic invertebrate diversity was predicted for the Kearl project and the Horizon project because of the replacement of significant amounts of watercourse habitats with compensation waterbody habitats. Changes in fish habitat were predicted for the Kearl project because of increased flows that have the potential for increased suspended sediment levels and changes in channel regime. Potential changes in water quality that could result in changes in aquatic health and fish tissue concentrations were identified for the Aurora project, Steepbank Mine project and Millennium project. Potential changes in thermal regime and concerns with end pit lake water quality were identified for the Millennium project. Although these predictions may be appropriate for the specific development(s) they are associated with, they are not relevant to the Frontier Project. The Frontier Project is similar in some ways to the Kearl and Horizon projects in that some watercourse habitats will be replaced with compensation waterbody habitats, but the extent to which this will occur is quite different. Most habitat losses for the Kearl and Horizon projects are watercourses, and most or all of their compensation habitats are waterbodies. In contrast, most habitat losses for the Frontier Project are waterbody habitats (primarily Unnamed Lake 1) that will be replaced with compensation waterbody habitats. This is one of the reasons that the predicted effects of the Project on benthic invertebrate diversity were assessed as negligible. October 2014 ESRD/CEAA Page 35

38 ESRD and CEAA Responses Water Frontier Oil Sands Mine Project Table 9a-1 Comparison of EIA Predictions for Fish and Fish Habitat for Operating Oil Sands Mine Projects Project (Application Year) Aquatic Endpoints Linkage or Effects Pathway (Changes In) Validity Mitigation or Compensation Predictions Residual Effects Environmental Consequence Teck Frontier (2011) Fish habitat Fish abundance Fish and fish habit diversity Habitat area Valid Best management practices to minimize sedimentation and seepage, and effects on water quality during project development, operation and closure Surface water flow and water levels Valid Development of compensation habitat in the fish habitat compensation lake Loss of habitats and productivity associated with watercourse diversions are mitigated with compensation habitat. Compensation habitats are expected to mitigate potential effects on habitat productivity, fish abundance and fish and fish habitat diversity. Flow changes in watercourses downstream of the Project area with potential effects on habitat productivity are mitigated by compensation habitat. Athabasca River water withdrawals are expected to have a negligible effect on habitat with implementation of the Water Management Framework and proper intake screening. Compensation habitats are expected to fully mitigate effects on fish and fish habitat, but there will be some change in habitat types present on the landscape until the closure drainage watercourses mature Low Channel regime Invalid No assessment required Sediment load Valid Sediment loading to one waterbody that was assessed as having the potential to affect habitat productivity is mitigated by compensation habitat to prevent reduction in productive capacity and fish productivity. Water and sediment quality Invalid No assessment required Temperature regime Invalid No assessment required ESRD/CEAA Page 36 October 2014

39 Frontier Oil Sands Mine Project ESRD and CEAA Responses Water Table 9a-1 Comparison of EIA Predictions for Fish and Fish Habitat for Operating Oil Sands Mine Projects (cont d) Project (Application Year) Aquatic Endpoints Linkage or Effects Pathway (Changes In) Validity Mitigation or Compensation Predictions Residual Effects Environmental Consequence Teck Frontier (2011) (cont d) Dissolved oxygen (DO) levels Invalid No assessment required Habitat accessibility Invalid No assessment required Benthic invertebrate communities Valid Potential effects on benthic invertebrate communities are mitigated with compensation habitats and development of watercourses in the closure drainage system. Suncor Voyageur, North Steepbank Mine (2005a) Fish habitat Aquatic health Fish tissue quality Fish abundance Aquatic biodiversity Fish tainting Surface water flow Valid Flow attenuation Compensation habitat provided in compensation pond and habitat enhancements in the Steepbank River Small to negligible changes with localized effects on flood flow velocities at Steepbank River crossing structure Decrease in 10-year flood peak discharge in lower Unnamed Creek is mitigated by compensation habitat. Habitat area Valid Loss of habitats in upper Best management practices to Unnamed Creek are mitigated by habitat compensation pond. Channel Valid minimize Negligible changes with geomorphology sedimentation and relatively unchanged flood flows seepage, and effects Increase in fish habitat in new on water quality diversion channel and during project compensation pond. development, Water levels Valid operation and closure Negligible changes with localized effects on flood flow levels at Steepbank River crossing structure. Change in water quality metal concentrations and accumulation in fish Low October 2014 ESRD/CEAA Page 37

40 ESRD and CEAA Responses Water Frontier Oil Sands Mine Project Table 9a-1 Comparison of EIA Predictions for Fish and Fish Habitat for Operating Oil Sands Mine Projects (cont d) Project (Application Year) Aquatic Endpoints Linkage or Effects Pathway (Changes In) Validity Mitigation or Compensation Predictions Residual Effects Environmental Consequence Suncor Voyageur, North Steepbank Mine (2005a) (cont d) Water quality Valid Changes to water quality expected with minor effects on aquatic health. Dissolved oxygen levels Invalid No assessment required Thermal regime Invalid No assessment required Sediment load Valid Increased sediment load, but concentrations are expected to be below levels of ecological significance. Sediment quality Valid No changes expected Suncor Voyageur, Voyageur Upgrader (2005b) Fish habitat Aquatic health Fish tissue quality Fish abundance Aquatic biodiversity Fish tainting Surface water flow Valid Best management Channel Valid practices to geomorphology minimize sedimentation and Water levels Valid seepage, and effects Overall water Invalid on water quality quality during project development, Dissolved oxygen Invalid operation and levels closure Negligible changes with no measurable effect on aquatic health or fish habitat, abundance or diversity. No assessment required No assessment required Thermal regime Invalid No assessment required None No rating provided Sediment load Valid Negligible changes with no measurable effect on aquatic health or fish habitat, abundance or diversity. Sediment quality Invalid No assessment required ESRD/CEAA Page 38 October 2014

41 Frontier Oil Sands Mine Project ESRD and CEAA Responses Water Table 9a-1 Comparison of EIA Predictions for Fish and Fish Habitat for Operating Oil Sands Mine Projects (cont d) Project (Application Year) Aquatic Endpoints Linkage or Effects Pathway (Changes In) Validity Mitigation or Compensation Predictions Residual Effects Environmental Consequence Imperial Oil Kearl (2005) Aquatic health Fish abundance Fish and fish habitat diversity Fish health Surface water quality Types of aquatic habitats in the reclamation watercourses and waterbodies Basin sediment yield and sediment concentrations Surface water flows and levels Surface water channel regime and erosion Surface water quality Thermal regime in surface waters Valid Valid Valid Valid Valid Best management practices to minimize sedimentation and seepage, and effects on water quality during project development, operation and closure Compensation habitat provided in a compensation lake connected to Kearl Lake Flow augmentation to maintain naturalized flows and associated habitat area in some watercourse segments Diversion channels and drainage systems that provide aquatic habitat Small to negligible transport of sediments into watercourses and waterbodies. Decrease in surface water flows and levels of watercourses with habitat loss mitigated by compensation lake. Athabasca River water withdrawals are expected to have a negligible effect on habitat with implementation of the Water Management Framework and proper intake screening. Small to negligible changes in erosion (total suspended solids [TSS]) and channel regime with increased discharge flows in some watercourses. Negligible to small change in substance concentrations and TSS in waterbodies and watercourses. Water in pit lakes is expected to have lower acute and chronic toxicity and tainting potential than threshold levels. Small temperature changes in receiving waters, which will quickly attain thermal equilibrium. Change to benthic invertebrate diversity Changes in fish habitat conditions in the far future because of reductions in flows during the open-water period Changes in fish habitat conditions from changes in channel regime and TSS due to increased flows Low Dissolved oxygen levels in surface waters Valid Negligible decreases in DO. Oxygen-consuming organic materials will be mitigated by elimination in polishing ponds. October 2014 ESRD/CEAA Page 39

42 ESRD and CEAA Responses Water Frontier Oil Sands Mine Project Table 9a-1 Comparison of EIA Predictions for Fish and Fish Habitat for Operating Oil Sands Mine Projects (cont d) Project (Application Year) Aquatic Endpoints Linkage or Effects Pathway (Changes In) Validity Mitigation or Compensation Predictions Residual Effects Environmental Consequence Imperial Oil Kearl (2005) (cont d) Sediment quality Valid Negligible changes in polycyclic aromatic hydrocarbons (PAHs) and metal concentrations in bottom sediments of receiving waters. Change in fishing pressure Valid Minimal potential for increased fishing pressure with limited access and angler management by ESRD. Accessibility to fish Valid Short-term loss of access to habitat because of project diversions, with limited localized effect on fish populations. No predicted adverse effects on fish habitat resulting from changes in accessibility with mitigation and habitat compensation. Watercourse or waterbody habitat areas Valid No net habitat loss with compensation habitat. Acidification of lakes and streams Valid Negligible effects on lake and stream acidification in the oil sands region. Fish food base Valid No predicted adverse effects on fish habitat because of changes in benthic invertebrate communities or drift resulting from changes in flow, temperature regime and habitat loss. Fish entrainment or impingement Valid No effects on fish abundance resulting from fish entrainment or impingement at intake structure with mitigation (i.e., fish screens). ESRD/CEAA Page 40 October 2014

43 Frontier Oil Sands Mine Project ESRD and CEAA Responses Water Table 9a-1 Comparison of EIA Predictions for Fish and Fish Habitat for Operating Oil Sands Mine Projects (cont d) Project (Application Year) Aquatic Endpoints Linkage or Effects Pathway (Changes In) Validity Mitigation or Compensation Predictions Residual Effects Environmental Consequence Albian Sands Muskeg River Mine Expansion (2005) Aquatic health, fish and fish habitat Habitat area Valid Habitat enhancement of watercourses and a waterbody Streamflows and water levels Valid Use of clear-span bridges Negligible effect of changes in habitat area on fish habitat, fish abundance, benthic invertebrate communities or drift with habitat enhancement compensation. Negligible effect of changes in streamflows and water levels on fish habitat with mitigation and habitat enhancement compensation. Low-magnitude changes in water quality (strontium) and tissue quality (selenium) on aquatic health in Isadore s Lake Low Access or passage for fish Invalid No assessment required Water quality Valid Negligible effects of changes to concentrations of iron, manganese and strontium in Jackpine Creek on aquatic health, except for low-magnitude effects in Isadore s Lake. Fishing pressure Invalid No assessment required Sediment quality Invalid No assessment required Tissue concentrations Valid Potential low-magnitude effects of selenium levels in Isadore s Lake. Acidifying emissions Invalid No assessment required Channel regime or geomorphic condition Invalid No assessment required Sediment deposition Invalid No assessment required October 2014 ESRD/CEAA Page 41

44 ESRD and CEAA Responses Water Frontier Oil Sands Mine Project Table 9a-1 Comparison of EIA Predictions for Fish and Fish Habitat for Operating Oil Sands Mine Projects (cont d) Project (Application Year) Aquatic Endpoints Linkage or Effects Pathway (Changes In) Validity Mitigation or Compensation Predictions Residual Effects Environmental Consequence Canadian Natural Resources Ltd. Horizon (2002) Fish habitat Fish health Fish tissue chemical concentration s/tainting Fish abundance Fishing pressure Valid Compensation lake and associated reconstructed channels providing aquatic habitat Negligible effects on fish abundance with reduced fishing pressure on Athabasca River. Alternate fishing opportunities provided by compensation habitats. Impacts of acidifying emissions on fish health Entrainment of fish at water intake Invalid Best management practices to No assessment required Change in benthic minimize Accessibility to fish Valid Loss of access to watercourses invertebrate sedimentation and diversity and waterbodies mitigated by seepage, and effects compensation habitats. on water quality, Watercourse or waterbody areas Valid during project construction, Negligible; mitigated by compensation habitats. Dissolved oxygen Valid operation and No difference in DO in receiving closure waters from baseline conditions. Possible increases DO in some waters. Low (in watercourses) Undetermined (in waterbodies) Moderate Channel regime or geomorphic condition Valid Changes resulting from diversion waters into watercourses and waterbodies, but effects on fish abundance and habitat are mitigated by compensation habitat. ESRD/CEAA Page 42 October 2014

45 Frontier Oil Sands Mine Project ESRD and CEAA Responses Water Table 9a-1 Comparison of EIA Predictions for Fish and Fish Habitat for Operating Oil Sands Mine Projects (cont d) Project (Application Year) Aquatic Endpoints Linkage or Effects Pathway (Changes In) Validity Mitigation or Compensation Predictions Residual Effects Environmental Consequence Canadian Natural Resources Ltd. Horizon (2002) (cont d) Streamflow and water levels Valid Minor flow reductions and water level changes with minor potential for effects on fish habitat. Potential effects are mitigated by compensation habitat. Athabasca River water withdrawals are expected to have a negligible effect on habitat with implementation of the Water Management Framework and proper intake screening. Sediment loading Valid With mitigation, sediment loading is not expected to increase because of project construction or operation. Thermal regime Valid Temperature changes are not expected to alter watercourse thermal regimes or affect productivity. Water quality Valid Negligible effects of changes in water quality in watercourses resulting from muskeg and overburden water. Potential effects on fish health are expected because of sulphide from acidifying emissions. October 2014 ESRD/CEAA Page 43

46 ESRD and CEAA Responses Water Frontier Oil Sands Mine Project Table 9a-1 Comparison of EIA Predictions for Fish and Fish Habitat for Operating Oil Sands Mine Projects (cont d) Project (Application Year) Aquatic Endpoints Linkage or Effects Pathway (Changes In) Validity Mitigation or Compensation Predictions Residual Effects Environmental Consequence Canadian Natural Resources Ltd. Horizon (2002) (cont d) Benthic invertebrate community and drift Valid Minor loss of drift in watercourses with no effects on fish habitat or abundance. Lowlevel reduction in benthic invertebrate diversity with replacement of riverine habitats with waterbody and channel habitats. Negligible changes in biodiversity in waterbodies. Sediment quality Valid Negligible effects of minor changes in sediment quality on fish tissue concentrations and fish health. Shell Jackpine Mine, Phase 1 (2002) Fish habitat Fish abundance Fish and fish habitat biodiversity Fish health Fish tissue quality Access Valid Naturalized diversion channels and compensation lake to provide fish habitat Watercourse or waterbody areas Valid Best management practices to minimize sedimentation and seepage, and effects on water quality during project construction, operation and closure Negligible effects of loss of access to habitat on fish habitat and abundance with mitigation measures and compensation habitat. Fish habitat loss from lost stream segments negligible with habitat compensation. Dissolved oxygen Valid Negligible effects on DO levels in receiving waterbodies. Streamflow and Valid Effects on fish habitat from water levels localized changes in streamflow are expected to be negligible with habitat compensation. Changes in lake water levels with project-related fluctuations are negligible and within the Fish ladder to range of natural variability. maintain passage in Sediment loading Valid redesigned channel Negligible effects on sediment loading. None No rating required ESRD/CEAA Page 44 October 2014

47 Frontier Oil Sands Mine Project ESRD and CEAA Responses Water Table 9a-1 Comparison of EIA Predictions for Fish and Fish Habitat for Operating Oil Sands Mine Projects (cont d) Project (Application Year) Aquatic Endpoints Linkage or Effects Pathway (Changes In) Validity Mitigation or Compensation Predictions Residual Effects Environmental Consequence Shell Jackpine Mine, Phase 1 (2002) (cont d) Benthic community Valid Negligible effects on benthic communities with habitat compensation. Drift loss also negligible. Channel regime or geomorphic condition Valid Negligible effects on channel regime or geomorphic condition with mitigation. Water quality (including thermal regime) Valid Acute and chronic toxicity below guideline limits. No expected effects on thermal regime. Fish tissue chemical concentrations Valid Negligible with mitigation measures to regulate water quality. Fish flavour Valid Negligible Syncrude Mildred Lake Upgrader Expansion (1998) Surface water quality Aquatic resources (i.e., fish abundance and quality) Air emission deposition in surface waters surface water quality Air emission deposition in surface waters Valid Valid Project design reduces potential load of metals and PAHs to tributary streams No significant effect of acidforming emissions and an increase in particulate metals or PAH emissions on water quality. Negligible effects of particular emissions of metals and PAHs on aquatic resources. None No rating required October 2014 ESRD/CEAA Page 45

48 ESRD and CEAA Responses Water Frontier Oil Sands Mine Project Table 9a-1 Comparison of EIA Predictions for Fish and Fish Habitat for Operating Oil Sands Mine Projects (cont d) Project (Application Year) Aquatic Endpoints Linkage or Effects Pathway (Changes In) Validity Mitigation or Compensation Predictions Residual Effects Environmental Consequence Total Joslyn North Mine (2006) Fish and fish habitat Water quality Streamflow Valid Compensation lake and fish habitat enhancement (diversion channel and channel realignments Channel geometry and sediment concentrations Valid designed to provide fish passage movement and enhanced habitat/ increased habitat availability) Effects on fish habitat from changes in streamflow (i.e., decreased runoff and stream diversions) are mitigated by habitat compensation and enhancement. Insignificant changes resulting from flow changes and construction works. Physical habitat Valid Alteration or loss of habitat components mitigated for with habitat compensation and Water quality Valid Best management practices to minimize sedimentation and seepage, and effects enhancement. No significant changes in water quality that would result in adverse effect on fish health or fish tainting. Aquatic temperature Valid on water quality Stream temperatures under regimes during project diverted flow regime are not development, expected to differ significantly operation and from baseline conditions. closure Valid Use of the fisheries resources Potential for adverse effects from increased access mitigated by fisheries regulation. None No rating required Sedimentation Valid No significant changes to sedimentation and no adverse effects. Benthic invertebrate communities Valid Loss in available habitat, and effects of changes in water and sediment quality are localized, and the effects on fish are small or negligible with mitigation ESRD/CEAA Page 46 October 2014

49 Frontier Oil Sands Mine Project ESRD and CEAA Responses Water Table 9a-1 Comparison of EIA Predictions for Fish and Fish Habitat for Operating Oil Sands Mine Projects (cont d) Project (Application Year) Aquatic Endpoints Linkage or Effects Pathway (Changes In) Validity Mitigation or Compensation Predictions Residual Effects Environmental Consequence Total Joslyn North Mine (2006) (cont d) Acidification of aquatic ecosystems Valid Negligible magnitude of potential effects on episodic acidification Sediment quality Valid Negligible with mitigation Suncor Millennium (1998) Water quality Fish habitat Fish abundance Acute or chronic effects on fish Fish tissue quality Reclamation streams, wetlands and end pit lake ecosystem viability Basin sediment yield and sediment concentrations in receiving streams Channel regime and erosion Surface water flows and levels Valid Valid Valid Creation or enhancement of compensation habitat Best management practices to minimize sedimentation and seepage, and effects on water quality during project construction, operation and closure Negligible Negligible Changes in fish habitat mitigated by habitat compensation Water quality Valid Low to moderate effects of toxicity; water quality values above guidelines and PAH accumulation Changes in thermal regime of streams End pit lake water quality Lake acidification Spring ph depression Water quality above guidelines in a stream Low Moderate Thermal regime in surface waters Valid Low-magnitude changes Dissolved oxygen in streams Valid Negligible change Sediment quality Valid Negligible change Acidifying emissions Valid Low-magnitude change for acidification of lakes and spring ph depression in surface waters with negligible effects on fish Benthic community Invalid No assessment required Direct habitat loss Valid Habitat loss mitigated by habitat compensation October 2014 ESRD/CEAA Page 47

50 ESRD and CEAA Responses Water Frontier Oil Sands Mine Project Table 9a-1 Comparison of EIA Predictions for Fish and Fish Habitat for Operating Oil Sands Mine Projects (cont d) Project (Application Year) Aquatic Endpoints Linkage or Effects Pathway (Changes In) Validity Mitigation or Compensation Predictions Residual Effects Environmental Consequence Suncor Millennium (1998) (cont d) Access to fishing Invalid No assessment required Fish tissue quality Valid Negligible change Suncor Fort Hills Oil Sands (2001) Fish habitat Aquatic health Fish abundance Fish tissue quality Aquatic ecosystems in project reclamation waterbodies Aquatic biodiversity Habitat quantity and diversity Valid Creation of replacement habitat where prevention of habitat degradation not feasible Negligible fish and benthic invertebrate habitat loss with habitat compensation Flow Valid Effects on fish mitigated by compensation habitat. Magnitude of flow change effects pending results of instream flow study and off-stream storage options Water quality Valid Low to moderate effects of contaminants and acidifying emissions to aquatic health. Possible effects on fish tissue quality. Effects of water contaminants and acidifying emissions on aquatic health and fish tissue quality Low to moderate Benthic invertebrate taxonomic richness and benthic drift Valid Potential low-magnitude effect of reduced benthic drift on food base and fish abundance resulting from changes in flows and stream elimination. Effects are expected to be mitigated by compensation habitat. ESRD/CEAA Page 48 October 2014

51 Frontier Oil Sands Mine Project ESRD and CEAA Responses Water Table 9a-1 Comparison of EIA Predictions for Fish and Fish Habitat for Operating Oil Sands Mine Projects (cont d) Project (Application Year) Shell Muskeg River Mine (1998) Aquatic Endpoints Fish habitat Fish abundance Acute or chronic effects on fish health Fish tissue quality Linkage or Effects Pathway (Changes In) Validity Mitigation or Compensation Access to fishing Invalid Creation of fish Areas of Valid habitat in drainage channels waterbodies Predictions Dissolved oxygen Invalid No assessment required Channel regime Invalid No assessment required Flows and levels in streams Valid Residual Effects Environmental Consequence No assessment required Minor effects on forage fish from None No rating required elimination of waterbodies. Effects are expected to be mitigated by creation of equivalent habitat within drainage channels during operation. Changes not sufficient to affect benthic invertebrate communities Sediment loading Invalid No assessment required Thermal regime Invalid No assessment required Water quality Invalid No assessment required Benthic community Invalid No assessment required Fish tissue chemical concentrations Fish tainting or flavour Invalid Invalid No assessment required No assessment required October 2014 ESRD/CEAA Page 49

52 ESRD and CEAA Responses Water Frontier Oil Sands Mine Project Table 9a-1 Comparison of EIA Predictions for Fish and Fish Habitat for Operating Oil Sands Mine Projects (cont d) Project (Application Year) Aquatic Endpoints Linkage or Effects Pathway (Changes In) Validity Mitigation or Compensation Predictions Residual Effects Environmental Consequence Suncor Steepbank Mine (1996) Aquatic habitat Aquatic ecosystem health Fish flesh tainting Fish abundance Use of fish resources Use of Athabasca River water Benthic invertebrate communities Fish health Fish tissue chemical concentrations Fishing pressure Physical changes or disturbance to aquatic habitat Valid During the reclamation phase, streams will be created that have equivalent or better aquatic habitat than what was lost Potential effect of diversion on stream habitat and benthic invertebrate communities is low and considered negligible with stream restoration in the reclamation phase Surface flow Valid Negligible effect on aquatic patterns habitat or benthic invertebrate Best management communities practices to Water releases Valid Negligible effect on aquatic minimize habitat or benthic invertebrate sedimentation and communities seepage, and effects Water quality Valid on water quality during project construction, operation and closure No toxicity levels resulting from slight increase in chemical concentrations from water discharge. No impacts to fish health or to benthic invertebrate communities. Potential for moderate-level tainting of fish flesh, but no measureable increase in fish tissue chemical concentrations is expected. Changes in the quality of fish flesh Decreased use of fish resources Moderate during the construction and operational phases Moderate, short-term and local effect during project construction and operation Erosion and sedimentation Valid Negligible with mitigation measures Riparian cover Valid Negligible effect on fish habitat with mitigation Barriers to fish movement Valid Potential effects of ice bridges negligible with mitigation Fishing access (bridge) Valid Negligible effect on fish abundance with appropriate enforcement of legislation ESRD/CEAA Page 50 October 2014

53 Frontier Oil Sands Mine Project ESRD and CEAA Responses Water Table 9a-1 Comparison of EIA Predictions for Fish and Fish Habitat for Operating Oil Sands Mine Projects (cont d) Project (Application Year) Aquatic Endpoints Linkage or Effects Pathway (Changes In) Validity Mitigation or Compensation Predictions Residual Effects Environmental Consequence Syncrude Aurora Mine (1996) Fish abundance Habitat quality and availability Aquatic ecosystem health Fish harvest Reestablishment of habitat Sediment loading Valid Aquatic habitat provided in pit lakes and drainage restoration. Mitigation measures not included in the effects assessment. Negligible effect on fish habitat with mitigation (i.e., to prevent erosion and sedimentation) Streamflows Valid Small changes in habitat areas are expected in streams with diverted flows with no significant impact to fish movement or passage. Losses are expected to be mitigated by habitat re-establishment during the reclamation phase. Habitat quality and availability Valid Habitat losses for forage fish because of drainage and diversions. Losses are expected to be mitigated by habitat reestablishment during the reclamation phase. Chronic toxicity to sensitive aquatic organisms and reduction of fish health Marginal to low Water quality Valid No significant changes in productivity expected from changes in nutrient loads. Potential effects on aquatic health in some watercourses. Number of people and improved access Valid Negligible effect of increased fishing access with enforcement of fishing regulations. October 2014 ESRD/CEAA Page 51

54 ESRD and CEAA Responses Water Frontier Oil Sands Mine Project Table 9a-1 Comparison of EIA Predictions for Fish and Fish Habitat for Operating Oil Sands Mine Projects (cont d) Project (Application Year) Aquatic Endpoints Linkage or Effects Pathway (Changes In) Validity Mitigation or Compensation Predictions Residual Effects Environmental Consequence Syncrude Aurora South (2009) Fish habitat Fish abundance Fish health Fish harvest Fish and fish habitat diversity Flows and water levels Valid Aquatic habitat provided in pit lakes and drainage restoration. Low to moderate effects because of cumulative flow changes that may affect fish production in some watercourses. The project is expected to provide a small contribution to these changes. Direct habitat loss Valid Losses in habitat area will occur during operations. These losses will be mitigated by a significant increase in habitat area during reclamation to replace losses in habitat productivity. These losses are expected to result in temporary effects on fish abundance but not fish diversity. Habitat accessibility Valid Temporary loss of habitat accessibility due to diversions. Temporary effects on fish habitat area and accessibility during operations that will affect fish productivity, with productivity reestablished at reclamation due to the significant increase in aquatic resources Not provided in the assessment Channel regime Valid The project provides a minor contribution to cumulative reductions in peak flows in the Muskeg River that could result in reduced fish production. Sediment load Valid Negligible changes in suspended sediment or sedimentation with no predicted effects on fish habitat. Water quality Valid Negligible changes in temperature regime with negligible effects on fish. No changes are expected that would affect aquatic health or pit lake water quality. ESRD/CEAA Page 52 October 2014

55 Frontier Oil Sands Mine Project ESRD and CEAA Responses Water Table 9a-1 Comparison of EIA Predictions for Fish and Fish Habitat for Operating Oil Sands Mine Projects (cont d) Project (Application Year) Syncrude Aurora South (2009) (cont d) Aquatic Endpoints Linkage or Effects Pathway (Changes In) Validity Mitigation or Compensation Predictions Fishing pressure Valid Project does not result in increased access to harvestable fish populations. Benthic invertebrates Constructed habitats Valid Valid Some changes in benthic invertebrate abundance or diversity may occur because of changes in habitat areas and types at reclamation, but no reduction in food base for fish is expected. Increased habitat area at reclamation will re-establish fish productivity and is expected to result in increased fish diversity. Residual Effects Environmental Consequence SOURCES: CNRL (2002); Deer Creek (2006); IORVL (2005); Shell (1998, 2002, 2005); Suncor (1996, 1998, 2005a, 2005b); Syncrude (1996, 1998, 2009); TrueNorth (2001). October 2014 ESRD/CEAA Page 53

56 ESRD and CEAA Responses Water Frontier Oil Sands Mine Project b. As part of federal Fisheries Act authorizations and provincial operating approvals for oil sands mine developments, monitoring programs are implemented to monitor project-related effects on fish and fish habitat, and to determine the success of habitat compensation in achieving no net loss of fish productivity. Although many of these monitoring programs are underway, there are a limited number of publically available reports of results. Conclusions about project-related effects on fish and fish habitat, and on the success of compensation habitats, are generally not available because results are considered preliminary. Examples of project-specific monitoring programs and reports from the oil sands region are summarized as follows: Aquatic Effects Monitoring Study for the Suncor Lease 86/17 oil sands development (Hatfield 2005) This report summarizes monitoring of benthic invertebrate communities at reference sites and potentially exposed sites in the Athabasca River. The study found that benthic invertebrate communities were generally similar at reference sites and potentially exposed sites in Fish and Fish Habitat Monitoring Program Shell Jackpine Mine Phase-1 This monitoring program aims to verify and refine predictive habitat suitability index (HSI) models for fish species in the project area and identify any changes in fish use of watercourses near the project compared to baseline conditions (Hatfield 2009). Recent work focuses on tracking the development of the compensation habitats and confirming that habitat gains compensate for project-related losses (Hatfield 2013). Monitoring focuses on watercourses that are not authorized for harmful alteration, disruption or destruction (HADD) of fish habitat and the project compensation lake. Fisheries and Aquatics Monitoring Program for the CNRL Horizon project This program includes monitoring of affected habitats (Golder 2013a) and fish compensation habitats (Golder 2013b) to determine whether compensation measures meet the objective of providing permanent fish habitat productive capacity gains that compensates for productive capacity losses. Surface Water and Fish Monitoring Plan for the Imperial Oil Kearl project (Golder 2013c) This report describes monitoring conducted for surface water hydrology, water quality, sediment quality, fish habitat, fish populations and benthic invertebrate communities. The objective is to monitor potential effects of the project on the aquatic environment within and adjacent to the project area, and to evaluate the effectiveness of compensation habitats in compensating effects on fish productivity. Monitoring programs underway for operating oil sands developments are generally designed to evaluate or confirm assessment predictions on fish and fish habitat. Data is collected to monitor potentially affected habitats, but also adjacent habitats predicted to be unaffected and compensation habitats that are part of project compensation plans. However, because of changes over time in the assessment process and in regulatory requirements and expectations, the more comprehensive ESRD/CEAA Page 54 October 2014

57 Frontier Oil Sands Mine Project ESRD and CEAA Responses Water monitoring programs (i.e., those specifically aiming to confirm assessment predictions) are for the most recently approved developments. These monitoring programs (i.e., for the most recently approved oil sands developments) specifically focus on assessing fish productivity in affected habitats and compensation habitats to: validate the process used to quantify habitat productivity losses and gains (e.g., HSI model validation) quantitatively assess the effectiveness of the compensation habitats The available project-specific monitoring reports indicate that, to date, no conclusions can be reached about assessment predictions and project effects. This is either because of the limited duration of monitoring efforts so far, the early stages of development for compensation habitats, or the early stages of project development (i.e., specific effects are not yet expected). As such, the available monitoring data do not indicate whether effects have been substantially under- or overpredicted and do not provide enough information to confirm or support the effects predictions or uncertainty assessment for the Frontier Project. The longest and most continuous monitoring data available for the oil sands region are provided by the Regional Aquatics Monitoring Program (RAMP), which has been monitoring aquatic resources in the oil sands region on an annual basis since The program monitors fish and fish habitat (including benthic invertebrate communities), and its objectives are to define the baseline range for the monitoring components and variables, identify long-term trends, and verify assessment predictions (Golder 2003). A summary of the RAMP benthic invertebrate communities component and fish population component is provided (see Table 9b-1), including program conclusions to date (i.e., through the 2013 monitoring year). The monitoring components include a range of measureable endpoints for each potentially affected monitoring site; these endpoints are compared to one or more of the following; the regional normal range of variability for the endpoint the baseline range of variability for the endpoint at the monitoring site the range of variability for the endpoint at a reference (control) site changes over time in the endpoint at the monitoring site Based on these comparisons, differences observed at the monitoring site are defined and classified as follows: Negligible-Low: little or no difference, or endpoints are higher at the monitoring site Moderate: moderate level of difference that might indicate degrading conditions at the monitoring site High: high level of difference that might indicate degrading conditions at the monitoring site October 2014 ESRD/CEAA Page 55

58 ESRD and CEAA Responses Water Frontier Oil Sands Mine Project This classification system is concerned only with differences that suggest a negative change and that might indicate degrading conditions at the monitoring site. It does not classify changes that might be considered beneficial or improved (i.e., increases in one or more endpoints). Table 9b-1 Key Results of the Regional Aquatics Monitoring Program for Fish and Fish Habitat, Watercourse or Waterbody Study Component Benthic Invertebrate Communities Muskeg River Jackpine Creek Firebag River McClelland Lake Johnson Lake Kearl Lake Calumet River Christina River Christina Lake Sunday Creek Jackfish River Shipyard Lake Isadore s Lake Fort Creek Sawbones Creek Birch Creek Unnamed Creek Athabasca River Delta (Big Point and Goose Island channels) Athabasca River Delta (Fletcher Channel and Embarras River) MacKay River Benthic invertebrate community composition, abundance, richness, %EPT (sensitive Ephemeroptera, Plecoptera and Trichoptera) taxa, equitability Classification of Results Negligible-Low Moderate Negligible-Low to Moderate Conclusions Measureable endpoints are: within the tolerance limits of the normal range of variability for regional baseline data similar to the relevant reference sites similar or higher than the range of variability or reference conditions, or one or more endpoints have increased over time The benthic invertebrate communities at these monitoring locations are generally considered indicative of good water quality, sediment quality and habitat conditions. Many also have relatively diverse and abundant communities that support sensitive taxa. Endpoints are within the range of variability, but declines in richness or abundance are observed over time. One site is within the range of variability with increasing %EPT over time, but a second site has richness and %EPT taxa that is less than the range of variability. Steepbank River Moderate Lower abundance, richness and %EPT compared to reference site; however, the community is diverse and includes many taxa that require cool, clean water, indicating a lack of habitat degradation. Differences relative to the reference site potentially result from habitat (substrate) differences. Tar River Moderate Endpoints are within range of variability, but abundance and richness have declined over time. ESRD/CEAA Page 56 October 2014

59 Frontier Oil Sands Mine Project ESRD and CEAA Responses Water Table 9b-1 Key Results of the Regional Aquatics Monitoring Program for Fish and Fish Habitat, (cont d) Watercourse or Waterbody Study Component Benthic Invertebrate Communities (cont d) Classification of Results Conclusions Ells River Moderate Endpoints are within or at the lower range of variability, and abundance, richness and %EPT have declined over time. There is some potential that differences result from differences in water velocities between years. Clearwater River Moderate Abundance, richness and %EPT are less than the reference site; however, all endpoints are within the regional range of variability and have been increasing over time. Poplar Creek Moderate Abundance and %EPT are less than the reference site, and richness and abundance have decreased over time. Fish Populations Athabasca River Fish inventory (relative abundance, lengthfrequency, agefrequency, condition factor, external abnormalities) Athabasca River Delta Sentinel species (age, weight-atage, relative gonad weight, relative liver weight) Fish assemblage monitoring (FAM) Clearwater River Fish inventory (relative abundance, lengthfrequency, agefrequency, condition factor, external abnormalities) Not classified Negligible-Low Not available Not available As of 2013, current and historical data indicate stable species richness combined with speciesspecific variability in relative abundance, agefrequency distribution and condition factor with no trends over time, except increased abundance of goldeye and lake whitefish since the start of monitoring in Observed frequency of external abnormalities remains within the historical range and is consistent with regional data and conditions prior to major oil sands development. Results for some parameters differed from the reference site in 2013, but the pattern was not consistent over time. Overall, the results suggest little difference from the reference site. The FAM program is in its initial phase for the delta, and classification of the results is not currently possible. FAM data indicate that measurement endpoints were fairly consistent among the sampled channels, with high species richness and abundance. Species composition is consistent with the Athabasca River. Limited data indicates a decline in total catch, richness and abundance in 2013 compared to This is considered likely a result of notable flow differences between surveys. Prior to 2013, richness had been increasing and abundance showed no consistent trend. Tar River FAM Negligible-Low Species richness and diversity are higher than baseline range of variability. October 2014 ESRD/CEAA Page 57

60 ESRD and CEAA Responses Water Frontier Oil Sands Mine Project Table 9b-1 Key Results of the Regional Aquatics Monitoring Program for Fish and Fish Habitat, (cont d) Watercourse or Waterbody Fish Populations (cont d) Study Component Classification of Results Conclusions Calumet River FAM Negligible-Low Endpoints are within the normal range of variability for regional baseline data. Firebag River FAM Negligible-Low Species richness and diversity are higher than regional baseline range of variability. Christina River FAM Negligible-Low Endpoints are within the normal range of variability for regional baseline data. Poplar Creek FAM Negligible-Low Species richness, diversity, relative abundance and proportion of sensitive species have increased over time. Steepbank River FAM Moderate Relative abundance is less than the regional normal range of variability and decreasing over time. Results are potentially due to observed changes in environmental factors that might have affected habitat suitability. Muskeg River FAM Moderate Endpoints are within the normal range of variability for regional baseline data, but abundance has been declining over time. This declining trend potentially results from differences observed in habitat conditions between surveys. Fish fence Not classified Changes in fish migration into the Muskeg River were undetectable relative to natural variability; however, the evaluation focused only on recent fish fence sampling conducted by RAMP (i.e., 2003, 2006 and 2009) and did not include historical data. Ells River FAM Moderate A decline in abundance and diversity has been observed over time, although the proportion of sensitive species has increased. Fort Creek FAM Moderate Abundance has declined over time. MacKay River FAM Moderate Endpoints are near lower tolerance limit of regional range of variability, with declining abundance and diversity over time. Jackpine Creek FAM High Abundance and richness are at lower tolerance limit of range of variability and declining over time. Athabasca tributaries River Athabasca River and regional lakes Sentinel species Negligible-Low Monitoring in the Muskeg, Steepbank and Ells rivers indicates variability in some endpoints, such as reduced relative gonad size and increased relative liver size and fish growth, but no consistent trends. Fish tissue Not classified Mercury concentrations in fish tissue sampled from the Athabasca River and regional lakes show that lake whitefish concentrations are generally below consumption guidelines, but northern pike and walleye concentrations are often over the subsistence guideline and sometimes over the general guideline. This is consistent with all regional data and no increasing trends have been detected. SOURCES: Golder (2003); RAMP (2010, 2012, 2013, 2014) ESRD/CEAA Page 58 October 2014

61 Frontier Oil Sands Mine Project ESRD and CEAA Responses Water Results from RAMP show that most benthic invertebrate monitoring sites are classified as negligiblelow, indicating there is little difference or change at the site (see Table 9b-1). Several of these sites have improved conditions relative to reference sites, regional variability or trends over time. The negligible-low category includes sites located near relatively intensive oil sands development (e.g., the Muskeg River, Jackpine Creek, Shipyard Lake). At the remaining benthic invertebrate monitoring sites, differences are classified as moderate because of lower or declining conditions for one or more measurement endpoints. For fish populations, results for several RAMP monitoring components were not classified because of a lack of sufficient data or lack of quantifiable endpoints. For components that were classified, approximately half were classified as negligible-low and the other half as moderate. Components with negligible-low differences were the sentinel species programs that examine the health of smallbodied fish in the Athabasca River and its tributaries and fish assemblage monitoring (FAM) in the Tar, Calumet, Firebag and Christina rivers and in Poplar Creek. Moderate differences were identified for FAM in the Muskeg, Steepbank, Ells and MacKay rivers and in Fort Creek. One component (FAM at Jackpine Creek) was classified as having high differences. Some monitoring sites that were classified as having moderate or high differences were noted to have environmental conditions that might be a factor in the results (e.g., habitat differences between monitoring and reference sites or between survey periods). There are no conclusions that differences or changes observed at any of the monitoring sites are specific indications of habitat degradation or a result of oil sands development. There are also no conclusions presented to date regarding the accuracy of assessment predictions for operating oil sands mines. Components of the fish population monitoring program for which there are several years of data but the results were not classified by RAMP include: the Athabasca River fish inventory the investigation of fish tissue quality in the Athabasca River and in several regional lakes the Muskeg River fish fence The Athabasca River fish inventory shows that although there has been species-specific variability in assessment variables such as relative abundance, age-frequency distributions and condition factor among years, there are no long-term trends or changes identified in this data. The one exception is that goldeye and lake whitefish populations have shown an increase in abundance over time, since the start of the monitoring program in 1997, as well as a shift toward older dominant age classes and increases in mean condition factor. The increase in goldeye is considered potentially a result of environmental conditions, namely warm, calm spring seasons in recent years possibly contributing to improved goldeye recruitment. The results also show that the incidence of external abnormalities for Athabasca River fish remains within the historical range and is consistent with studies completed prior to major oil sands development and with other habitats in northern Alberta. October 2014 ESRD/CEAA Page 59

62 ESRD and CEAA Responses Water Frontier Oil Sands Mine Project Investigations of mercury concentrations in fish tissue in the Athabasca River and in regional lakes show that lake whitefish concentrations are generally below consumption guidelines. However, northern pike and walleye concentrations are often greater than the subsistence guideline and sometimes also greater than the general consumption guideline. Based on the RAMP conclusions, this is consistent with pre-disturbance and post-disturbance data for the oil sands region and no increasing trends have been detected. Published literature concerning mercury concentrations near oil sands developments includes a study that reports that concentrations are increasing (Timoney and Lee 2009) as well as a study (Evans and Talbot 2012) that refutes the reports of increases and concludes that mercury concentrations in lake whitefish and walleye from the Athabasca River have decreased. The Muskeg River fish fence results collected by RAMP were considered too variable among years to draw conclusions about possible changes in fish migration into the Muskeg River relative to natural variability. However, the evaluation focused only on recent fish fence sampling conducted by RAMP (i.e., 2003, 2006 and 2009) and did not include historical data. A more comprehensive discussion of the fish fence results is provided in the response to part c. None of the monitoring results to date contradicts assessment predictions for the Frontier Project. Monitoring has not identified any cases where effects were substantially under-predicted, or overpredicted. The monitoring results also do not indicate any specific level of uncertainty for the Frontier Project predictions. The effects predictions for the Frontier Project are considered appropriate and were based on the project-specific assessment of the mine development plan and the specific aquatic resources in the Project area that might be affected by development activities. In addition to the RAMP activities summarized in Table 9b-1, the Canadian and Alberta governments have mandated scientifically rigorous, comprehensive, integrated and transparent environmental monitoring for the oil sands region through the Joint Oil Sands Monitoring (JOSM) initiative. The Joint Canada/Alberta Implementation Plan for Oil Sands Monitoring (Canada/Alberta 2012) includes regional monitoring enhancements to be implemented over a three-year period, with full implementation by c. The Muskeg River has one of the most complete sets of monitoring data for watercourses in the oil sands region. This is because fish-counting fences were used in studies conducted in various years from 1976 to 2009 as part of the Alberta Oil Sands Environmental Research Program (Bond and Machniak 1977, 1979), baseline surveys for oil sands developments (Golder 1996) and monitoring completed under RAMP (Golder 1999, 2002; RAMP 2010). Data comparability is low for some fishfence studies because of different fence locations, study timing, or duration of survey periods. However, comparing data from fences located at the mouth of the Muskeg River for a representative portion of the spring period allows for examination of possible trends in seasonal use of the Muskeg River by large-bodied fish species from the Athabasca River. ESRD/CEAA Page 60 October 2014

63 Frontier Oil Sands Mine Project ESRD and CEAA Responses Water Historical studies conducted in 1976 and 1977 show a range of 7,762 to 10,366 fish captured at the two-way fish fence, with the catch dominated by longnose and white sucker. Fewer Arctic grayling, northern pike and mountain whitefish were observed and small numbers of other sport fish. Fish fence surveys were also conducted between 1995 and 2001, but these surveys did not provide comparable data given differences in fence location or the short duration of individual study intervals. More recent fish fence studies conducted in 2003, 2006 and 2009 by RAMP generally showed significant declines in numbers of large-bodied fish species. Total numbers captured at the fish fence were as low as 1,206 (in 2003) and 1,256 (in 2006), but increased to 5,657 (in 2009). The total number of fish captured in 2009 was much closer to historical numbers than in any other recent survey years and was almost entirely because of an increase in the number of white sucker, which were captured in numbers greater than in historical surveys. Numbers of all other large-bodied fish species remain below historical levels. Fish fence studies have also been conducted in Jackpine Creek, a Muskeg River tributary with documented spawning use by Arctic grayling, longnose sucker and white sucker (O Neil 1982). Results of spring fish fence studies in 1981 and 1984 in this creek also identified a decline in Arctic grayling, northern pike and longnose sucker numbers, with the decline evident prior to oil sands development in the Muskeg River watershed (RAMP 2010). Changing environmental conditions in Jackpine Creek over time (i.e., replacement of previously documented swift-flowing, rocky spawning habitats with beaver pond habitats) has been suggested as a factor in the declining use of the watershed by species that use rocky habitats for spawning (Golder 2002). This applies particularly to Arctic grayling given the large number of fish of this species historically recorded in the Jackpine Creek fish fence (O Neil 1982). The fish fence results reflect a change in use of the Muskeg River by large-bodied fish species, but do not provide data for the whole fish community. Several studies of fish population have been conducted in the Muskeg River for baseline surveys and monitoring programs in recent years. The most comparable data are results of FAM conducted by RAMP (see the response to part b). The RAMP results classify the Muskeg River as having a moderate difference between test and reference conditions. Although the fish population endpoints are within the normal range of variability for regional baseline data, abundance has been declining over time. The declining trend was considered potentially a result of observed differences in habitat conditions between surveys. The Steepbank River was also the subject of a historical two-way fish fence study conducted in 1977 (Machniak and Bond 1979). During the spring, 9,274 large-bodied fish were captured as part of the study, and 2,295 fish were captured during the fall. No additional fish fence studies have since been conducted for this watercourse. Although more recent baseline inventory studies have completed, the data were collected at various locations throughout the Steepbank River watershed using a variety of other fish capture techniques and are not comparable to the historical fish fence data. Comparison of recent fish inventories conducted in 1995 (Golder 1996) and 2004 (Golder 2005) using similar methods indicates that based on fish species abundance measures (i.e., catch-per-unit-effort), October 2014 ESRD/CEAA Page 61

64 ESRD and CEAA Responses Water Frontier Oil Sands Mine Project abundance was similar for most species between the 1995 and 2004 surveys, indicating little change in the fish community in the interval between these surveys. These results are not comparable to the historical survey; however, and do not show whether fish abundance was similar to historical levels. More recently, based on FAM results (see the response to part b), RAMP classifies the Steepbank River as having a moderate difference between test and reference conditions. Relative abundance is less than the regional normal range of variability and is decreasing over time. Again, these results were considered to potentially stem from observed changes in environmental factors that might have affected habitat suitability. In summary, fish fence data for the Muskeg River and for Jackpine Creek indicate a decline in the populations of large-bodied fish that use the watershed on a seasonal basis. There is some indication the decline began prior to oil sands development in the watershed, and although significant declines occurred for all species, white sucker use in the most recent survey was the highest ever recorded, indicating that variability in the fish fence data is high. Results of RAMP s fish assemblage monitoring for the Muskeg and Steepbank rivers indicate declines in various measurement endpoints that could stem from degrading conditions. However, all declining indicators are considered to have possible associated environmental factors that could be responsible, or contributing to the observed declines. These factors are similar to those that might be contributing to observed increases in fish abundance for some fish species in the Athabasca River as noted by RAMP. No conclusions have been derived as to the cause of the observed trends or suggestions that they are due to oil sands development. The fish and fish habitat assessment for the Frontier Project is a project-specific assessment conducted based on the specific development plan and characteristics of the local watercourses, waterbodies and fish populations. Watercourses in the Project area support limited use by fish from the Athabasca River because of their small size and limited length of defined channel habitat (due to the fluvial fan emanating from the Birch Mountains; see the response to part a). These watercourses are quite different from the Muskeg and Steepbank rivers, which are larger and have defined channel habitats and connectivity throughout most of their lengths. Given the different characteristics of the Muskeg and Steepbank rivers compared to watercourses in the Project area, as well as the absence of any conclusions or monitoring data to date that indicate observed effects, the assessment completed for the Frontier Project is considered appropriate. REFERENCES Bond, W.A. and K. Machniak Interim Report on an Intensive Study of the Fish Fauna of the Muskeg River Watershed of Northeastern Alberta. Prepared by the Department of Fisheries for the Alberta Oil Sands Environmental Research Program. AOSERP Project AF AOSERP Report 26. ESRD/CEAA Page 62 October 2014

65 Frontier Oil Sands Mine Project ESRD and CEAA Responses Water Bond, W.A. and K. Machniak An Intensive Study of the Fish Fauna of the Muskeg River Watershed of Northeastern Alberta. Prepared for Alberta Oil Sands Environmental Research Program by Environment Canada, Freshwater Institute. AOSERP Report 76. Canada/Alberta (Government of Canada and Government of Alberta) Joint Canada/Alberta Implementation Plan for Oil Sands Monitoring. Public Works and Government Services of Canada. CNRL (Canadian Natural Resources Ltd.) Horizon Oil Sands Project Application for Approval. Canadian Natural Resources Ltd, Calgary, Alberta. June Deer Creek (Deer Creek Energy Ltd.) Joslyn North Mine Project, Alberta Energy Utilities Board and Alberta Environment. Deer Creek Energy, Ltd., Calgary, Alberta. February Evans M.S. and A. Talbot Investigations of mercury concentrations in walleye and other fish in the Athabasca River ecosystem with increasing oil sands development. J. Environ. Monit. DOI: /c2em30132f. Golder (Golder Associates Ltd.) Aquatic Baseline Report for the Athabasca, Steepbank and Muskeg Rivers in the Vicinity of the Steepbank and Aurora Mines. Prepared for Suncor Energy Inc., Oil Sands Group. Calgary, Alberta. Golder Oil Sands Regional Aquatics Monitoring Program (RAMP), Prepared for Suncor Energy Inc., Shell Canada Limited, Mobil Oil and Syncrude Canada Ltd. Fort McMurray, Alberta. Golder Oil Sands Regional Aquatics Monitoring Program (RAMP) Volume I: Chemical and Biological Monitoring. Annual Report Prepared for the RAMP Steering Committee. Calgary, Alberta. Golder Oil Sands Regional Aquatics Monitoring Program (RAMP) Five Year Report. Prepared for the RAMP Steering Committee. Golder Fish and Fish Habitat Environmental Baseline Setting Report for the Suncor Voyageur Project. Prepared for Suncor Energy Inc., Fort McMurray, Alberta. Golder. 2013a. Canadian Natural Horizon Fisheries and Aquatics Monitoring, Five Year Data Report. Prepared for Canadian Natural Resources Ltd., Calgary, Alberta. June Golder. 2013b Horizon Lake Monitoring Report. Prepared for Canadian Natural Resources Ltd. by Golder Associates Ltd., Calgary, Alberta. June Golder. 2013c. Kearl Oil Sands Project: Surface Water and Fish Monitoring Plan Annual Report Prepared for Imperial Oil Resources. Calgary, Alberta. December October 2014 ESRD/CEAA Page 63

66 ESRD and CEAA Responses Water Frontier Oil Sands Mine Project Hatfield (Hatfield Consultants Ltd.) Aquatic Effects Monitoring Study in the Athabasca River, Fall Prepared for Suncor Energy Inc., Oil Sands by Hatfield Consultants Ltd., West Vancouver, British Columbia. October Hatfield Fish and Fish Habitat Monitoring Program Shell Jackpine Mine Phase-1. Prepared for Shell Canada Energy by Hatfield Consultants Ltd., West Vancouver, British Columbia, and Solander Ecological Research, Victoria, British Columbia. April Hatfield Jackpine Compensation Lake Monitoring Program, Prepared for Shell Canada Energy, Fort McMurray, Alberta. April IORVL (Imperial Oil Resources Ventures Ltd.) Kearl Oil Sands Project Mine Development, Regulatory Application. Imperial Oil Resources Ventures Ltd., Calgary, Alberta. July Machniak, K. and W.A. Bond An Intensive Study of the Fish Fauna of the Steepbank River Watershed of Northeastern Alberta. Prepared for the Oil Sands Environmental Research Program by Environment Canada, Freshwater Institute, Winnipeg, Manitoba. AOSERP Report 61. O Neil, J., L. Noton and T. Clayton Aquatic Investigations in the Hartley Creek Area, 1981 (Sandalta Project). RAMP (Regional Aquatics Monitoring Program) Regional Aquatics Monitoring Program 2009 Technical Report. Prepared for RAMP Steering Committee by the RAMP 2009 Implementation Team: Consisting of Hatfield Consultants, Kilgour and Associates Ltd. and Western Resource Solutions. RAMP Regional Aquatics Monitoring Program 2011 Technical Report. Prepared for RAMP Steering Committee by the RAMP 2011 Implementation Team: Consisting of Hatfield Consultants, Kilgour and Associates Ltd. and Western Resource Solutions. RAMP Regional Aquatics Monitoring Program 2012 Technical Report. Prepared for RAMP Steering Committee by the RAMP 2012 Implementation Team: Consisting of Hatfield Consultants, Kilgour and Associates Ltd. and Western Resource Solutions. RAMP Regional Aquatics Monitoring Program 2013 Technical Report. Prepared for RAMP Steering Committee in Support of the JOSMP by the RAMP 2013 Implementation Team: Consisting of Hatfield Consultants, Kilgour and Associates Ltd. and Western Resource Solutions. Shell (Shell Canada Ltd.) Application for the Approval and Environmental Impact Assessment for the Muskeg River Mine Project. Shell Canada, Ltd., Calgary, Alberta. March Shell Application for Approval of the Jackpine Mine Phase 1. Shell Canada, Ltd., Calgary, Alberta. May Shell Application for Approval of the Muskeg River Mine Expansion Project. Prepared for Albian Sands Energy Inc. by Shell Canada, Ltd., Calgary, Alberta. April ESRD/CEAA Page 64 October 2014

67 Frontier Oil Sands Mine Project ESRD and CEAA Responses Water Suncor (Suncor Inc.) Steepbank Mine Project Application. Suncor Inc., Oil Sands Group, Fort McMurray, Alberta. April Suncor (Suncor Energy Inc.) Project Millennium Application. Suncor Energy, Inc., Fort McMurray, Alberta. April Suncor. 2005a. Voyageur Project, Volume 1A, North Steepbank Extension Project Application. Suncor Energy, Inc., Fort McMurray, Alberta. March Suncor. 2005b. Voyageur Project, Volume 1B, Voyageur Upgrader Project Application. Suncor Energy, Inc., Fort McMurray, Alberta. March Syncrude (Syncrude Canada Ltd.) Environmental Impact Assessment for the Syncrude Aurora Mine. Syncrude Canada, Ltd., Fort McMurray, Alberta. June Syncrude Mildred Lake Upgrader Expansion Application and Environmental Impact Assessment. Syncrude Canada, Ltd., Fort McMurray, Alberta. July Syncrude Aurora South Project 2009 Environmental Update, Volume 2. Submitted to the Energy Resources Conservation Board. Syncrude Canada, Ltd., Fort McMurray, Alberta. December Timoney K.P. and P. Lee Does the Alberta tar sands industry pollute? The scientific evidence. Open Conserv. Biol. J. 3: TrueNorth (TrueNorth Energy L.P.) Application for Approval of the Fort Hills Oil Sands Project. TrueNorth Energy, L.P., Calgary, Alberta. June Question 10 SIR1, Volume 1, Section 10, SIRs 72 and 73, Pages SIR1, Volume 1, Section 5.5, SIR 111a, Pages to SIR 112, Pages to SIR1, Volume 1, Section 10, SIR 71 b, Page 148 SIR2, Volume 1, Aquatics, SIR 30 Modelling work undertaken to support the development of the Terrestrial Ecosystem Management Framework (TEMF), and the Lower Athabasca Regional Plan (LARP) predict fish indicators will decline as land use change associated with bitumen extraction increases through time. a. Describe how the assessment conclusions are consistent with the TEMF and LARP predictions. Update the assessment as appropriate. Ecological systems are complex, as are the mechanistic drivers to model fish and wildlife outcomes. Consequently, the presentation of knowledge gaps and uncertainty is important in the October 2014 ESRD/CEAA Page 65

68 ESRD and CEAA Responses Water Frontier Oil Sands Mine Project characterization of environmental risk associated with the Frontier Project alone and in combination with other projects. b. Ensure all assessment and confidence conclusions are placed in the context of their associated ecological uncertainty. Highlight knowledge gaps and how they contribute to uncertainty around ecological outcomes associated with the Project and mineable oil sands. Ensure uncertainty and knowledge gaps associated with water quantity and quality model conclusions are considered and transmitted to the revised aquatic ecology assessment. c. Discuss resilience with respect to aquatic systems. Given the pre-disturbance and current data for aquatic systems in presently disturbed watersheds, provide a discussion of resilience to contextualize the Frontier Project effects, regional effects, and to support better understanding of the potential aquatic ecological risk associated with the mine development. d. Identify when baseline surveys will be undertaken to assess fish and fish habitat for the unclassified watercourses in the centre of the PAA. e. Update the assessment and compensation plan to include these habitats using a precautionary assumption that they support fish. Include figures representing fish presence and confirmed absence. f. Assess potential changes to species composition and relative abundance. Consider and discuss broader ecological connections, uncertainty and knowledge gaps. Response 10 a. LARP The Lower Athabasca Regional Plan (LARP) does not provide any predictions relative to aquatic ecology, fish habitats or fish populations (Alberta Government 2012). Instead, it identifies various management frameworks designed to manage, at a regional level, the long-term cumulative effects of development on the environment. One component is the Biodiversity Management Framework (BMF), which will include aquatic ecosystems. Although the LARP states that a BMF will be developed, it is currently in draft form and its timeline for completion is not known. As such, the LARP does not currently provide specific information about aquatic ecosystems that can be used to consider assessment predictions. TEMF The Terrestrial Ecosystem Management Framework (TEMF) predictions for fish are based on an Index of Native Fish Integrity (INFI), which ranges from 1 for a pristine fish community to 0 for a highly disturbed community. The index can be generalized as follows: 1 corresponds to a fish community with abundant, large sport fish and few minnows ESRD/CEAA Page 66 October 2014

69 Frontier Oil Sands Mine Project ESRD and CEAA Responses Water 0.5 corresponds to a fish community with common, small sport fish and abundant minnows 0 corresponds to a fish community with few sport fish and abundant minnows The limited description of the IFNI model provided in the TEMF does not provide sufficient detail to fully evaluate the methodology used for IFNI modelling. The model is based on simple, assumed relationships between linear development density (representing the degree of habitat fragmentation), human density and the INFI. These relationships are used to forecast the INFI under different landuse scenarios. The TEMF conclusion is that the INFI is in the red condition in the Regional Municipality of Wood Buffalo, meaning that the index is 20% below the natural range of variation (NRV) or the model predicts it will drop to this level within 15 years (SEWG 2008). Effects of human density (e.g., angling effects) and fragmentation (e.g., because of hanging culverts associated with linear developments) were flagged as key drivers for the predicted decline in the INFI. Access management was identified as the key mitigation for reducing the predicted IFNI decline and would include managing motorized human access and the reclamation of linear footprints. The TEMF predictions were not used in the fish and fish habitat assessment for the Project. They are considered inappropriate and inaccurate for a Project-specific assessment for several reasons: The TEMF is a modelling exercise to determine the potential outcomes of various hypothetical resource management scenarios. However, the information available is not at an appropriate level of detail to be used in the effects assessment. The IFNI is not relevant to the aquatics LSA because of the lack of sport fish populations in the Project area. Habitats in the aquatics LSA do not appear on the IFNI scale, and effects on these habitats would not register as a change on the scale no matter what the level of impact to the fish populations. The TEMF does not consider baseline conditions in the aquatics LSA. There are currently no watercourse culvert crossings and therefore no potential for habitat fragmentation because of linear developments. The TEMF does not consider mitigation identified in the. For example, Teck will comply with the Alberta Water Act Codes of Practice for Watercourse Crossings to avoid interfering with upstream and downstream fish migrations. This mitigation would eliminate habitat fragmentation at each watercourse crossing location (see the response to ESRD/CEAA Round 3 SIR 39), but would not be reflected in TEMF predictions. For these reasons, the TEMF predictions of serious decline in the INFI are not relevant to the aquatics LSA. Based on the mitigation measures identified for the Project and the characteristics of local fish populations, the Frontier Project is not expected to result in aquatic habitat fragmentation or increased fishing pressure (see the response to ESRD/CEAA Round 3 SIR 36) and will not contribute to any local or regional decline in the IFNI as modelled by the TEMF. October 2014 ESRD/CEAA Page 67

70 ESRD and CEAA Responses Water Frontier Oil Sands Mine Project Nonetheless, the potential for improperly installed and maintained road culvert crossings to result in habitat fragmentation is an important issue. Surveys of culvert crossings in northern Alberta watersheds found a large number of hanging culverts: 55% of the 1,760 culverts examined (ACA 2009, 2012). The specific protocol for relating linear density to habitat fragmentation (e.g., assumed proportion of hanging culverts) used in the TEMF cannot be determined given the limited descriptions of INFI modelling methods. Therefore, it is not possible to assess the suitability of TEMF predictions for portions of the lower Athabasca region where sport fish populations occur. As indicated, Teck will comply with the Alberta Water Act Codes of Practice for Watercourse Crossings to mitigate potential aquatic habitat fragmentation as a result of the Frontier Project. This includes selecting the appropriate crossing type and properly installing, inspecting and maintaining culverts at planned road crossings (for details, see the response to ESRD/CEAA Round 3 SIR 39). Although it has been determined that hanging culverts can impede upstream fish movement (Burford et al. 2009), bridges generally provide unimpeded fish passage (Pluym et al. 2008). Studies of habitat fragmentation for Arctic grayling in the Athabasca River basin showed that upstream fish passage was unimpeded by bridges and non-hanging culvert stream crossings, and that Arctic grayling abundance appeared to be unaffected by increasing road densities (ACA 2010; McPherson and Furuka 2010). The predictions for the Frontier Project are not consistent with the TEMF; however, the fish and fish habitat assessment completed for the Project is project-specific and is based on the specific development plan (including mitigation) and the specific watercourses, waterbodies and fish populations in the aquatics LSA. In contrast, the TEMF provides a general model for assessing the implications of different management strategies. The suitability and accuracy of the INFI model could not be assessed given the limited methodology detail included in the TEMF. As a result, an updated fish and fish habitat assessment that incorporates TEMF is not provided. b. The response to ESRD/CEAA Round 3 SIR 42b summarizes the fish and fish habitat assessment and the information provided in the various SIR responses related to the assessment. Table 42b-1 identifies the assessment conclusions, confidence level, uncertainty and knowledge gaps for each of the assessment pathways. Table 42b-1 also indicates where the results of the hydrology and surface water quality assessments support the fish and fish habitat assessment. Further discussion about confidence levels for the hydrology and surface water quality assessments is provided in response to ESRD/CEAA Round 3 SIR 12a, h and SIR 15a. c. Based on historical (predevelopment) and current data for aquatic systems in the lower Athabasca River basin and regional monitoring data for benthic invertebrate communities and fish populations, the resilience of these aquatic systems appears to be generally high (see the response to ESRD/CEAA Round 3 SIR 9b,c). For example: RAMP results show that benthic invertebrate communities in various Athabasca River tributaries have similar or higher metrics for measurement endpoints relative to reference sites, regional ESRD/CEAA Page 68 October 2014

71 Frontier Oil Sands Mine Project ESRD and CEAA Responses Water variability or trends over time. This includes sites located near relatively intensive oil sands development (e.g., the Muskeg River, Jackpine Creek, Shipyard Lake). The remaining benthic invertebrate community monitoring sites are classified as having lower or declining conditions for one or more measurement endpoint. For fish populations, RAMP results indicate an approximately even number of monitoring sites were classified as similar to and lower than baseline or reference conditions. Some of the monitoring sites for benthic invertebrate communities and fish populations that were classified as having differences from baseline or reference conditions were noted to have environmental conditions that might be a factor in the results, such as habitat differences between monitoring and reference sites or between survey periods. With respect to the comparison of current and historical data (see the response to ESRD/CEAA Round 3 SIRs 9c, 32a and 34b), fish fence data for the Muskeg River and for Jackpine Creek indicate a decline in the populations of large-bodied fish that use the watershed on a seasonal basis. There is some indication the decline began prior to oil sands development in the watershed, and although significant declines occurred for all species, white sucker use in the most recent survey was the highest ever recorded, indicating that the variability in the fish fence data is high. Results of RAMP s fish assemblage monitoring for the Muskeg River indicate declines in various measurement endpoints that could stem from degrading conditions. However, all declining indicators are considered to have possible associated environmental factors that could be responsible, or contributing to the observed declines. Overall, the available long-term monitoring data and comparisons of predevelopment and current benthic invertebrate communities and fish populations do not identify specific effects of oil sands activity. This is true even in areas with intensive development, indicating that the resilience of these key indicators is fairly high. d. As described in response to ESRD/CEAA Round 3 SIR 22a, the unclassified drainage in the centre of the PDA appears as a watercourse in figures provided in the fish and fish habitat assessment (e.g., Figure in the revised conceptual fish habitat compensation plan [see the response to ESRD/CEAA Round 2 SIR 30j, Appendix 30j.1]). This is an error based on its appearance in the 1:20,000 AltaLIS hydrography. There are no watercourse or pond habitats present in this drainage on aerial photographs or on the 1:50,000 National Topographic System (NTS) hydrography (stream network topology) of this area (Map 74 E/12 Asphalt Creek). The drainage consists entirely of bog and terrestrial habitats, with no aquatic habitats present, including no defined watercourse channel or channel segments and no ponds or beaver impoundments. This observation is consistent with the ground-truthing study conducted as part of the hydrology baseline study (see Volume 2, Appendix 4B), which examined the hydrography in the Redclay Creek and Unnamed Creek 16 and 17 drainages. The ground-truthing study was conducted to verify the presence or absence of watercourses given the differences noted between the AltaLIS and NTS data, in which considerably fewer October 2014 ESRD/CEAA Page 69

72 ESRD and CEAA Responses Water Frontier Oil Sands Mine Project watercourses were evident in drainage areas on the NTS map relative to the AltaLIS map. During the study, it was determined that the examined drainage areas were more consistent with the NTS map. A correction of the hydrography is provided in Figure 22a-1 (see the response to ESRD/CEAA Round 3 SIR 22a), which no longer shows a watercourse in the drainage in question. Given the lack of aquatic (watercourse or pond) habitats in the drainage (as described in the response to part d and to ESRD/CEAA Round 3 SIR 22a), a fish and fish habitat baseline survey of the drainage is neither warranted nor possible. e. Given the lack of aquatic (watercourse or pond) habitats in the drainage (see the response to part d and to ESRD/CEAA Round 3 SIR 22a), there is no potential for fish habitat productivity. Therefore, an update of the fish and fish habitat assessment, fish habitat losses and compensation plan is neither warranted nor possible. f. Given the lack of aquatic (watercourse or pond) habitats in the drainage (see the response to part d and to ESRD/CEAA Round 3 SIR 22a), there is no potential for changes to species composition or relative abundance because there is no potential for fish use. REFERENCES ACA (Alberta Conservation Association) Road Developments and Habitat Fragmentation of Sportfish and Non-Sportfish Species in the Athabasca River Basin. Alberta Conservation Association. ACA Stream Crossings and Arctic Grayling Conservation in the Athabasca River Basin. Alberta Conservation Association. ACA Stream Crossing Remediation. Alberta Conservation Association. Alberta Government Lower Athabasca Regional Plan Alberta Environment and Sustainable Resource Development. Available at: REGIONALPLANS/LOWERATHABASCAREGION/Pages/default.aspx. Accessed July Burford, D.D., T.E. McMahon, J.E. Cahoon and M. Blank Assessment of Trout Passage Through Culverts in a Large Montana Drainage During Summer Flow. North American Journal of Fisheries Management 29: MacPherson, L. and T. Furukawa Preliminary Report: Stream Crossings and Arctic Grayling Conservation in the Athabasca River Basin. Produced by the Alberta Conservation Association, Alberta, Canada. Pluym, J.L., D.B. Eggleston and J.F. Levine Impacts of road crossings on fish movement and community structure. Journal of Freshwater Ecology 23: ESRD/CEAA Page 70 October 2014

73 Frontier Oil Sands Mine Project ESRD and CEAA Responses Water SEWG (Sustainable Ecosystem Working Group) of the Cumulative Environmental Management Association Indicator Synthesis: Selection Rationale, Modelling Results and Monitoring Considerations for Key Indicators of the Terrestrial Ecosystem Management Framework. Prepared by B. Wilson and B. Stelfox. Question 11 SIR1, Volume 1, Section 10, SIRs 72 and 73, Pages SIR1, Volume 1, Section 5.5, SIR 111a, Pages to SIR 112, Pages to SIR1, Volume 1, Section 10, SIR 71 b, Page 148 SIR2, Volume 1, Aquatics, SIR 30 Teck undertook an aquatic health assessment and concluded that whole effluent and chronic toxicity are the most relevant indicators of potential effects of oil sands release waters to aquatic systems. In support, Teck indicates that whole effluent toxicity testing has been shown to be an effective indicator of instream effects, referencing Environment Canada (1991). More recent literature, including documents published by Environment Canada refutes this conclusion. While acute and chronic toxicity parameters are informative, especially with respect to whole effluent, they are necessarily assessed in the lab, and do not consider other ecological factors that might work in conjunction with the water quality changes. Consequently there is considerable uncertainty associated with the aquatic ecological outcomes of water quality change associated with oil sands mining. a. Discuss more recent literature associated with the use of whole effluent, acute, and chronic toxicity testing as an indicator of instream effects and aquatic ecological health. b. Describe how uncertainty and broader aquatic biota population level effects were considered in the aquatic health assessment. c. The approach for the aquatic health effects assessment mixes the stressor assessment (water quality) with the ecological response or effect (aquatic health). Separate the effects assessment for water quality from the assessment for aquatic health effects. Consider the water quality modelling results and then consider aquatic health. For example, if duration is considered: the water quality effects assessment would outline the time frame under which the water quality change is expected to persist, and then the aquatic health effects assessment would outline how long the aquatic health effects associated with that water quality change would be expected to persist, both on an individual and population level. d. Discuss whether the water quality and aquatic health assessment conclusions are appropriate; revise the aquatic ecology assessment as appropriate. October 2014 ESRD/CEAA Page 71

74 ESRD and CEAA Responses Water Frontier Oil Sands Mine Project Response 11 The following response is common to all parts (a to d) of this SIR. Individual sub-questions are addressed below. There are uncertainties associated with any aquatic health assessment, whether conducted in the field, the laboratory, or based on an extension of findings from the literature. The aquatic health assessment (see Volume 5, Section 4.12) considered both acute and chronic toxicity, and integrated findings from laboratory-based studies of mixture toxicity and substance-specific research focused on developing chronic effects benchmarks (CEBs). Predicted concentrations of substances in fish tissue were also compared to applicable fish tissue effects benchmarks; this provided an additional method of evaluation that is appropriate for bioaccumulative substances. CEBs are derived from controlled studies of individual substances. These studies examine potential effects of the substance in isolation; however, they do not typically account for additive, synergistic or antagonistic effects that might influence toxicity. This is one of the main reasons why whole-effluent (or mixture) toxicity tests provide an important line of evidence to confirm or refute literature-based predictions. Bioavailability is another important consideration not necessary reflected in substancespecific investigations. Literature-based predictions frequently overpredict potential instream effects because of highly bioavailable forms of the substances (e.g., dissolved forms). Whole-effluent toxicity tests generally represent toxicity-modifying conditions that are representative of natural conditions. On the basis of these considerations, any toxicity predictions in the aquatic health assessment that exceeded the recommended whole-effluent toxicity guidelines (chronic or acute) (AEP 1995) was rated a high magnitude effect. Where guidelines for overall toxicity were exceeded (i.e., toxicity predicted in receiving environment), this was regarded as evidence of a moderate to high environmental consequence. 1 However, the lack of predicted acute or chronic toxicity did not preclude the literaturebased assessment of individual substances using the CEB approach. For individual substances, CEB exceedances were considered in the context of geographical extent, duration, reversibility and frequency in assessing overall environmental consequence. a. Teck references Environment Canada (1996) and U.S. EPA (1991) in support of the conclusion that whole-effluent toxicity (WET) testing is an effective indicator of potential instream effects. Teck is unaware of more recent literature (by Environment Canada or others) that refutes this conclusion. 1 According to the effects description criteria in and environmental consequences rating system identified in the aquatic health assessment (see Volume 5, Section , Table 4-32 and Table 4-33), predicted acute or chronic toxicity would result in a high magnitude rating. This corresponds to a moderate to high environmental consequence, a finding that likely indicates a significant environmental effect. ESRD/CEAA Page 72 October 2014

75 Frontier Oil Sands Mine Project ESRD and CEAA Responses Water More recent publications from Environment Canada (1999, 2005) have reviewed research on field validation of toxicity tests in the laboratory and have confirmed the earlier conclusion that laboratory tests are generally good predictors of effects in natural habitats. Chapman (2000) acknowledges that WET tests are a useful tool for identifying impacts in the environment, although the review cautions that they do not provide an absolute prediction of potential field impacts. Recognizing the uncertainties inherent in laboratory-to-field extrapolation, Chapman (2000) concludes that WET tests are often overprotective, meaning that the uncertainty with WET testing is the tendency to identify false-positives rather than false-negatives. The review concludes that WET tests are appropriate for identifying and delineating effluents of concern, and may be appropriately considered as part of a weight-of-evidence approach (i.e., a combination of evidence). As discussed above, in assigning a high-magnitude effects rating, the aquatic health assessment considered multiple lines of evidence, including comparing: predicted water quality to WET thresholds CEBs for individual substances fish tissue concentrations to applicable fish tissue effects benchmarks Modelling and assessing acute and chronic toxicity using WET predictions is common in EIAs submitted for other oil sands developments in Alberta. These assessments have been reviewed and approved by Joint Review Panels, and precedence exists for this approach. AEP (1995), for example, identifies WET testing as one component of the water quality-based procedure for setting effluent limits, stating: Limits that are based on meeting instream guidelines are either developed through chemical specific or whole effluent toxicity approaches. The chemical specific approach involves restricting individual substances concentrations to meet associated instream guidelines, while the whole effluent approach involves restricting the toxicity of an entire effluent to the extent that no toxicity will occur instream. The whole effluent approach considers the aggregate effect of a complex mixture of substances. Chemical specific and whole effluent limits can be calculated based on projected stream and effluent flows and substance concentrations. The WET approach, combined with assessment of individual substances in the water column and accumulated in fish tissue, is consistent with this weight-of-evidence approach. Moreover, toxicity testing is mandated by the Alberta Government as part of Environmental Protection and Enhancement Act (EPEA) approvals (see the responses to ESRD/CEAA Round 1 SIR 388b and ESRD/CEAA Round 2 SIR 169a). The most recent EPEA approval for an oil sands mine available at the time this response was drafted was issued for the Total Joslyn Mine and requires routine WET testing for diversion and discharge waters (GOA 2011). b. The ecological significance of effects on aquatic communities is commonly assessed at the community level because the protection goal is to maintain the functional status of the aquatic community. This includes maintaining diverse and abundant taxa at each trophic level. This protection October 2014 ESRD/CEAA Page 73

76 ESRD and CEAA Responses Water Frontier Oil Sands Mine Project goal differs from that of generic water quality guidelines, which are intended to protect all aspects of the aquatic life cycles, including the most sensitive life stage of the most sensitive species over the long term (CCME 2007). In the case of sensitive keystone species, commercially or culturally valued species, or species at risk (as defined by the Committee on the Status of Endangered Wildlife in Canada [COSEWIC]), population-level assessment is appropriate. However, for the purposes of this response, we assume that the reviewer is referring to community composition when using the term broader aquatic biota population level effects and that the SIR relates to how results from individual test species are extrapolated to the broader range of organisms found in natural environments. The aquatic health assessment compared water quality model predictions to reference conditions, baseline concentrations, and generic water quality guidelines for the protection of aquatic life. Water quality guidelines represent levels that, if met in any surface water, will provide a high level of protection to all aquatic life, including individual and population-level effects for all species. Exceedance of a water quality guideline indicates that adverse effects are possible, but not necessarily likely. Where water quality guidelines are met, all life stages and all species are, by definition, protected, and there is a high degree of certainty that protection goals will be achieved. Laboratory-to-field extrapolation is a source of uncertainty in any aquatic health evaluation; however, methods and assumptions have been developed in the field of environmental toxicology to account for these uncertainties. For example: Laboratory test species are assumed to serve as reasonable surrogates for naturally occurring species. Toxicity test protocols have been developed with a preference for using species and endpoints that are sensitive to the effects of anthropogenic substances. The lowest acceptable endpoint is typically used in developing species sensitivity distributions, and no-effect data are preferentially and primarily plotted when available. Toxicity tests for most metals and metalloids incorporate conservatism because these substances are often introduced in a highly dissolved form that overstates the bioavailability expected in natural exposures. Therefore, although uncertainty remains, the conservatism incorporated in CEB derivations offsets the uncertainty in the derivation method. Uncertainty is addressed, in part, by using multiple approaches to assess aquatic health (e.g., literature-based methods and site-specific toxicity testing of effluents). As outlined in the response to part a, the acute, chronic and WET testing approach considers the aggregate effect of a mixture. WET testing addresses uncertainties associated with chemical interactions and factors that can modify toxicity. This approach has been extensively validated; for example, numerous field research programs have been conducted to associate effects in natural (i.e., wild) aquatic communities with results of laboratory tests. Similar experiments have also been done using controlled communities ESRD/CEAA Page 74 October 2014

77 Frontier Oil Sands Mine Project ESRD and CEAA Responses Water (i.e., mesocosms). Environment Canada provided a major review of that research, and concluded that in most cases, the laboratory tests were good predictors of effects in natural habitats (Environment Canada 1999, 2005). Mebane (2010) also reports reasonable agreement between the laboratory-based predictions and effects observed in field surveys or ecosystem experiments. Where generic water quality guidelines are predicted to be exceeded, a framework for region-specific derivations is applied (see Volume 5, Appendix 4B). The use of species sensitivity distributions (SSDs) provides an ecosystem-level approach that considers: the range of toxicity data for representative species the resiliency and redundancy in biological communities, especially at lower trophic levels biological differences among species and that the variation among species sensitivities can be described by a statistical distribution The SSD can be used to define an environmental quality criterion (usually an HC 5 value, which represents the hazardous concentration threshold for 5% of species), a conservative threshold for effects to aquatic ecosystems (Versteeg et al. 1999). CEBs derived using the SSD approach are less conservative (i.e., more realistic) than generic water quality guidelines, but retain a level of conservatism for the evaluation of community-level effects. In its final phase, the aquatic health assessment reviews monitoring data over time. Teck expects that water quality sample collection and analysis, in addition to chronic and acute toxicity testing, will be conducted regularly as part of the anticipated EPEA approval conditions and monitoring requirements for the Project (see the responses to ESRD/CEAA Round 1 SIR 388b and ESRD/CEAA Round 2 SIR 169a). Although water quality predictions include some uncertainty, monitoring data will provide the opportunity to verify predictions and address changes through adaptive management. This monitoring is one example of Teck s adaptive management approach (as described for mine operation and closure in the response to ERCB Round 1 SIR 88). c. The water quality assessment (see Volume 5, Section 4.5) served two purposes: (1) to predict changes in the concentrations of constituents (and associated implications for water quality) (2) to assess potential exposure pathways and conditions for the risk-based aquatic health impact assessment Following a classical risk assessment approach (e.g., U.S. EPA 1998), the stressor (or exposure) assessment is typically separated from the effects assessment. This approach was generally followed in the assessment. The water quality predictions represent the stressor assessment for aquatic health assessment, whereas the effects assessment and risk characterization portions of the aquatic health assessment are covered separately. Specifically, consideration of the ecological responses (effects) is considered in the aquatic health assessment (see Volume 5, Section 4.12) and the CEBs (see Volume 5, Appendix 4B). October 2014 ESRD/CEAA Page 75

78 ESRD and CEAA Responses Water Frontier Oil Sands Mine Project Ecological risk assessment guidance (e.g., U.S. EPA 1998) emphasizes an iterative approach where each assessment component is revisited as necessary to address uncertainty and refine assessment conclusions. As a result, in the risk characterization stage, some of the exposure predictions were examined in greater detail. These iterations were discussed in the aquatic health assessment, rather than revising the water quality assessment, to maintain the focus of the water quality assessment on the numerical changes to the concentrations of water quality parameters. Although the water quality and aquatic health assessments for the Project could have been organized differently to better define the distinctions among the stressor (exposure) assessment, the effects assessment, and the risk characterization components, this reorganization would not have changed the assessment approaches or conclusions for these assessment components. One of the challenges associated with clearly demarcating the boundaries between exposure assessment and effects assessment relates to the required use of predictive models for water quality. These models provide complex output over a range of conditions. This output requires processing to align with the effects assessment (i.e., to provide a basis for meaningful comparison to benchmarks). The following bullets summarize some of the data aggregations that were required: As discussed in Volume 5, Section 4.5, the water quality assessment considered Project and cumulative effects during temporal snapshots. These snapshots were selected to represent worstcase conditions during construction, operation and closure. Within each time snapshot, stochastic modelling was completed for spatial nodes of interest. Stochastic modelling assumes a fixed temporal condition (e.g., an annual mine plan snapshot) but simulates a wide range of meteorological, water quality and hydrologic conditions that are derived from the longest available set of observed data. Model output from such stochastic modelling is an extended series (generally about 20,000 simulated days) from which to draw statistical probabilities of occurrences. Results are provided as median and peak concentrations (see Volume 5, Section 4.5 and as revised various SIR responses). Water quality predictions were applied to indicate potential exposure. Predicted peak concentrations were compared to CEBs, and then peak concentrations then estimated using the percentile (i.e., one-day-in-three-year frequency of occurrence), which corresponds to the recommended frequency of compliance with generic water quality guidelines as determined by ESRD (AEP 1995) and the U.S. EPA (1991). The application of a one-day-in-three-year concentration to represent chronic exposure is highly protective given that the timeframe over which chronic effects are typically expected to manifest is multiple consecutive days (or weeks). CCME (2007) specify a seven-day guideline for chronic exposure, whereas CEBs developed for the EIA applied a four-day guideline (i.e., 96 hours) based on the criteria defined in Volume 5, Appendix 4B, Section 4B Given this high degree of conservatism, peak exceedances of CEBs were examined further in the aquatic health section (see Volume 5, Section 4.12). In determining the magnitude of potential effects, estimates considered both the magnitude and duration of the exceedance above the CEB. These ESRD/CEAA Page 76 October 2014

79 Frontier Oil Sands Mine Project ESRD and CEAA Responses Water refinements were documented in the aquatic health section (rather than the water quality section) because they related to the appropriate matching of exposure duration between water quality predictions and chronic effects data. Regarding the duration of aquatic health responses (as distinguished by the reviewer from the duration of the water quality condition), it was assumed that these durations would be equivalent. Any aquatic health effects associated with impaired water quality would be expected to last for the same duration as the water quality exceedance above the CEB, subject to an evaluation of reversibility of harm. The degree to which the effects are predicted to be reversible was considered as a separate component of the environmental consequence classification. As described in Volume 5, Section , Pages to 4-193, an environmental consequence rating consolidates the results of the effects criteria (direction, magnitude, duration, frequency, geographic extent and reversibility) into a single rating. d. Given the discussion in parts a to c, the water quality and aquatic health assessment conclusions are considered appropriate. REFERENCES AEP (Alberta Environmental Protection) Water Quality Based Effluent Limits Procedures Manual. Environmental Protection. Edmonton, Alberta. CCME (Canadian Council of Ministers of the Environment) A Protocol for the Derivation of Water Quality Guidelines for the Protection of Aquatic Life Winnipeg, Manitoba. Chapman, P.M Whole Effluent Toxicity Testing Usefulness, Level of Protection, and Risk Assessment. Environmental Toxicology and Chemistry Volume 19: Environment Canada Guidance Document on the Interpretation and Application of Data for Environmental Toxicology. Environmental Protection, Conservation and Protection. Ottawa, Ontario. Environment Canada Guidance Document on Application and Interpretation of Single-Species Tests in Environmental Toxicology. Method Development and Applications Section, Ottawa, Ontario. Report EPS 1/RM/34. Environment Canada Guidance Document of Statistical Methods for Environmental Toxicology Tests. Method Development and Applications Section, Environmental Technology Centre, Environment Canada, Ottawa, Ontario. GOA (Government of Alberta) Terms and Conditions for Approval of Construction, Operation and Reclamation of the Joslyn North Oil Sands Processing Plant and Associated Mines (Leases 24, 452 and 799). Approval number September Mebane, C.A Relevance of risk predictions derived from a chronic species-sensitivity distribution with cadmium to aquatic populations and ecosystems. Risk Analysis 30: October 2014 ESRD/CEAA Page 77

80 ESRD and CEAA Responses Water Frontier Oil Sands Mine Project U.S. EPA (United States Environmental Protection Agency) Technical Support Document for Water Quality-Based Toxics Control. U.S. EPA, EPA U.S. EPA Guidelines for Ecological Risk Assessment. U.S. EPA, EPA/630/R-95/002F. Versteeg, D.J., S.E. Belanger and G.J. Carr Understanding single species and model ecosystem sensitivity: data-based comparison. Environ. Toxicol. Chem. 18: Question 12 SIR1, Volume 1, Section 10, SIRs 72 and 73, Pages SIR1, Volume 1, Section 5.5, SIR 111a, Pages to SIR 112, Pages to SIR1, Volume 1, Section 10, SIR 71 b, Page 148 SIR2, Volume 1, Aquatics, SIR 30 The broader aquatic ecological uncertainty associated with the water quality conclusions was not carried forward and presented to provide context to the aquatic ecology portion of the assessment. a. Revisit each water quality conclusion used to support the aquatic effects assessment and consider whether the conclusion is appropriate to fully invalidate a linkage, support the conclusion, and/or has considered the broad suite of potential aquatic ecological effects and the uncertainty associated with the conclusion. There is considerable uncertainty associated with whether EPLs will provide healthy, productive aquatic ecosystems and on what time frame this might be accomplished. Although industry is supporting modeling and pilot work associated with Syncrude s Base Mine Lake, the lake was developed using older technology. New bitumen extraction processes, the removal of processaffected materials from many proposed EPLs, the use of polymers in tailings management, etc. are not well understood with respect to their potential effects in the final closure watershed. EPLs are the place to which most water on the reclaimed landscape will eventually flow. Teck s conclusions appear predicated on the assumption that if constituents remain below acute and chronic toxicity parameters, tainting potential levels, and chronic effects benchmarks (CEBs), the ecological outcome will be a functional aquatic ecosystem. b. Discuss the uncertainty associated with the prediction EPLs will provide healthy, productive aquatic ecosystems. Support the discussion with peer-reviewed literature and current data. c. Provide a discussion regarding the assumption that if constituents remain below acute and chronic toxicity parameters, tainting potential levels, and CEBs, the ecological outcome will be a functional aquatic ecosystem. ESRD/CEAA Page 78 October 2014

81 Frontier Oil Sands Mine Project ESRD and CEAA Responses Water EPL water quality outcomes and noted constituent exceedances for aluminum, cadmium, molybdenum, selenium and strontium are largely attributed to process-affected seepage in the initial EIA. The SIR2 responses and update are not consistent with this and suggest these exceedances are due to natural inflows. d. Discuss why the source attribution has changed and whether the change influences the effects conclusions. e. Provide a discussion of the broader aquatic ecological connections that will be required for the development of functional, healthy, aquatic ecosystems in EPLs. f. Provide a discussion of limnological parameters of aquatic ecological importance to support the EPL predictions. Include; but, do not limit the discussion to seasonal chemoclines, thermoclines and DO gradients and whether they will result in reasonable habitat conditions throughout the depth profile of EPLs over the annual seasonal cycle. Discuss whether there will be seasonal exclusions of available habitat within the depth profile associated with known temperature, DO and chemical preferences of aquatic biota. g. Expand the discussion of EPLs to include potential aquatic biota behavioral or fitness responses, and expected outcomes for primary and secondary productivity, abundance and species composition. h. Discuss uncertainty. Response 12 As discussed in the response to AER Round 3 SIR 1, Teck intends to update the for the Project to: recover additional resource from leases acquired from Shell during the Teck Shell asset exchange optimize the tailings management strategy in consideration of the current state of engineering practice and improved understanding of site-specific conditions reflect additional engineering studies and information obtained from Shell as part of the asset exchange consider input received from regulators and potentially affected Aboriginal communities during the review process Portions of this SIR response will be re-evaluated as part of the Project Update; however, the following discussion provides appropriate and relevant context for the aquatics ecology and water quality portion of the assessment. October 2014 ESRD/CEAA Page 79

82 ESRD and CEAA Responses Water Frontier Oil Sands Mine Project a. The surface water quality and aquatic health assessments were carried out according to the requirements of the terms of reference (TOR) for the Project and other regulatory requirements, as explained in Volume 1, Section , Page 18-1 of the. These assessments examined the potential effects of the Project, in conjunction with other existing, approved and planned developments, on water quality and aquatic health. To this end, potential effects were evaluated on the watercourses and waterbodies directly or indirectly affected by the Project (i.e., those in the aquatics LSA), and on the watercourses and waterbodies affected by the Project along with regional developments (i.e., those in the aquatics RSA). To assess potential changes in water quality and aquatic health, existing conditions were compared to potential future conditions. Information about current conditions was acquired through field work and data publically available through government organizations and industry; potential future conditions were determined through predictive modelling. Potential changes in water quality and aquatic health were assessed at different snapshots in time representing different stages of the mine life. When potential changes in water quality parameters were found to exceed aquatic effects thresholds, these were carried forward to the aquatic health assessment, which evaluated potential effects on aquatic health and the environmental consequence of these changes. The assessment of effects considered Project-specific mitigation that Teck has incorporated into Project design (see Volume 5, Section , Pages 4-57 to 4-58 and Section , Page 4-168). The surface water quality and aquatic health assessments submitted as part of the Integrated Application, as well as in the response to SIRs (Rounds 1 to 3), met the level of assessment specified in the TOR for the Project since they considered multiple lines of evidence to determine potential effects. For example, based on the line of evidence of water, the Project, in combination with other oil sands developments, is predicted to have a negligible effect on acute and chronic toxicity and on tainting potential in receiving waters in the aquatics LSA and RSA (see Volume 5, Section , Page 4-212). Concentrations of some substances that exceeded guidelines and chronic effects benchmarks (CEBs) were carried forward to an aquatic health assessment for further evaluation. Potential effects on aquatic health were evaluated in consideration of predicted changes to surface water quality, including acute and chronic whole-effluent toxicity levels, sediment quality and fish tissue metal concentrations. Parameters such as metals and acute and chronic toxicity were modelled in surface water using conservative assumptions and considerations, and an uncertainty analysis was performed (see Volume 5, Appendix 4A) to gauge the level of confidence in predictions. Conservative assumptions and considerations were incorporated into the assessment; for example: Water quality measurements used to produce water quality probability distributions were often consistent and satisfied requirements of statistical tests for belonging to the same population (see Volume 5, Section 4.5.7, Page 4-95). Sink terms such as decay and settling in small streams were excluded from the model (see Volume 5, Section 4.5.7, Page 4-95), which leads to overestimates (i.e., conservatism) for some parameters. ESRD/CEAA Page 80 October 2014

83 Frontier Oil Sands Mine Project ESRD and CEAA Responses Water Predicted acute and chronic toxicity at the upper bound of the confidence interval (90 th percentile) in the uncertainty analysis were appreciably below threshold levels despite having a greater variability than naphthenic acids or total dissolved solids (see Volume 5, Appendix 4A). Predicted concentrations of total metals were compared to guidelines and CEBs that were derived mainly using dissolved and more bioavailable forms of metals. An increase of 10% in the predicted concentration of a substance from the Base Case to the Application Case was set as a screening level to detect meaningful change (see Volume 5, Section , Page 4-89). Together, these layers of conservative assumptions and considerations result in compounding conservatism, making it unlikely that effects on water quality and aquatic health will be underpredicted. This approach provides a conservative line of evidence in determining potential aquatic health effects. Because of varying water chemistry and flow rates of mine-related water releases and natural flows from undisturbed areas, substance concentrations in Ronald Lake, Redclay Creek and Big Creek might be affected (see Volume 5, Section , Pages 4-58 to 4-65). Concentrations of substances that exceeded guidelines and CEBs were carried forward to an aquatic health assessment for further evaluation. Therefore, the linkage for potential aquatic ecological effects on Ronald Lake, Redclay Creek and Big Creek applies to substances that were carried forward to the aquatic health assessment. Since chronic guidelines for the protection of aquatic life are the scientific estimates of no-effect thresholds or safe levels for a substance in question (ESRD 2014), and CEBs are sitespecific thresholds that are intended to be protective of the vast majority of species found at the site (see Volume 5, Section , Page 4-3), the linkage for potential aquatic ecological effects is considered invalid for substances that were not predicted to exceed guidelines or CEBs. This is also explained in the response to part c. Changes in sediment quality were also used to assess potential effects on aquatic health. As with water quality, the sediment quality model incorporated conservative assumptions and considerations. For example: The model assumed that the highest predicted water concentrations at surface water nodes remained high long enough to reach steady state with the sediment concentrations (see Volume 5, Section 4.8.2, Page 4-109). Individual polycyclic aromatic hydrocarbons (PAHs) in a PAH group were assigned the full concentration of the group under development scenarios even though each PAH group concentration is the sum of several individual PAHs (see Volume 5, Section 4.8.2, Page 4-109). Sediment quality modelling did not account for settling, sorption or degradation of PAHs that might occur before they reach the model nodes (see Volume 5, Section , Page 4-112). October 2014 ESRD/CEAA Page 81

84 ESRD and CEAA Responses Water Frontier Oil Sands Mine Project These conservative assumptions make sediment quality under-predictions unlikely (see Volume 5, Section , Page 4-112); therefore, the sediment quality model represents an appropriate line of evidence for aquatic health effects. Although Redclay Creek and Big Creek will receive flows from muskeg drainage, overburden dewatering or pit lakes that will contain process-affected waters (see Volume 5, Section , Page 4-111), only cadmium and mercury in Redclay Creek were predicted to exceed the interim sediment quality guideline (ISQG) and were carried forward to the aquatic health assessment (see Volume 5, Section , Page 4-111). As a result, the linkage for potential aquatic ecological effects on Redclay Creek is valid for cadmium and mercury, but is invalid for other substances in Redclay Creek, and is invalid for all substances in Big Creek. Mitigation strategies and commitments to support predictions (i.e., through monitoring, adaptive management and active treatment as necessary), were considered and discussed as part of the surface water quality and aquatic health assessments (see Volume 5, Section , Pages 4-57 to 4-58 and Section 4.5.9, Page 4-97) and in the responses to ERCB Round 1 SIRs 88a and 89b and ESRD/CEAA Round 1 SIR 405a. Based on the above, the conclusions of the water and sediment quality assessments are considered appropriate to support the conclusions of the aquatic effects assessment. b. Uncertainty with the conclusion that pit lakes will provide healthy, productive ecosystems stems from three main areas: the lack of an existing, functional oil sands pit lake, the accuracy of the model predictions and the biological responses to these predictions. Presently there are no fully functioning oil sands pit lakes that can be used to verify or compare predictions about long-term outcomes for Teck s pit lakes. To address this uncertainty, Teck is contributing to the ongoing research at Syncrude s Base Mine Lake (BML) and research at the planned COSIA Demonstration Pit Lake (DPL) facility. Also, as noted in the response to ESRD/CEAA Round 1 SIR 421a, in Alberta, there are several examples of pit lakes from the coal mining industry, including Quarry Lake near Canmore, East Pit Lake near Wabamun, Silkstone Lake, Lovett Lake and Lac des Roches near Hinton. As stated in the response to ESRD/CEAA Round 1 SIR 421a: Teck also has experience creating safe and healthy aquatic ecosystems, most particularly at the Cardinal River Mine in west-central Alberta and the Highland Valley Copper Mine in British Columbia. At Cardinal River (also known as the Luscar open pit coal mine), the Sphinx Lake open pit has been reclaimed to support Athabasca rainbow trout and bull trout. Lake and stream channel development began in 2005 and was completed in The five-year post-reclamation fisheries habitat and population assessment for Sphinx Lake indicates a surging rainbow trout population, high growth rates and enhanced habitat conditions, as compared with the pre-mine, cold-water, lotic system (Brinker et al. 2011). ESRD/CEAA Page 82 October 2014

85 Frontier Oil Sands Mine Project ESRD and CEAA Responses Water At Teck s Highland Valley Copper mine in central British Columbia, Teck has successfully reclaimed the Heustis Pit Lake and Trojan Tailings Pond to support fisheries resources. Aquatic plants and invertebrates were introduced, riparian vegetation was transplanted onto the shorelines, and the lakes were stocked with rainbow trout. Trojan Pond is now the location of an annual fly-fishing and icefishing derby that Teck sponsors, with all proceeds directed to the local hospital in Kamloops. Teck will incorporate knowledge obtained through its experience establishing these lakes into the design and closure of the Project pit lakes to provide a functional aquatic ecosystem and to minimize uncertainty associated with the absence of functional pit lakes in the oil sands region. Accuracy of the model predictions is affected by model structure, solution schemes, data inputs and calibration or parameter estimation (Beck 1987). Similarly, uncertainty exists in the biological responses to these predictions because not every dose, condition, species, or age can be tested. These uncertainties were mitigated by incorporating conservative assumptions (i.e., where present data or information are incomplete) and a range of adaptive management tools (i.e., where technologies are not fully proven). Uncertainty related to model structure and solution schemes is considered negligible since the water quality models are based on proven equations and solutions. For example the CE-QUAL-Q2 model that was applied to predict hydrodynamic behaviour in pit lakes has been applied hundreds of times worldwide in many types of aquatic systems and has been verified as predicting reasonably accurate representations of limnologic behaviour (Cole and Wells 2013; Portland State University 2014). However, inputs and parameters that affect the accuracy of water quality predictions in the pit lakes are not known with complete certainty. The uncertainty stemming from these sources is addressed by using conservative assumptions for water quality model inputs and parameters that minimize the likelihood that predictions will be under-estimated. For example: The upper range of seepage predictions, the shortest seepage travel times and the slowest available decay rates were used to predict constituent concentrations. This approach likely overestimates predicted concentrations, resulting in an additional level of protection for the environment. Uncertainty related to input data was examined using the Monte Carlo method and found to range within environmentally acceptable limits. The Monte Carlo analysis (see Volume 5, Appendix 4A, Section 4A.4.3) indicated that the 95th percentile concentrations for acute and chronic toxicity were below applicable water quality thresholds at the time of initial discharge and will remain so indefinitely. Therefore, prediction confidence is high that these thresholds will not be exceeded and that the pit lakes will provide a water quality that will support aquatic life. October 2014 ESRD/CEAA Page 83

86 ESRD and CEAA Responses Water Frontier Oil Sands Mine Project With respect to biological processes, many factors contribute to uncertainty with the prediction that pit lakes will provide healthy, productive aquatic ecosystems. Safe levels of chemical exposure are developed through the use of CEBs, which are based on extensive toxicity testing using multiple aquatic species from multiple trophic levels (see Volume 5, Appendix 4B). However, it is impractical to evaluate all species and life stages, in combination with all potential contaminants. As such, assumptions are made that the species and conditions evaluated are representative of the community and conditions encountered (Suter 1996). Uncertainty is therefore introduced when CEBs are used to protect species or life stages under conditions that were not specifically tested. Although CEBs will provide a level of protection for species within pit lakes, potential remains that some species, individuals or life stages might be more sensitive than those initially evaluated. This is mitigated somewhat by the conservative assumptions used to establish the CEBs (see Volume 5, Appendix 4B, Section 4B.2.1). Uncertainty is also introduced when laboratory tests are used to estimate toxicity in field conditions. Laboratory test waters can differ substantially from natural waters mainly due to the lack of ligands (i.e., an ion or molecule attached to a central metal atom by covalent bonding) that are present in natural waters (e.g., Stumm and Morgan 1981; Martino et al. 2003; Van Genderen et al. 2003; Stackhouse and Benson 1988). Major ions such as calcium and magnesium can affect uptake (and therefore toxicity) through competitive interaction at biological surfaces (e.g., gills), which can limit the uptake of potentially toxic substances (Playle 1998). The result is that laboratory tests are often conservative in predicting CEBs. Similarly, laboratory test waters typically do not mimic the natural levels of other ligands (e.g., dissolved and particulate organic matter). Some organic substances (e.g., naphthenic acids) have reduced bioavailability in natural waters because of their ability to complex with other ligands (e.g., Headley and McMartin 2004). In natural waters, this creates potential for reduced toxicity compared to laboratory tests. Dissolved organic matter includes humic and fulvic acids, which have been shown to have a profound effect on the bioavailability of many metals and reactive organic compounds (e.g., Paquin et al. 2002; de Schamphelaere and Janssen 2004). As a result, CEBs based on laboratory tests can overestimate effects concentrations if these factors have not been taken into account in designing the tests. Similarly, laboratory tests on single substances cannot readily account for the effects of multiple substances. The competitive interactions noted above can occur when multiple substances are present, with the result that the toxicological effects are not simply additive as is typically predicted from single substance toxicity tests. Uncertainty may also be associated with the initial conditions of CEB determination. Without a functional oil sands pit lake for reference, CEBs must be based on laboratory testing alongside existing data from in-situ and laboratory exposures conducted using related systems (e.g., Kavanagh et al. 2011; McNeill et al. 2012; van den Heuvel et al. 2012). Without specific knowledge of the conditions and chemical composition of established pit lakes, these inferences introduce a degree of uncertainty. These factors are further complicated by potential interactions between compounds and ESRD/CEAA Page 84 October 2014

87 Frontier Oil Sands Mine Project ESRD and CEAA Responses Water a lack of understanding regarding the mechanisms and specific causative agents involved (e.g., van den Heuvel et al. 2012; Kavanagh et al. 2013). This is particularly challenging for chemical mixtures because compounds may interact in additive, competitive or synergistic fashions. As a result, modelling effects and developing relevant CEBs that take these factors into consideration can be particularly difficult (Yang 1998; Feron and Groten 2002). However, the ongoing research at Syncrude s BML and research at COSIA s planned DPL will refine the conservative assumptions used in developing the CEBs. Furthermore, several approved pit lakes for other oil sands operations will be constructed before the Project s pit lakes are developed. These lakes will provide knowledge and data to refine the conceptual design of the Project s pit lakes. Syncrude s Base Mine Lake is the first pit lake being monitored and studied in the region. Canada s Oil Sands Innovation Alliance (COSIA) envisions a research facility on or near a mine site in the oil sands region, studying demonstration pit lakes and experimental ponds of various sizes and depths, and with different contents and water balances. Field data from these projects will provide information about the conditions, chemical composition and toxicology of pit lake water and sediment and will inform future model calibration for pit lakes. Although there are several sources of uncertainty that affect the accuracy of predictions and the assessment of biological responses to these predictions, these factors are largely mitigated though the use of the conservative assumptions and adaptive management practices. Using conservative estimates for modelling parameters and in defining CEB values minimizes the likelihood that predictions will be underestimated. The result is a high level of confidence in the conclusion that the pit lakes will be able to provide a healthy, productive aquatic ecosystem. c. Teck does not assume that if constituents remain below acute and chronic toxicity parameters, tainting potential levels and CEBs that the ecological outcome will be a functional aquatic ecosystem. Rather, Teck states that the Project pit lakes are expected to be able to support a viable aquatic ecosystem, and that this expectation is based on predicted water, sediment and fish tissue quality, along with the results of field and laboratory research (see Volume 5, Section , Pages 4-209). The federal and provincial governments both require that pit lakes eventually reach a state that can support aquatic habitat. However, pit lakes are engineered and other factors besides the quality of water and sediment will influence the colonization of species and the establishment of a functional aquatic ecosystem. The measurement endpoints listed above (i.e., toxicity, CEBs and tainting potential) represent one line of evidence regarding the ability of the Project s pit lakes to support a viable aquatic ecosystem. Water, sediment, and tissue quality predictions that meet the acute and chronic toxicity parameters, tainting potential levels and CEBs provide convincing evidence that there will be no toxicological impediment to colonization and establishment of an aquatic ecosystem in the pit lakes. This finding, combined with the additional evidence discussed below, provides a moderate to high degree of confidence in the prediction that the Project s pit lakes will be able to support a viable aquatic ecosystem. October 2014 ESRD/CEAA Page 85

88 ESRD and CEAA Responses Water Frontier Oil Sands Mine Project Additional evidence that supports this moderate to high degree of confidence comes from the considerable amount of literature on pilot systems that demonstrate the ability of pit lakes to support aquatic life. As discussed in Volume 5, Section , Pages to 4-209, and in Section of the 2012 End Pit Lakes Guidance Document (CEMA 2012), studies conducted in experimental pit lakes have shown colonization, growth and survival of macrophytes (Crowe et al. 2002), phytoplankton (Harris 2001; Hayes 2005; Leung et al. 2003; MacKinnon and Boeger 1986), zooplankton (MacKinnon and Boeger 1986; McCormick 2000), benthic invertebrates (Leonhardt 2003; MacKinnon and Boeger 1986), amphibians (Gupta 2009; Hersikorn 2009; Hersikorn et al. 2010; Hersikorn and Smits 2011), aquatic birds (Smits et al. 2000) and fish (van den Heuvel et al. 1999a, 1999b; Siwik et al. 2000). Chapter 6 of the 2012 End Pit Lakes Guidance Document concludes that a range of trophic levels organisms may be sustainable in pit lakes, although not necessarily at the abundance and breadth of biodiversity observed in natural lakes in the region. As discussed in Volume 5 Section , Pages to 4-178, the pit lake hydrodynamic and water quality predictions were generated using a model developed specifically for pit lakes. The model uses equations that are well known, documented and specific to pit lake processes. Moreover, the water quality predictions for pit lakes are based on conservative assumptions such as no settling or precipitation and low decay rates of mine-related inputs. Although there are uncertainties in inputs and processes leading to a low confidence in the predictions, the risk of under-predicting concentrations is also low given the conservative assumptions that are included. The 2012 End Pit Lakes Guidance Document acknowledges although models are very important in the design of [end pit lakes] EPLs, the ultimate measure of the success of failure of an EPL will be determined through a robust and long-lived monitoring program. Therefore, although the assessment (see Volume 5, Section 4.13, Page 4-212) indicates that changes in surface water quality as a result of the Project will be negligible to low, ongoing monitoring of water quality in the pit lakes and receiving environment will be conducted to confirm these predictions, and additional mitigation measures will be implemented at appropriate locations in the event that surface water quality does not meet required standards. For example, water in pit lakes could be treated to promote biological productivity or chemical activity and to enhance precipitation, settling and removal of substances. Management and monitoring of water quality, sediment quality and pit lake water quality is discussed in the assessment (see Volume 5, Section 4.5.9, Page 4-97 [water quality]; Section 4.8.9, Pages to [sediment quality] and Section , Pages to [pit lake water quality]). As stated in the response to ESRD/CEAA Round 2 SIR 128b: Teck and Shell are presently leading a separate project as part of the COSIA process to design and construct a number of field-scale demonstration pit lakes in the oil sands region. The project will create waterbodies that have similar water quality characteristics to pit lakes that are proposed regionally. ESRD/CEAA Page 86 October 2014

89 Frontier Oil Sands Mine Project ESRD and CEAA Responses Water The objective of this project will be to demonstrate the feasibility of using pit lakes, at the field scale, to treat oil sands process-affected water (OSPW) and other oil sands-related waters, and of creating functioning aquatic ecosystems in reclamation waterbodies. Similarly: Teck is participating in Syncrude s Base Mine Lake COSIA Joint Industry Project, which is the first demonstration oil sands pit lake. This project will monitor and evaluate water quality conditions in a full-scale oil sands pit lake as it develops into an aquatic system. These projects will provide the necessary information to address knowledge gaps over the next two decades. The pit lakes that are contemplated for the Project will be developed decades after these research projects and pit lakes in other operations have been constructed. This will allow Teck the opportunity to test the experimental hypotheses for the demonstration pit lakes, to verify the performance of actual pit lakes, and to incorporate this knowledge in the design and operation of the Project s pit lakes. The outlined research plan is considered adequate to support the proposed reclamation strategies that involve OSPW wetlands and pit lakes. d. As indicated in the response to ESRD/CEAA Round 2 SIR 31a, the reasons for specific outflow water quality trends in pit lakes vary by constituent and by pit lake. However, upward trends over the long term are typically the result of inflows from natural sources. As described in Volume 5, Section 4.5.3, Pages 4-33 to 4-34 and responses to ERCB Round 1 SIRs 78c and 79a and ESRD/CEAA Round 1 SIR 89a, waters in the aquatics LSA are known to be high in several total metals. These concentrations are probably associated with naturally occurring high TSS associated with erosion of the polymetallic black shales that outcrop on the Birch Mountains west of the Project. Over time, as the initial waters are flushed from the pit lakes, the water in the pit lakes will tend to resemble these inflow sources. In the case of cadmium and strontium in central pit lake A (CPLA), concentrations are predicted to exceed CEBs in 2068 primarily because of the direct input of process-affected water. In 2157, cadmium and strontium concentrations are predicted to be higher than CEBs primarily because of process-affected seepage from the reclaimed landscape (see Volume 5, Section , Page 4-175). Likewise, concentrations of cadmium, molybdenum, selenium and strontium are predicted to exceed CEBs in central pit lake B (CPLB) mostly because of process-affected seepage from the reclaimed landscape (see Volume 5, Section , Page 4-17). In the case of aluminum (and several other total metals), the predicted elevated concentrations in both pit lakes are expected to result from natural inflows. Additional detail about pit lake characteristics and flow rates was provided in response to ESRD/CEAA Round 1 SIR 45, Appendix 45a.7, Table As Table 4-28 shows, CPLA s two major sources of water during filling are the Athabasca River and tailings pond water. Athabasca River water and tailings water are both high in total metals (see Volume 5, Appendix 4A, Section 4A.3). October 2014 ESRD/CEAA Page 87

90 ESRD and CEAA Responses Water Frontier Oil Sands Mine Project Seepage water that will be pumped to CPLA and the revised groundwater seepages resulted in increased concentrations of most constituents, but these increases did not cause additional constituents to be above CEBs (for details, see the response to ESRD/CEAA Round 1 SIR 45a, Appendix 45a.7). In addition, the revised groundwater seepage rates resulted in increases or decreases of some constituent concentrations in CPLB; however, these changes in concentrations did not change the list of constituents that are above screening criteria. Although no additional constituents were predicted to be above CEBs in pit lakes, the revised concentrations (i.e., those that were predicted to be above CEBs) were re-evaluated for effects on aquatic health (see the response to ESRD/CEAA Round 1 SIR 45a, Appendix 45a.7, Section 4.12). The revised aquatic health assessment of pit lakes resulted in no changes to the conclusions presented in the regarding aquatic health effects. As mentioned in the response to ERCB Round 1 SIR 88a, Teck has several adaptive management strategies available during the filling of the pit lakes. These strategies include monitoring source waters and active or passive treatment of these source waters as needed, for pit lake water quality to meet water quality standards. e. The development of functional, healthy, aquatic ecosystems in pit lakes will depend on the physical, chemical and biological processes that occur in the lakes (CEMA 2012). There are currently no fully commissioned oil sands pit lakes. Therefore, research on the physical, chemical and biological processes in natural lakes, other pit lakes and oil sands experimental and reclamation wetlands, along with established modelling approaches, are used to predict how these processes will influence pit lakes. Factors that will affect broader aquatic ecological connections and development of functional, healthy, aquatic ecosystems in pit lakes are described below. LAKE MIXING The vertical mixing regime of pit lakes will determine key ecological functions and connections. Vertical mixing is influenced by meteorological conditions and physical characteristics of the waterbody such as depth, fetch, bottom profile, temperature and residence time (Wetzel 2001). Vertical mixing transports oxygen from the upper portion of the lake to the lower portion, which can affect other processes such as degradation of naphthenic acids (Herman et al. 1994; Scott et al. 2005). In most temperate lakes, thermal stratification occurs on a seasonal basis (i.e., they are holomictic). Turnover and mixing of the water is caused when the top layer of the water column becomes as dense as or denser than the bottom layer. Pit lakes (especially non-oil sands pit lakes, which are typically much deeper and have smaller fetch) have potential to be meromictic because of the steep slope of the shoreline, their depth and the high salt concentrations that typically characterize many mine pits (Castro and Moore 2000; Boehrer and Schultze 2006). High salt concentrations, which ESRD/CEAA Page 88 October 2014

91 Frontier Oil Sands Mine Project ESRD and CEAA Responses Water could intrude into the deep layers of some pit lakes, can lead to a salinity-driven density gradient that causes meromixis (CEMA 2012). To examine the relevance of meromixis to pit lakes, Golder (2004, 2007) conducted modelling studies that evaluated the full range of physical and chemical properties of planned pit lakes. These studies showed that as the depth, initial salinity and inflow rate of the pit lake increased, the probability of meromixis also increases. However, the probability of meromixis occurring over a long time period was low because of a lack of constant salt input (Golder 2004, 2007). This same modelling was applied to Teck s pit lakes to evaluate vertical mixing. As reported in the assessment (see Volume 5, Section 4.11, Pages to 4-180), Teck s pit lakes are predicted to be holomictic. Adaptive management can be used to reduce the potential for meromixis in pit lakes. Strategies include increasing lake filling time, reducing the proportion of process-affected water to prevent chemical stratification, controlling total dissolved solids concentrations in the lake or inflow to reduce salinity, using mechanical mixing, or installing air diffusers (Golder 2007; CEMA 2012). CHANGES IN WATER LEVEL Littoral communities are strongly influenced by seasonal fluctuations in water levels and support species that have adapted to a broad range of moisture levels (Lahring 2003). The vegetation along the littoral zone supports important ecological functions including providing habitat for fish and benthic invertebrates, stabilizing the shoreline and filtering run-off (Lahring 2003). Extreme changes in water levels can result in changes in the littoral communities and reduce the productivity of the littoral zone (Leira and Cantonati 2008). The water balance in Teck s pit lakes will be maintained with sufficient inflows to compensate for evaporative losses (see Volume 5, Section 4.11). The conceptual closure drainage systems have been designed to be self-sustaining over the long-term and have characteristics (such as water level fluctuation) similar to natural drainage systems (see Volume 5, Section 3.5.5, Pages 3-42 to 3-66). SEDIMENT TRANSPORT Re-suspension of sediment into the water column is another factor that can affect water quality and might influence the ability of a pit lake to support aquatic life (CEMA 2012). Re-suspension of sediment can increase TSS, influence light penetration and have adverse effects on aquatic organisms. Erosion of the closure landscape and the risk of slumping of pit lake walls are also potential contributors to sedimentation in pit lakes. Post-closure sediment yields from the reclaimed areas and drainage systems upstream of the pit lakes are expected to be comparable to similar natural systems because the closure landscape and drainage systems will be designed and constructed following a fluvial geomorphic approach. In addition, any wind- or flood-induced erosion along the shorelines of the pit lakes post-closure is expected to exhibit similar characteristics as natural lakes October 2014 ESRD/CEAA Page 89

92 ESRD and CEAA Responses Water Frontier Oil Sands Mine Project because the lake shorelines will be stabilized with native vegetation and granular materials for erosion control. LITTORAL ZONE The littoral zone of a waterbody is the interface zone between the land and the open water, between the highest seasonal water level and the lowest area of submerged vegetation (Wetzel 2001). The development of a healthy and functional aquatic ecosystem in a pit lake will depend on a healthy and productive littoral zone. Littoral zones are shallow, high in nutrients, and provide habitat for fish for foraging, reproduction and refuge from predators (CEMA 2012). The littoral zone influences the productivity of the lake, so its design features are critical. A common commitment for oil sands pit lakes is to have 10% to 30% of the surface area designated as a littoral zone, which is predicted to result in a medium to high probability of sustaining salmonid populations (Shell 2007; CEMA 2012). The Project s pit lakes will be designed to have an appropriately sized littoral zone (see Volume 5, Section 4.11, Pages to 4-180). Productivity of the littoral zone will depend on light penetration. The design of the littoral zone must therefore consider the depth of the euphotic zone, which is influenced by water clarity. Productivity of the littoral zone can be limited by the organic component of the sediment, nutrient concentrations and the substrate density (Moeller et al. 1988; Chambers et al. 2001). Shoreline complexity and shoreline stability are important factors in the design of littoral zones (CEMA 2012). A variety of habitats along the shoreline will promote biodiversity, and high biodiversity promotes greater resiliency of the ecosystem to an environmental disturbance (Hooper et al. 2005). Protection from wave action can be achieved by creating littoral zones in embayments or using breakwaters (CEMA 2012). Littoral and riparian vegetation can serve as protection from erosion and increase habitat along the shoreline. The Project s pit lakes will be designed to have an adequate littoral zone to support functional, healthy, aquatic ecosystems. The littoral zones will be constructed using clean reclamation materials so sediment quality in the littoral zone will initially be similar to clean soils. Shallow areas (e.g., nearby wetlands) can be connected to the pit lake to serve the function of littoral areas, if required (CEMA 2012). If nutrient concentrations limit primary production, then adaptive management solutions can be employed to augment the nutrient status (e.g., adding sediment to increase organic content or adding nutrients). HABITAT Macroinvertebrate abundance and distribution are related to the abundance of submerged vegetation, substrate characteristics, sediment and water quality, and the morphology of the lake. Vegetation provides a substrate and habitat for benthic invertebrates. Particle size and organic content of the substrate can affect the suitability of the habitat (Minshall 1984). Changes in water quality and ESRD/CEAA Page 90 October 2014

93 Frontier Oil Sands Mine Project ESRD and CEAA Responses Water sediment quality have been shown to occur in wetlands exposed to oil sands process-affected materials. Specifically, these wetlands have been shown to have reduced density and species diversity relative to reference wetlands (Bendell-Young et al. 2000). To achieve a functional ecosystem, lower trophic levels must be established before the introduction or colonization of fish populations. As discussed in the response to part b, the predicted water quality of the Project s pit lakes has been assessed, including their potential to support a productive ecosystem. Independent lines of evidence presented in the assessment indicate that conditions will be adequate. Likewise, winter dissolved oxygen is known to be a limiting factor in northern aquatic ecosystems given the lack of aeration between November and April. Dissolved oxygen is predicted to be adequate year-round in the top 40 m of the Project s pit lakes (for details, see the response to part f). An important habitat requirement for the establishment of fish populations is aquatic vegetation that provides spawning substrate and habitat for rearing and protection. Spawning substrates such as cobble and gravel are also important for the establishment of fish populations. Littoral area design will incorporate the appropriate habitats at the preferred spawning depths for target fish species at the detailed design stage. WATER QUALITY The primary issue related to pit lake water quality is the degradation of constituents of oil sands process-affected water (OSPW). OSPW will be a component of the pit lakes through direct transfers and passive migration of OSPW from the reclaimed landscape runoff and tailings seepage. OSPW constituents influencing pit lake water quality are mostly dissolved organics and salinity, although water quality might also be affected by chemical transformations that occur in anaerobic sediments (CEMA 2012). Iron and manganese can become reduced in anaerobic sediments, releasing phosphorus (bound to these metals), which can promote nutrient enrichment (Wetzel 2001). The cycling of nitrogen, sulphur, silica and other metals are also influenced by the redox status of sediments, which can influence the concentrations of these analytes in the water column (DiToro 2001; CEMA 2012). Mitigation measures will be implemented to maximize the function of the pit lakes and to maintain water quality within the appropriate targets (see the response to ESRD/CEAA Round 1 SIR 88). For example: Pit lakes will exclude tailings and the rate of Athabasca River water input will be managed to ensure that the water quality filling targets are met. The size and efficiency of wetlands that route reclamation drainages to the pit lakes can be increased, if required. Water quality of outflows can be treated actively or passively, as needed, by adding wetlands and settling basins to the discharge channels that connect the pit lakes to the receiving waters. October 2014 ESRD/CEAA Page 91

94 ESRD and CEAA Responses Water Frontier Oil Sands Mine Project FIELD STUDIES Researchers at Syncrude and the University of Waterloo created experimental ponds containing fluid fine tailings (FFT) with both OSPW and freshwater capping layers and studied their success in establishing functional aquatic ecosystems (CEMA 2012). Benthic invertebrate density and diversity were reduced in the experimental ponds compared to reference systems for all species except chironomids, which are stress tolerant (Whelly 1999; Bendell-Young et al. 2000). Over time, the total densities of benthic invertebrates were similar to lakes in the region, but community composition differed (Leonhardt 2003; Barr 2009). It may take seven years or longer for a benthic community to develop to be similar to a reference wetland (Leonhardt 2003). The development of a productive benthic invertebrate community will be necessary to support higher trophic level species such as fish. Studies conducted at the Syncrude experimental ponds showed that even when water caps were primarily OSPW, phytoplankton populations established quickly (Hayes 2005) and, in some cases, algal blooms were observed. The presence of FFT below the water cap did not influence phytoplankton. Water caps were able to support primary productivity comparable to reference systems (Harris 2001). Fresh OSPW has been shown to pose a threat to zooplankton communities depending on the life cycle of the species (McCormick 2000). High concentrations of TSS, total dissolved solids, and naphthenic acids that are typical of OSPW reduce success and will bias the zooplankton community towards more tolerant species. Lower abundance and diversity were observed in experimental ponds relative to reference systems. Amphibians are known to be sensitive to pollution and habitat stress (Wyman 1990). The results of the first field studies assessing the potential success of tadpoles in reclamation wetlands concluded that pit lakes could not support amphibians (Pollet and Bendell-Young 2000). This study was conducted in a habitat that was continuously exposed to fresh OSPW. A more appropriate habitat would be a pit lake with aged OSPW and a freshwater cap. Follow-up studies have shown that tadpole survival and metamorphosis in reclamation wetlands older than seven years were similar to reference systems and that amphibian success in pit lakes is possible (Hersikorn 2009; Hersikorn et al. 2010; Hersikorn and Smits 2011). One of the objectives of pit lake design for stakeholders is for the pit lake to support large-bodied fish (CEMA 2012). Initially, OSPW might be toxic and limit the success of fish populations because of concentrations of naphthenic acids, ammonia, and the salinity of OSPW. Over time, the concentrations of these substances will decrease, although effects on fish reproduction and the potential of tainting might persist (Rodgers et al. 2007; Young et al. 2007, 2008, 2011). Studies have been conducted on the effects of FFT and OSPW on fathead minnows. For example, Siwik et al. (2000) found no significant differences in the growth and survival of fathead minnows in laboratory tests with concentrations of naphthenic acids 5 to 10 times the concentrations expected in pit lakes. ESRD/CEAA Page 92 October 2014

95 Frontier Oil Sands Mine Project ESRD and CEAA Responses Water In field tests, no significant differences in survival were observed, although a significant difference in growth was detected in exposure fathead minnows relative to reference organisms (Siwik et al. 2000). Kavanagh et al. (2011) suggest an effects threshold of 25 mg/l for aged naphthenic acids for fathead minnow reproductive impairment based on laboratory tests using OSPW. This concentration is two to four times greater than the predicted concentrations for pit lakes. Yellow perch were introduced into an experimental pond containing water-capped FFT and another pond containing bitumen-bearing sodic clay and the perch reproduced successfully (van den Heuvel et al. 1999a, 1999b). The perch and their offspring exhibited physiological stresses such as reduced immune function, but had increased nutrition given the abundance of food and lack of predators. Similar experiments were conducted in the same ponds in 2009 (van den Heuvel et al. 2012). The pond that contained tailings had a two-fold increase in salinity, alkalinity and naphthenic acids and ph increased from 8.4 to 9.4. The second pond had no changes in total dissolved solids, major ions, or ph and naphthenic acid concentration were reduced more than two-fold. Male perch in the pond that contained tailings showed reductions in testicular development and circulating testosterone and 11-ketotestosterone and no effects were observed on males in the other pond or on females (van den Heuvel et al. 2012). These field studies provide evidence that pit lakes containing FFT and OSPW can support aquatic ecosystems. The Project s pit lakes will not contain tailings and are expected to have lower concentrations of naphthenic acids relative to these field studies. In addition, these concentrations are expected to decrease over time because naphthenic acids aerobically decay over time (see Volume 5, Section 4.3.4, Pages 4-16 to 4-17). PIT LAKE CONNECTIVITY TO THE CLOSURE SYSTEM The long-term success of a pit lake will be achieved by incorporating the lake into a closure system and the regional watershed that leads to a functional open system. Integration of the pit lake to an open system will involve connections to natural watercourses, other reclaimed habitats and ultimately a connection to the Athabasca River. Successful integration to an open system includes supporting upper trophic level species such as large-bodied fish. Natural colonization of aquatic biota to the pit lakes is expected to occur and will be influenced by the presence of physical barriers (e.g., beaver dams or vertical drops with high water velocities) or the presence of limited water connectivity as occurs naturally. Water quality is not expected to be a limiting factor for establishing fish populations as discussed in the aquatic health assessment (see Volume 5, Section 4.12, Pages to 4-212) and in response to ESRD/CEAA Round 1 SIR 45a, Appendix 45a.7, Section October 2014 ESRD/CEAA Page 93

96 ESRD and CEAA Responses Water Frontier Oil Sands Mine Project f. As stated in Volume 5, Section , Pages to 4-176, all the Project s pit lakes (i.e., North pit lake, CPLA and CPLB) will become thermally stratified seasonally and mix vertically at least once a year, which is typical for lakes in temperate regions. Monthly vertical profiles of water temperature are presented for CPLA (see Volume 5, Section , Figure 4-25, Page 4-170). Temperature profiles were presented only for CPLA because it is the Project s deepest pit lake and it will receive process-affected water. As a result, it represents worst-case conditions in terms of meromictic potential. Among the three pit lakes, only the North pit lake (NPL) will not receive direct inputs of process-affected water. Temperature profiles for CPLB and NPL are provided in Figures 12f-1 and 12f-2. According to the predicted temperature profiles, NPL follow a pattern of thermal stratification similar to CPLA, which has two turnovers (typically occurring in April and October). Water temperature in the bottom layer of NPL and CPLA is predicted to be constant throughout the year. CPLB is predicted be more wellmixed than CPLA and NPL because it is more shallow. CPLB is predicted to become a polymictic lake. Temperature in pit lakes is predicted to be suitable for aquatic biota throughout the year because it is expected to be well below acute temperature criteria for regional sport fish (i.e., below 22 C) (Taylor and Barton 1991). The temperature profiles in Figures 12f-1 and 12f-2 indicate that the pit lakes will have epilimnion water temperatures of approximately 11 C during the summer months. This will provide moderately suitable habitat for the longnose sucker (Golder 2008), white sucker (Twomey et al. 1984) and northern pike (Inskip 1982), and thermally suitable habitat for Arctic grayling (Golder 2008). The temperature provides low habitat suitability for walleye in summer (Golder 2008). Near the lake beds, concentrations of dissolved oxygen (DO) are predicted to decrease because of sediment oxygen demand. This process also occurs in natural lakes. DO profiles are presented in Figures 12f-3 to 12f-5. For NPL, the predicted DO levels show that the water is expected to be well oxygenated (i.e., DO concentrations above the minimum chronic guideline of 6.5 mg/l) throughout the year at all depths, and therefore will be sufficient for aquatic life. For CPLA, in the 8 m of water layer at the bottom of water column, DO concentrations are predicted to be less than 6.5 mg/l throughout the year. As a result, this part of the water column will be less suitable for aquatic biota. However, this portion of the lake is more than 40 m deep, and other factors such as light limitation would reduce the suitability of this part of lake as habitat. The top 40 m of water in CPLA is predicted to have sufficient DO levels for aquatic life. This vertical mixing and surface aeration is similar to that of other large lakes in the region such as Cold Lake and Lake Athabasca (Golder 2007), both of which support a diverse fish community. In CPLB, the whole water column is predicted to have DO concentrations higher than 6.5 mg/l except a 1 m layer of water at the bottom of the lake in August and September. ESRD/CEAA Page 94 October 2014

97 Frontier Oil Sands Mine Project ESRD and CEAA Responses Water Chambers and Mill (1996) recommend minimum DO levels of 6.0 mg/l for salmonid species and 5.0 for non-salmonid species in the oil sands region. The DO levels in the three pit lakes are predicted to be greater than 6.0 mg/l in most of the water column throughout the year. In the pit lakes, mainly in CPLA, chemical stratification will establish seasonally when processaffected seepage and saline groundwater enter the lakes while they are thermally stratified. Figures 12f-6 to 12f-8 show TDS profiles for the pit lakes during a typical year. After each turnover event, concentrations of TDS in NPL and CPLB are predicted to be homogeneous throughout the water column. In CPLA, the turnover is not predicted to fully mix the high TDS water at the bottom of the lake, but the TDS gradient will decrease after each event. Most of the water column in all three lakes will have relatively constant TDS during the year, and the seasonal higher-tds layer is predicted to be located at the bottom of the lakes with depth of 5, 10 and 2 metres for NPL, CPLA and CPLB, respectively. As described in the response to ESRD/CEAA Round 1 SIR 45a, Appendix 45a.7, Section 4.11, detailed water chemistry was predicted for two layers in each pit lake. The assessment assumed full mixing within each layer, and concentrations of the modelled constituents are not predicted to be notably different between the two layers. Potential effects associated with guideline exceedances were rated as being low in magnitude (see the response to ESRD/CEAA Round 1 SIR 45a, Appendix 45a.7, Section ). In summary, the temperature profiles for each of the Project pit suggest that the lakes will provide suitable habitat to relevant fish species. As well, most of the water column in all three pit lakes is predicted to meet DO guidelines. Evaluation of these limnological parameters supports the assessment conclusion that the pit lakes are expected to have the capability to support a viable aquatic ecosystem by the time they begin discharging to the surrounding environment and into the far future (see Volume 5, Section , Page 4-212). October 2014 ESRD/CEAA Page 95

98 ESRD and CEAA Responses Water Frontier Oil Sands Mine Project Figure 12f-1 Temperature Profiles for North Pit Lake (Typical Year) ESRD/CEAA Page 96 October 2014

99 Frontier Oil Sands Mine Project ESRD and CEAA Responses Water Figure 12f-2 Temperature Profiles for Central Pit Lake B (Typical Year) October 2014 ESRD/CEAA Page 97

100 ESRD and CEAA Responses Water Frontier Oil Sands Mine Project Figure 12f-3 Dissolved Oxygen Profiles for North Pit Lake (Typical Year) ESRD/CEAA Page 98 October 2014

101 Frontier Oil Sands Mine Project ESRD and CEAA Responses Water Figure 12f-4 Dissolved Oxygen Profiles for Central Pit Lake A (Typical Year) October 2014 ESRD/CEAA Page 99

102 ESRD and CEAA Responses Water Frontier Oil Sands Mine Project Figure 12f-5 Dissolved Oxygen Profiles for Central Pit Lake B (Typical Year) ESRD/CEAA Page 100 October 2014

103 Frontier Oil Sands Mine Project ESRD and CEAA Responses Water Figure 12f-6 TDS Profiles for North Pit Lake (Typical Year) October 2014 ESRD/CEAA Page 101

104 ESRD and CEAA Responses Water Frontier Oil Sands Mine Project Figure 12f-7 TDS Profiles for Central Pit Lake A (Typical Year) ESRD/CEAA Page 102 October 2014

105 Frontier Oil Sands Mine Project ESRD and CEAA Responses Water Figure 12f-8 TDS Profiles for Central Pit Lake B (Typical Year) October 2014 ESRD/CEAA Page 103

106 ESRD and CEAA Responses Water Frontier Oil Sands Mine Project g. The following is a summary and a qualitative evaluation of the potential aquatic responses, species composition and abundance and expected productivity outcomes that could occur in pit lakes. In general, ecosystem development in pit lakes will be a function of how water quality and physical habitat characteristics change over time. Water quality is expected to be initially characterized by elevated salinity and naphthenic acids concentrations and low DO levels, which are likely to result in low species diversity in pit lakes. As described in Volume 5, Section 4.13, Page 4-212, these conditions are expected to improve over time and be suitable for aquatic life by the time pit lakes begin discharging to the surrounding environment. SPECIES COMPOSITION AND ABUNDANCE AQUATIC VEGETATION The aquatic vegetation found in the on-shore area of pit lakes will experience changes in the community structure and species composition. Fluctuations in water level, water chemistry and soil elevation are likely to have the greatest influence on the species found in and around the pit lake as the system moves through different phases of development. Studies of experimental ponds in northern Alberta have shown that species are able to establish and grow in processed water (Pouliot et al. 2012; Rezanzhad et al. 2012). However, it is expected that species richness will likely be lower than in natural wetlands. However, as the pit lake develops, physical conditions will progress, the water levels will stabilize, and soils near the lake and edge will reach full saturation. As the lake water level stabilizes, the emergent zone and wet meadow zones are likely to become more defined, thereby enhancing species diversity (Trites and Bayley 2009). The following are lists of plant species that are expected to establish (Trites and Bayley 2009; Crowe et al. 2002; Pouliot et al. 2012), and these species are likely to be observed during different phases of lake development. Expected emergent vegetation species include, but are not limited to: swamp horsetail (Equisetum fluviatile) marsh horsetail (Equisetum palustre) rushes (Juncus tenuis and Juncus spp.) common cattail (Typha latifolia) common great bulrush (Schoenoplectus tabernaemontani) pondweed species (Potamogeton spp.) Expected wet meadow vegetation species include, but are not limited to: water sedge (Carex aquatilis) fowl bluegrass (Poa palustris) slough grass (Beckamnnia syzigachne) ESRD/CEAA Page 104 October 2014

107 Frontier Oil Sands Mine Project ESRD and CEAA Responses Water seaside arrow-grass and slender arrow-grass (Triglochin maritima and T. palustris) creeping spike-rush (Eleocharis palustris) awned sedge (Carex atherodes) narrow reed grass (Calamagrostis stricta) AQUATIC MACROPHYTES For growth of aquatic macrophytes in pit lakes, the physical conditions of the sediments (e.g., texture and firmness), the organic content and the slope of the shoreline are essential (Duarte and Kalff 1986; Barko et al. 1991). Salinity is another essential physical variable for macrophyte growth; if elevated, salinity can limit successful colonization. Experimental pond studies have shown that macrophyte growth and rates of germination were inhibited by salinity (Crowe et al. 2002; Pouliot et al. 2012). However, limited growth was observed only at levels that exceed those predicted for the Project s pit lakes. Another study investigated the salt tolerance of three macrophyte species and observed that they did not react equally well to brackish water (Harris 2001). Stonewort (Chara spp.) was the most resilient, possibly because of the protective calcium coat it carries in its cell walls, while pondweed was considered the most sensitive to the brackish conditions (Luong 1999). Light availability is also essential for aquatic organism survival. Because vegetation is limited in near-shore areas, it is expected that pit lakes will have increased turbidity, thereby reducing light availability to the pit lake. However, it is anticipated that within two years, vegetation will become present in the near-shore zones of the pit lakes, which can be expected to reduce turbidity and more closely resemble a natural lake (CEMA 2012). As the lake ages, the accumulation of organic matter will increase the supply of nutrients in the sediments. These nutrients will be available for macrophyte growth and will improve the physical environment required to support macrophytes. As the lake ages and nutrients accumulate in the sediments, macrophyte production will increase in these areas, but physical habitat limitation is expected to persist, thereby preventing abundant macrophyte growth. PHYTOPLANKTON Phytoplankton is expected to be the first aquatic organisms to colonize pit lakes. Studies have shown that in process-affected waters, high nutrient concentrations and light availability allowed rapid establishment of phytoplankton population (Hayes 2005). Additional studies have shown that cap waters in experimental ponds will eventually be able to support a level of primary productivity similar to those observed in natural systems, but with differences in phytoplankton diversity and species composition. October 2014 ESRD/CEAA Page 105

108 ESRD and CEAA Responses Water Frontier Oil Sands Mine Project Studies have identified a small number of tolerant algal species with process-affected water (Harris 2001), which are: Botryococcus braunii Cosmarium depressum Gloeococcus schrosteri Navicula radiosa Oocystis crassa the genera Keratococcus and Ochromonas Harris (2001) showed that the age of the ponds was important for developing phytoplankton communities largely because of the time required for the degradation of naphthenic acids and dilution of salts. Experimental ponds constructed with mature fine tails and natural cap waters were able to support phytoplankton communities similar to that of local natural lakes within about five years. ZOOPLANKTON Several physical, chemical and biological factors influence the health of zooplankton communities in pit lakes (Harris 2001). Studies have shown that naphthenic acids, salinity and TSS concentrations all influence the development of zooplankton communities. It is anticipated that during the initial phases of the pit lakes, the number and abundance of zooplankton will increase slowly. Leung et al. (2003) found that after 12 months, zooplankton densities in processed-affected water began to increase. There is much uncertainty regarding zooplankton communities and their long-term development in pit lakes. Monitoring would be essential to better understand the key influencing factors on zooplankton development. BENTHIC INVERTEBRATES During the initial development of the end pit lakes, limited colonization of benthic invertebrates is anticipated. Water quality will be unsuitable for benthic community establishment during the early start-up phase of pit lake development because of high naphthenic acids concentrations, turbidity and salinity, and low DO concentration. It has been suggested that it will take approximately three years to maximize benthic invertebrate densities in constructed pit lakes (Harris 2001). Highly tolerant benthic invertebrates, which could potentially survive in a pit lake during the early years after filling, include some species of midges and aquatic worms (Oligochaeta spp.). Although midges will be able to colonize as adults depositing eggs, aquatic worms will not be able to disperse without a connection to natural surface or seeding. ESRD/CEAA Page 106 October 2014

109 Frontier Oil Sands Mine Project ESRD and CEAA Responses Water FISH Literature suggests that fish may be able to establish in pit lakes. However, this will not occur until several years after the initial start-up phase, once naphthenic acids concentrations decline to nonacutely toxic levels and water quality improves to a point where lower trophic communities can establish. The success of forage fish in pit lakes will depend on the adequate development of lower trophic communities. The diversity and abundance of forage fish will depend on lake productivity, and the extent of emergent and submerged macrophyte beds. Based on available information, fathead minnow (Pimephales promelas) is a species native to the oil sands region and is a suitable forage fish species to be stocked in a pit lake or allowed to colonize at the appropriate time. Fathead minnows have been shown to survive and thrive in water-capped fluid fine tailings (FFT) pits (Siwik et al. 2000). Another forage fish species that will likely colonize pit lakes is brook stickleback (Culaea inconstans). Brook stickleback is a widespread species throughout the oil sands region and is tolerant of a wide range of environmental conditions. A study conducted at Loon Lake, located on the Suncor oil sand mining site and a former open pit mine that was filled approximately 25 years ago, showed that the lake was able to support a brook stickleback population (Farrell et al. 2004). Once the forage fish community has established and stabilized in a pit lake, the lake will be suitable for stocking larger sport fish, or allowing them to colonize from inflowing waters. The management of sport fish in the Project s pit lakes will be considered in consultation with stakeholders and regulators during the detailed design and certification phases of the Project. PRODUCTIVITY OUTCOMES Ecosystems that develop in pit lakes will be the result of complex interactions between physical, chemical and biological features in the aquatic and terrestrial environments. The general consensus based on experimental studies of demonstration ponds and reviews of the pit lakes, is that pit lakes are viable reclamation features and, if properly designed and managed, will eventually develop aquatic ecosystems that resemble natural lake ecosystems (CEMA 2012). Nutrients are an important consideration in establishing an aquatic ecosystem. A shortage of nutrients could hinder the development of a productive aquatic ecosystem, whereas an excess of nutrients could lead to eutrophication. Predicted nutrient (phosphorus [P] and nitrogen [N]) concentrations were modelled for the Project s pit lakes (see the response to ESRD/CEAA Round 1 SIR45a, Appendix 45a.7, Section 4.11). These predictions suggest that there will be adequate nutrients for promoting primary productivity in pit lakes. Given that the nutrients were modelled as simple mass balances, they are likely overestimates; detailed nutrient and primary productivity modelling will be conducted during the detailed design phase. October 2014 ESRD/CEAA Page 107

110 ESRD and CEAA Responses Water Frontier Oil Sands Mine Project Based on the above discussion and the surface water quality assessment, the Project s pit lakes are expected to be able to support viable aquatic ecosystem by the time they begin discharging into the surrounding environment and into the far future. h. Much of the uncertainty in the assessment is linked to the water quality models and was addressed in Volume 5, Appendix 4A, which detailed the sources and management of uncertainty for each model. Given that the response to part b discusses uncertainties associated with predictions, this response focuses on uncertainties related to parts e, f and g of this response (namely, the strength of ecological connections, the importance of specific parameters to maintain ecological function, and the predictions of behaviour, biomass, productivity and species composition). There are six primary sources of uncertainty inherent in the responses to parts e, f and g: variability in baseline data simplifications of complex biogeochemical processes in models linkages between biogeochemical conditions and ecological health and function applicability of conclusions reached by third-party studies to specific aspects of the Project limited ability to verify assumptions unforeseen changes to developments or the environment Further descriptions of uncertainty, as relates to the responses to parts e, f and g are presented below. VARIABILITY IN BASELINE DATA Data were collected from watersheds in the aquatics LSA that could potentially be affected by mining activities. These data supplemented historical data compiled from other developments and from government monitoring activities, creating a baseline dataset. The baseline dataset included seasonal measurements of aquatic chemistry and inventories (i.e., count and spatial distribution) of aquatic life. The baseline dataset was used to calibrate the water quality models and to provide reference conditions for specific locations in the aquatics LSA. Uncertainty resulting from variability in the baseline aquatic chemistry data was addressed using probabilistic (Monte Carlo) modelling. Probability distributions of analyte concentration were defined from the baseline data and those distributions were used to create scenarios that incorporated usual (e.g., mean) and unusual (e.g., 95 th percentile) events. The probabilistic modelling approach enabled modelling of scenarios that were possible but not present in the measured data, and greatly enhanced the certainty of the conclusions drawn from model results. As discussed in the response to ERCB Round 1 SIR 77, additional sampling of water and sediment quality will augment the baseline dataset and reduce conservative uncertainties in the water quality assessment. Teck will continue to monitor water and sediment quality prior to development, during construction, during operation and for the period up to closure. ESRD/CEAA Page 108 October 2014

111 Frontier Oil Sands Mine Project ESRD and CEAA Responses Water SIMPLIFICATION OF COMPLEX BIOGEOCHEMICAL PROCESSES IN MODELS All models incorporate simplifications and approximations of true system behaviour. The assessment incorporated several conservative assumptions such as excluding sink terms like decay and particle settling in the small streams (HSPF) model. Additional conservatism in the modelling approach is discussed in the response to part a. Conservative assumptions introduce a known source of error into the predictions that errs on the side of overprotecting ecosystems. In addition, predictions presented in the assessment that were appreciably below threshold levels (e.g., guidelines, CEBs) also increase the certainty that thresholds will not be exceeded. As stated in the assessment (see Volume 5, Section , Pages to 4-179), intensive water quality monitoring throughout the mining and pit lake filling stages will be conducted to confirm that pit lakes water quality is improving. The monitoring program will reduce uncertainty by providing additional calibration data for the pit lake model. This data will be used to update model forecasts and create mitigation plans. LINKAGES BETWEEN BIOGEOCHEMICAL CONDITIONS AND ECOLOGICAL HEALTH AND FUNCTION The model results presented in the assessment, and the evidence outlined in the response to part c, suggest that pit lakes can provide suitable habitat for aquatic life. Assessment predictions that water, sediment and tissue quality will meet acute and chronic toxicity parameters, tainting potential levels and CEBs provide convincing evidence that, over time, there will be no toxicological impediment to colonization and establishment of an aquatic ecosystem in the pit lakes. Although uncertainties exist in the model, particularly regarding water quality inputs and processes, the risk of under-predicting concentrations associated with these uncertainties is low given the conservative assumptions that are included. The responses to parts e, f and g present a considerable amount of literature addressing habitat concerns. Specifically, the literature on pilot systems and representative examples demonstrate the ability of pit lakes to support aquatic life (see the response to parts c and g). Uncertainty in the relationship between chemical concentrations and aquatic health was managed through the multi-line approach described in the response to ESRD/CEAA Round 3 SIR 11b. Teck and Shell are presently leading a separate project as part of COSIA to design and construct a number of field-scale demonstration pit lakes in the oil sands region. Teck is also participating in a demonstration pit lake project in the oil sands (Syncrude s Base Mine Lake COSIA Joint Industry Project). These projects provide Teck the opportunity to test the experimental hypotheses for demonstration pit lakes, to verify the performance of actual pit lakes, and to incorporate this knowledge in the design and operation of the Project s pit lakes. Furthermore, several approved pit lakes for other oil sands operations will be constructed before the Project s pit lakes are developed. These lakes will provide knowledge and data to refine the conceptual design of the Project s pit lakes. October 2014 ESRD/CEAA Page 109

112 ESRD and CEAA Responses Water Frontier Oil Sands Mine Project APPLICABILITY OF CONCLUSIONS REACHED BY THIRD-PARTY STUDIES Third-party studies were used in the assessment to reach conclusions regarding habitat for aquatic life. Substantial research by government, industry and academia has been conducted that supports the ability of pit lakes to maintain a functioning aquatic ecosystem and aquatic life (see the response to part g). These studies also identify the linkages between water quality and the ecology of pit lakes. The conclusions of these third-party studies are applicable to the Project because study conditions are similar to the conditions of the pit lakes. For example, the range of analyte concentrations is similar and both include the presence of process-affected water, similar climate and geography, and regionally appropriate species. Monitoring of habitat and community structure will be an integral part of pit lake operations to ensure the ecosystem is functioning at the desired level. LIMITED ABILITY TO VERIFY ASSUMPTIONS There is presently limited ability to verify assumptions used in pit lake predictions, because the Project s pit lakes will not be constructed for several decades. However, throughout mining and pit lake filling stages, intensive water quality monitoring of inflow sources will be conducted to confirm analyte concentrations in the pit lake will be within expected ranges. If concentrations are more extreme than expected, conventional treatment technologies are available (see Volume 5, Section , Pages to 4-179). Meanwhile, monitoring of habitat and community structure in other oil sands pit lakes (e.g., Base Mine Lake and others as they develop) will provide information about whether other pit lakes ecosystems are functioning at the desired level, and whether adaptive management strategies are needed. UNFORESEEN CHANGES TO THE PROJECT OR ENVIRONMENTAL PARAMETERS The ability to predict the status of pit lake ecosystems depends on input data (baseline and forecasted) correctly reflecting future conditions. Climate change effects on substance concentrations at representative nodes were predicted using modelling tools (see Volume 5, Appendix 3C). However, it is possible that new developments could be proposed beyond Teck s lease but within the aquatics LSA, even though these changes are not reasonably foreseeable at the present time. Therefore, the effects of such developments could not presently be predicted in a robust way. Instead, this source of uncertainty would be addressed by the proponent of any such changes, in the regulatory application for those changes, including those that may be proposed for the Project. ESRD/CEAA Page 110 October 2014

113 Frontier Oil Sands Mine Project ESRD and CEAA Responses Water REFERENCES Barko, J.W., D. Gunnison and S.R. Carpenter Sediment interactions with submersed macrophyte growth and community dynamics. Aquatic Botany 41: Barr, L Influences of Tailings Water, Sediments, Macrophytes and Detritus on Zoobenthic Community Development in Constructed Wetlands Results of a Reciprocal Transplant Study. MSc Thesis. University of Windsor, Windsor, Ontario. Beck, M.B Water quality modeling: A review of the analysis of uncertainty. Water Resources Research 23: Bendell-Young, L.I., K.E. Bennett, A. Crowe, C.J. Kennedy, A.R. Kermode, M.M. Moore, A.L. Plant and A. Wood Ecological characteristics of wetlands receiving an industrial effluent. Ecological Applications 10: Boehrer, B. and M. Schultze On the relevance of meromixis in mine pit lakes. Proceedings of the 7th International Conference on Acid Rock Drainage. R.I. Barnhisel [ed.]. Lexington, KY: American Society of Mining and Reclamation. pp Brinker, C.J., M.D. Symbaluk and J.G. Boorman Constructing habitat for a sustainable native fisheries in the Sphinx Lake end pit lake system. Mine Closure, Fourie, A.B., M. Tibbett and A. Beersing [eds] Australian Centre for Geomechanics, Perth, Australia. Castro, J.M. and J.N. Moore Pit lakes: their characteristics and the potential for their remediation. Environmental Geology 39: CEMA (Cumulative Environmental Management Association) Document. Hrynyshyn and Wylynko [eds.]. End Pit Lakes Guidance Chambers, P.A. and T. Mill Dissolved Oxygen Conditions and Fish Requirements in the Athabasca, Peace and Slave Rivers: Assessment of Present Conditions and Future Trends. Northern River Basins Study Synthesis Report No. 5. Chambers, P.A., M. Guy, E.S. Roberts, M.N. Charlton, R. Kent, C. Gagnon, G. Grove and N. Foster Nutrients and their Impact on the Canadian Environment. Agriculture and Agri-Food Canada, Environment Canada, Fisheries and Oceans Canada, Health Canada & Natural Resources Canada. Cole, T.M. and S.A. Wells CE-QUAL-W2: A Two-Dimensional, Laterally Averaged, Hydrodynamic and Water Quality Model. Version Prepared for U.S. Army Corps of Engineers. Washington, DC. Crowe A.U., A.L. Plant and A.R. Kermode Effects of an industrial effluent on plant colonization and on the germination and post-germinative growth of seeds of terrestrial and aquatic plant species. Environmental Pollution 117: October 2014 ESRD/CEAA Page 111

114 ESRD and CEAA Responses Water Frontier Oil Sands Mine Project de Schamphelaere, K.A.C. and C.R. Janssen Development and field validation of a biotic ligand model predicting chronic copper toxicity to Daphnia magna. Environmental Toxicology and Chemistry 23: DiToro, D.M Sediment Flux Modeling. Wiley-Interscience. New York, NY. Duarte, C.M. and J. Kalff Littoral slope as a predictor of the maximum biomass of submerged macrophyte communities. Limnology and Oceanography 31: ESRD (Alberta Environment and Sustainable Resource Development) Environmental Quality Guidelines for Alberta Surface Waters. Water Policy Branch, Policy Division. Edmonton, Alberta. Farrell, A.P., C.J. Kennedy and A. Kolok Effects of wastewater from an oil-sand-refining on survival hematology gill histology and swimming of fathead minnows. Canadian Journal of Zoology 82: Feron, V.J. and J.P. Groten Toxicological evaluation of chemical mixtures. Food and Chemical Toxicology 40: Golder (Golder Associates Ltd.) Modeling Assessment of End Pit Lakes Meromictic Potential. Cumulative Environmental Management Association, Fort McMurray, Alberta. CEMA Contract No RWG. Golder Pit Lake Modelling Phase II. Report prepared for Cumulative Environmental Management Association (CEMA). Fort McMurray, Alberta. CEMA Contract No RWG. Golder Fish Species Habitat Suitability Index Models for the Alberta Oil Sands Region. Version 2.0. Gupta, N Effects of Oil Sands Process-Affected Water and Substrates on Wood Frog (Rana sylvatica) Eggs and Tadpoles. M.Sc. Thesis, University of Saskatchewan, Saskatoon, Saskatchewan. Harris, M. [ed.] Aquatic Ecosystems Associated with Oil Sands Development: Syncrude Canada's Progress in Optimizing Freshwater Environments. Summary of the University of Waterloo- Syncrude Canada Partnership, University of Waterloo, Waterloo, Ontario. Hayes, T.M.E Examining the Ecological Effects of Naphthenic Acids and Major Ions on Phytoplankton in the Athabasca Oil Sands Region. Ph.D. Thesis, Department of Biology. University of Waterloo, Waterloo, Ontario. Headley, J.V. and D.W. McMartin A Review of the Occurrence and Fate of Naphthenic Acids in Aquatic Environments. Journal of Environmental Science and Health Part A A39: Herman, D.C., P.M. Fedorak, M.D. MacKinnon and J.W. Costernon Biodegradation of naphthenic acids by microbial populations indigenous to oil sands tailings. Canadian Journal of Microbiology 40(6): ESRD/CEAA Page 112 October 2014

115 Frontier Oil Sands Mine Project ESRD and CEAA Responses Water Hersikorn, B.D In-situ Caged Wood Frog (Rana sylvatica) Survival and Development in Wetlands Formed from Oil Sands Process-Affected Materials (OSPM). M.Sc. Thesis, University of Saskatchewan, Saskatoon, Saskatchewan. Hersikorn, B.D., J.J. Ciborowski and J.E. Smits The effects of oil sands wetlands on wood frogs (Rana sylvatica). Toxicological and Environmental Chemistry 92: Hersikorn, B.D. and J.E. Smits Compromised metamorphosis and thyroid hormone changes in wood frogs (Lithobates sylvaticus) raised on reclaimed wetlands on the Athabasca oil sands. Environmental Pollution 159: Hooper, D.U., F.S. Chapin, J.J. Ewel, A. Hector, P. Inchausti, S. Lavorel, J.H. Lawton, D.M. Lodge, M. Loreau, S. Naeem, B. Schmid, H. Setälä, A.J. Symstad, J. Vandermeer and D.A. Wardle Effects of biodiversity on ecosystem functioning: a consensus of current knowledge. Ecological Monographs 75: Inskip, P.D Habitat Suitability Index Models: Northern Pike. U.S. Department of the Interior, Fisheries and Wildlife Service. Kavanagh, R.J., R.A. Frank, K.D. Oakes, M.R. Servos, R.F. Young, P.M. Fedorak, M.D. MacKinnon, K.R. Solomon, D.G. Dixon and G. Van Der Kraak Fathead minnow (Pimephales promelas) reproduction is impaired in aged oil sands process-affected waters. Aquatic Toxicology 101: Kavanagh, R., R. Frank, K. Oakes, M. Servos, R. Young, P. Fedorak, M. MacKinnon, K. Solomon and D.G. Dixon Fathead minnow (Pimephales promelas) reproduction is impaired in aged oil sands process-affected waters. Aquatic Toxicology 101: Kavanagh, R.J., R.A. Frank, K.R. Solomon and G. Van Der Kraak Reproductive and health assessment of fathead minnows (Pimephales promelas) inhabiting a pond containing oil sands process-affected water. Aquatic Toxicology : Lahring, H Water and Wetland Plants of the Prairie Provinces. Canadian Plains Research Center, University of Regina, Regina, Saskatchewan. Leira, M. and M. Cantonati Effects of water-level fluctuations on lakes: an annotated bibliography. Hydrobiologia 613: Leonhardt, C.L Zoobenthic Succession in Constructed Wetlands of the Fort McMurray Oil Sands Region: Developing a Measure of Zoobenthic Recovery. Ph.D. Thesis, University of Windsor, Windsor, Ontario. Leung, S.S., M.D. MacKinnon and R.E.H. Smith The ecological effects of naphthenic acids and salts on phytoplankton from the Athabasca Oil Sands Region. Aquatic Toxicology 62: Luong, L The Growth Responses of Myriophullum spicatum, Potamogeton richardsonii and Chara vulgaris to Reclamation Materials Nutrient Amendments (Inorganic and Organic) and Salinity in Laboratory Conditions. M.Sc. Thesis, University of Waterloo, Ontario, Canada. October 2014 ESRD/CEAA Page 113

116 ESRD and CEAA Responses Water Frontier Oil Sands Mine Project MacKinnon, M. and H. Boerger Description of two treatment methods for detoxifying oil sands tailings pond water. Water Pollution Research Journal of Canada 21: Martino, M., A. Turner and G.E. Millward Influence of Organic complexation on the adsorption kinetics of nickel in river waters. Environmental Science and Technology 37: McCormick, J.K The Effects of Oil Sands Tailings on Zooplankton Communities in Northern Alberta. M.Sc. Thesis, Department of Biology, University of Waterloo, Waterloo, Ontario. McNeill, S.A., C.J. Arens, N.S. Hogan, B. Kollner and M.R.van den Heuvel Immunological impacts of oil sands-affected waters on rainbow trout evaluated using an in situ exposure. Ecotoxicology and Environmental Safety 84: Minshall, G.W Aquatic insect-substratum relationships. In Resh, V.H. and Rosenberg, D.M. [eds.], Ecology of Aquatic Insects. Praeger Publishers, New York. Moeller, R.E., J.M. Burkholder and R.G. Wetzel Significance of sedimentary phosphorus to a rooted submersed macrophyte (Najas flexilis (Willd.) Rostk. and Schmidt) and its algal epiphytes. Aquatic Botany 32: Paquin, P.R., J.W. Gorsuch, S. Apte, G.E. Batley, K.C. Bowles, P.G.C. Campbell, C.G. Delos, D.M. Di Toro, R.L. Dwyer, F. Galvez, R.W. Gensemer, G.G. Goss, C. Hogstrand, C.R. Jansses, J.C. McGeer, R.B. Naddy, R.C. Playle, R.C. Santore, U. Schneider, W.A. Stubblefield, C.M. Wood and K.B. Wu The Biotic Ligand Model: A Historical Perspective. Comparative Biochemisty and Physiology Part C, C133:3 35. Playle, R.C Modelling metal interactions at fish gills. Science of the Total Environment 219: Pollet, I. and L. Bendell-Young Amphibians as indicators of wetland quality in wetlands formed from oil sands effluent. Environmental Toxicology and Chemistry 19: Portland State University Water Quality Research Group, CE-QUAL-W2: Application History. Available at: Pouliot, R., L. Rochefort and M. D. Graf Impacts of oil sands process water on fen plants: Implications for plant selection in required reclamation projects. Environmental Pollution 167: Rezanzhad, F., R. Anderson, R. Pouliot, J. S. Price, L. Rochefort and M. D. Graf How fen vegetation structure affects the transport of oil sands process-affected waters. Wetlands 32: Rogers, V., M. MacKinnon and B. Brownlee Analytical approaches to characterising fish tainting potential of oil sands process waters. Water Science and Technology 55: ESRD/CEAA Page 114 October 2014

117 Frontier Oil Sands Mine Project ESRD and CEAA Responses Water Scott, A.C., M.D. MacKinnon and P.M. Fedorak Naphthenic acids in Athabasca oil sands tailings waters are less biodegradable than commercial naphthenic acids. Environmental Science and Technology 39: Shell (Shell Canada Limited) Jackpine Mine Expansion and Pierre River Mine Project Application and Environmental Impact Assessment. Volumes 1, 2, 3, 4 and 5. Submitted to Alberta Energy and Utilities Board and Alberta Environment, December, Calgary, Alberta. Siwik, P.L., T. Van Meer, M.D. MacKinnon and C.A. Paszkowski Growth of fathead minnows in oilsand-processed wastewater in laboratory and field. Environmental Toxicology and Chemistry 19: Smits, J.E., M.E. Wayland, M.J. Millar, K. Liber and S. Trudeau Reproductive, immune, and physiological end points in tree swallows on reclaimed oil sands mine sites. Environmental Toxicology and Chemistry 19: Stackhouse, R.A. and W.H. Benson The influence of humic acid on the toxicity and bioavailability of selected trace metals. Aquatic Toxicology 13: Stumm, W. and J.J. Morgan Aquatic Chemistry. Second Edition. Wiley-Interscience. Toronto, Ontario. Suter, G.W Toxicological benchmarks for screening contaminants of potential concern for effects on freshwater biota. Environmental Toxicology and Chemistry 15: Taylor, B.R. and B.A. Barton Temperature and Dissolved Oxygen Criteria for Alberta Fishes in Flowing Waters. Alberta Fish and Wildlife Division, Edmonton, Alberta. Trites, M. and S. Bayley Vegetation communities in continental boreal wetlands along a salinity gradient: Implications for oil sands mining reclamation. Aquatic Botany 91: Twomey, K.A., K.L. Williamsom and P.C. Nelson Habitat Suitability Index Models and Instream Flow Suitability Curves: White Sucker. U.S. Department of the Interior, Fisheries and Wildlife Service. van den Heuvel, M.R., M. Power, M.D. MacKinnon, T. Van Meer, E.P. Dobson and D.G. Dixon. 1999a. Effects of oil sands related aquatic reclamation on yellow perch (Perca flavescens). I. Water quality characteristics and perch physiological and population responses. Canadian Journal of Fisheries and Aquatic Sciences 56: van den Heuvel, M.R., M. Power, M.D. MacKinnon, T. Van Meer and D.G. Dixon. 1999b. Effects of oil sands related aquatic reclamation on yellow perch (Perca flavescens). II. Chemical and biochemical indicators of exposure to oil sands related waters. Canadian Journal of Fisheries and Aquatic Sciences 56: van den Heuvel, M.R., N.S. Hogan, S.D. Roloson and G.J. Van Der Kraak Reproductive development of yellow perch (Perca flavescens) exposed to oil sands-affected waters. Environmental Toxicology and Chemistry 31: October 2014 ESRD/CEAA Page 115

118 ESRD and CEAA Responses Water Frontier Oil Sands Mine Project Van Genderen, E.J., A.C. Ryan, J.R. Tomasso and S.J. Klaine Influence of dissolved organic matter on silver toxicity to Pimephales promelas. Environmental Toxicology and Chemistry 22: Wetzel, R.G Limnology: Lake and River Ecosystems. Third edition. Academic Press. Whelly, M.P Aquatic invertebrates in wetlands of the oil sands region of Northeast Alberta, Canada, with emphasis on Chironomidae (Diptera) biological sciences. University of Windsor, Windsor, Ontario. Wyman, R.L What s happening to the amphibians? Conservation Biology 4: Yang, R.S Some critical issues and concerns related to research advances on toxicology of chemical mixtures. Environmental Health Perspectives 106: Young, R.F., E.A. Orr, G.G. Goss and P.M. Fedorak Detection of naphthenic acids in fish exposed to commercial naphthenic acids and oil sands process-affected water. Chemosphere 68: Young, R.F., W.V. Wismer and P.M. Fedorak Estimating naphthenic acids concentrations in laboratory-exposed fish and in fish from the wild. Chemosphere 73: Young, R.F., L.M. Michel and P.M. Fedorak Distribution of naphthenic acids in tissues of laboratory exposed fish and in wild fishes from near the Athabasca oil sands in Alberta, Canada. Ecotoxicology and Environmental Safety 74: Question 13 SIR1, Volume 1, Section 10, SIRs 72 and 73, Pages SIR1, Volume 1, Section 5.5, SIR 111a, Pages to SIR 112, Pages to SIR1, Volume 1, Section 10, SIR 71 b, Page 148 SIR2, Volume 1, Aquatics, SIR 30 Thermal regimes were modelled. Table 4-19, Page presents a seven Celsius degree shift between pre-development water temperatures in Big Creek in September and October. It also indicates a two month time lag in spring warming and fall cooling. a. Provide a discussion of aquatic biotic responses to temperature. Include; but, do not limit the discussion to thermal cues for the initiation and cessation of life history events (e.g. spawning, migration), and aquatic biota growth and productivity responses to temperature. Support the discussion with peer-reviewed literature. b. Given known biotic responses to temperature, provide support for the conclusion that the predicted change in temperature regime will result in negligible aquatic ecological effects. ESRD/CEAA Page 116 October 2014

119 Frontier Oil Sands Mine Project ESRD and CEAA Responses Water Teck s discussion of confidence around the effects conclusion is focussed on the model itself and does not discuss the ecological implications. c. Provide a discussion on confidence/uncertainty, including the broader aquatic ecological responses to temperature. d. Revise the effects conclusion and the linkage determination between water quality and aquatic ecology as appropriate. Ensure the thermal regime conclusions and uncertainty are carried forward. Teck refers to sedimentation in the SIR2 update and directs the reviewer to SIR1 45a and 45a.7. SIR1 Response 45a discusses perimeter ditches and seepage around the ETAs and TLDAs, not sedimentation. 45a.7 is an appendix and directs the reviewer to section of the EIA. Section of the EIA refers to changes in sediment quality and aquatic health with respect to toxicity, not sediment loading or the physical effects of sedimentation on aquatic biota or habitat. e. Provide an assessment of the potential aquatic ecological effects associated with sedimentation. Update the aquatic ecology assessment accordingly. Response 13 As discussed in the response to AER Round 3 SIR 1, Teck intends to update the for the Project to: recover additional resource from leases acquired from Shell during the Teck Shell asset exchange optimize the tailings management strategy in consideration of the current state of engineering practice and improved understanding of site-specific conditions reflect additional engineering studies and information obtained from Shell as part of the asset exchange consider input from regulators and potentially affected Aboriginal communities during the review process Portions of this SIR response will be evaluated as part of the Project Update; however, the following discussion provides appropriate information and context for the concerns expressed by the reviewer. a. The water quality assessment predicts changes in the temperature regime in Big Creek at closure due to discharges from central pit lake A (see Volume 5, Section , Pages to 4-101). The predicted changes are for the pit lake outflow to Big Creek; however, the predicted change in thermal regime reflects a shifting time scale and not an increase in temperatures beyond the normal range of surface water temperatures in Big Creek. The predicted temperature changes can be expected to attenuate and more closely match existing conditions as water flows from the pit lake outlet down the length of Big Creek to its mouth. Since the amount of attenuation is not known, the predicted changes were examined in relation to the fish community of lower Big Creek. October 2014 ESRD/CEAA Page 117

120 ESRD and CEAA Responses Water Frontier Oil Sands Mine Project The pit lake will warm and cool more slowly than the watercourses, delaying spring warming and fall cooling of water temperatures. Generally, water temperatures at closure will be offset by about one month during the spring and fall (i.e., baseline mean temperatures for May, June, September and October will occur in June, July, October and November, respectively). Temporal shifts in water temperatures can affect the community structure and productivity of aquatic ecosystems. For example, temperature changes can affect: the timing of invertebrate life cycles (Reece and Richardson 1998), which could affect food resources for fish primary productivity in streams; however, in some cases, the effects of temperature on primary productivity are insignificant relative to light intensity (Kevern and Ball 1965) the timing of life history events for some fish species, which are often correlated with temperature. Direct effects of the predicted temperature shifts on fish populations might include delays in the initiation of spring spawning migration, start of spring spawning, and initiation of fall migration for species where these activities depend on temperature cues, such as the suckers and burbot found in Big Creek (Baily 1969; Scott and Crossman 1973; Edwards 1983; Twomey et al. 1984; Hamel et al. 1997). embryo development and hatching success, particularly if the temperature is lower than the preferred incubation temperatures for the fish species (Edwards 1983; Twomey et al. 1984). This is likely to occur only in circumstances where cooler water temperatures during the normal spawning and incubation period do not result in a delay in spawning activity. Delay of spawning activity to when appropriate temperatures occur would result in appropriate incubation temperatures. Fish growth for species present in Big Creek is also related to water temperature and can be affected if temperatures during the nursery, rearing and feeding periods shift beyond the preferred temperatures for the relevant fish species (Edwards 1983; Twomey et al. 1984; Hill and Magnuson 1990). Effects on productivity can occur for aquatic biota (including benthic invertebrates and fish) if the new temperatures are outside the current regime and colder or warmer overall. This change is not predicted to occur in Big Creek. b. The aquatic health assessment concluded that the predicted temperature shifts in Big Creek would not affect aquatic health because they reflect a shifting time scale and not temperatures outside the current range for the watercourse (see Volume 5, Section , Pages to 4-101). Based on the information provided in response to part a, Teck modelled the predicted changes in water temperature resulting from a shift in the timing of spring warming and fall cooling. Data were used to evaluate benthic invertebrate communities and the specific fish species documented to occur in lower Big Creek. It was assumed that the range of minimum and maximum daily temperatures associated with a given mean monthly temperature would be the same under existing and closure conditions. ESRD/CEAA Page 118 October 2014

121 Frontier Oil Sands Mine Project ESRD and CEAA Responses Water BENTHIC INVERTEBRATES Annual changes in stream water temperature over time (i.e., seasonal changes) are one of the largest influences on the timing of invertebrate life cycles because they affect hatch and emergence timing (Reece and Richardson 1998). Seasonal changes were observed in benthic invertebrate community composition and abundance as invertebrates moved through their life cycle. Seasonal, temperaturerelated benthic invertebrate abundance patterns showed: high abundance in early spring (due to the presence of overwintering, pre-emergent invertebrates and the start of recruitment) reduced abundance in the late spring due to emergence high abundance again in the summer due to recruitment The timing of annual temperature cycles was important to the observed pattern of abundance. Therefore, a likely effect of the predicted temperature shifts for Big Creek would be a shift in the abundance pattern as follows: lower abundance in the early spring high abundance in the late spring low abundance in the early summer high abundance in the late summer and early fall FISH SPECIES The fish community in lower Big Creek consists of burbot, longnose sucker, white sucker and several forage fish species (brook stickleback, lake chub, longnose dace, pearl dace, slimy sculpin, spoonhead sculpin and spottail shiner). Many of these species are tolerant of a wide range of temperatures and exist in geographic areas where seasonal water temperatures are both lower and higher than in Big Creek. This distribution suggests that these species might have low sensitivity to the predicted changes in water temperature. Species that might be affected by delayed spring warming include longnose sucker (Baily 1969) and white sucker (Hamel et al. 1997). For both of these species, spring spawning is temperaturedependent and triggered by temperature thresholds. Hatching of larvae is also correlated with water temperature for both species (McCormick et al. 1977; Edwards 1983). In general, longnose sucker enter spawning tributaries when temperatures are 5 C to 9 C (Scott and Crossman 1973; Edwards 1983) and white sucker when temperatures are 10 C. Based on fish fence studies conducted in the oil sands region for other Athabasca River tributaries, spawning runs for regional populations of longnose sucker start at water temperatures of 5.5 C to 9 C, and for white sucker at 9 C to 10 C, with the main movement occurring for both species when the daily maximum temperature is 10 C or more (Bond and Machniak 1977, 1979; Machniak and Bond 1979; RAMP 2004, 2007, 2010). The timing of the start of the spawning runs for these two species has ranged from late April to early October 2014 ESRD/CEAA Page 119

122 ESRD and CEAA Responses Water Frontier Oil Sands Mine Project May, with peaks occurring in early May to mid-may (for longnose sucker) and in early May to late May (for white sucker), depending on the year. In all cases, sucker spawning occurs over about a two-week period following in-migration. Given that local sucker populations tend to adhere to a specific range of migration and spawning temperatures, it can be expected that, if sucker spawning occurs in Big Creek, the spring run and spawning activities would be delayed by approximately one month at closure. A similar delay in spawning might occur for forage fish species that use Big Creek for spawning and that typically spawn from May to June (i.e., brook stickleback, slimy sculpin and spoonhead sculpin), but not for the species that typically spawn in the summer at higher water temperatures (i.e., lake chub, longnose dace, pearl dace and spottail shiner). For all species, incubation and hatching success is assumed to be unaffected if the spawning period is delayed until appropriate temperatures occur. The potential shift in benthic invertebrate abundance means that food availability, fish growth and productivity are expected to be similarly offset in time. Specifically, the summer growth period might be longer due to the extension of warmer temperatures into September and October, such that warm temperatures (i.e., approximately 10 C or more) will occur for a four-month period following closure, compared to a three-month period under baseline conditions. Reduced growth or productivity is not expected. The expected delay in fall cooling of water temperatures has the potential to affect fall fish migrations. The species most likely to be affected in lower Big Creek is burbot. Regional spring fish fence data indicate that most migrant sucker populations that use Athabasca River tributaries for spawning exit the tributaries in the spring and summer; therefore, the out-migration does not correlate with falling water temperatures. The limited fall fish fence data for the oil sands region (Machniak and Bond 1979) shows comparatively very little sucker out-migration in the fall, but documented an out-migration by burbot. Fall migration of burbot is triggered by changes in water temperature and discharge (Paragamian and Wakkinen 2008). The data provided by Machniak and Bond (1979) show that the burbot out-migration in the Steepbank River occurred in October when water temperatures fell to 5 C. Based on the temperature changes predicted for Big Creek, this migration could be delayed until November at closure. c. The way in which primary producers and benthic invertebrates respond to seasonal changes in temperature is considered somewhat predictable (Kevern and Ball 1965; Reece and Richardson 1998), although some research indicates light intensity might be more important to primary production than water temperature in streams (Kevern and Ball 1965). For some aquatic components, however, there are a number of factors that add to the uncertainty associated with predicted temperature changes in Big Creek. These uncertainties include: the extent of temperature attenuation from the pit lake outlet to lower Big Creek whether lower Big Creek is used for spawning by suckers from the Athabasca River the potential for ecological interactions to affect fish productivity ESRD/CEAA Page 120 October 2014

123 Frontier Oil Sands Mine Project ESRD and CEAA Responses Water To address uncertainty regarding predicted temperature changes in Big Creek, Teck will seasonally monitor benthic invertebrate communities and fish populations, as well as fish use and productivity, in lower Big Creek (see the conceptual monitoring plan provided in response to ESRD/CEAA Round 3 SIR 24). d. Linkage pathways between water quality and aquatic ecology, effects conclusions and uncertainties are summarized in the response to ESRD/CEAA Round 3 SIR 42. This summary includes the thermal regime information provided above in response to parts a, b and c. e. The potential effects of sedimentation on aquatic biota and habitat are assessed in the fish and fish habitat assessment (see Volume 5, Sections to , Pages 5-28 to 5-34). The assessment incorporates Project-specific mitigation for changes in sediment load and sedimentation (see Volume 5, Section , Page 3-84). For example: Based on the water management plan for the Project, non-process-affected water will be directed to polishing ponds during operation before being released to receiving watercourses (see Volume 1, Section 7.7.4, Pages 7-19 to 7-21). During operation and at closure, major creeks in the aquatics LSA (i.e., Redclay Creek and Big Creek) will be affected by mine development activities and will be diverted through new diversion channels to the Athabasca River. These creeks will be designed using a geomorphic approach to provide erosion and sedimentation characteristics similar to natural regional drainage systems. The Frontier Project is expected to have negligible changes in the sedimentation regime of these watercourses and the Athabasca River. Changes in sediment loading to the tributary creek that flows into Ronald Lake were specifically assessed (see the revised hydrology assessment provided in response to ESRD/CEAA Round 1 SIR 45a, Appendix 45a.5). The results show that the mean annual TSS concentrations closely approximate predevelopment conditions. The planned, Project-specific mitigation will help prevent sedimentation in natural watercourses and will be considered as part of the Project Update. As such, effects of sedimentation are anticipated to be negligible and there will be no loss of habitat or productivity associated with sedimentation. If an effect is predicted as part of the Project Update, compensation for habitat and productivity loss will be considered and the conceptual fish habitat compensation plan (CFHCP) will be updated. REFERENCES Bailey, M.M Age, growth, and maturity of the longnose sucker Catostomus catostomus, of western Lake Superior. Journal of the Fisheries Board of Canada 26: Bond, W.A. and K. Machniak Interim Report on an Intensive Study of the Fish Fauna of the Muskeg River Watershed of Northeastern Alberta. Prepared by the Department of Fisheries for the Alberta Oil Sands Environmental Research Program. AOSERP Project AF AOSERP Report 26. October 2014 ESRD/CEAA Page 121

124 ESRD and CEAA Responses Water Frontier Oil Sands Mine Project Bond, W.A. and K. Machniak An Intensive Study of the Fish Fauna of the Muskeg River Watershed of Northeastern Alberta. Prepared for Alberta Oil Sands Environmental Research Program by Environment Canada, Freshwater Institute. AOSERP Report 76. Edwards, E.A Habitat Suitability Index Models: Longnose Sucker. U.S. Dept. Int., Fish Wildl. Serv. FWS/OBS-82/ Hamel, P., P. Magnan, M. Lapointe and P. East Timing of spawning and assessment of a degreeday model to predict the in situ embryonic developmental rate of white sucker, Catostomus commersoni. Canadian Journal of Fisheries and Aquatic Sciences 54: Hill, D.K. and J.J. Magnuson Potential effects of global climate warming on the growth and prey consumption of Great Lakes fish. Transactions of the American Fisheries Society 119: Kevern, N.R. and R.C. Ball Primary productivity and energy relationships in artificial streams. Limnology and Oceanography 10: Machniak, K. and W.A. Bond An Intensive Study of the Fish Fauna of the Steepbank River Watershed of Northeastern Alberta. Prepared for the Oil Sands Environmental Research Program by Environment Canada, Freshwater Institute, Winnipeg, Manitoba. AOSERP Report 61. McCormick, J.H., B.R. Jones and K.E. Hokanson White sucker (Catostomus commersoni) embryo development, and early growth and survival at different temperatures. Journal of the Fisheries Board of Canada 34: Paragamian, V.L. and V.D. Wakkinen Seasonal Movement of Burbot in Relation to Temperature and Discharge in the Kootenai River, Idaho, USA and British Columbia, Canada. In American Fisheries Society Symposium, American Fisheries Society. RAMP (Regional Aquatics Monitoring Program) Regional Aquatics Monitoring Program (RAMP) 2003 Annual Report. Prepared for the RAMP Steering Committee. Submitted by the RAMP 2003 Implementation Team Consisting of Hatfield Consultants Ltd., Jacques Whitford Environment Ltd., Mack, Slack and Associates Inc. and Western Resource Solutions. Submitted March RAMP Regional Aquatics Monitoring Program (RAMP) 2006 Technical Report. Prepared for the RAMP Steering Committee. Submitted by the RAMP 2006 Implementation Team consisting of Hatfield Consultants Ltd., Stantec Consulting Ltd., Mack, Slack and Associates Inc. and Western Resource Solutions. Submitted April RAMP Regional Aquatics Monitoring Program 2009 Technical Report. Prepared for RAMP Steering Committee by the RAMP 2009 Implementation Team: Consisting of Hatfield Consultants, Kilgour and Associates Ltd. and Western Resource Solutions. Reece, P.F. and J.S. Richardson Seasonal Changes of Benthic Macroinvertebrate Communities in Southwestern British Columbia. Prepared for Environment Canada, Environmental Conservation Branch, Aquatic and Atmospheric Sci. Div. FRAP Report No.: DOE-FRAP ESRD/CEAA Page 122 October 2014

125 Frontier Oil Sands Mine Project ESRD and CEAA Responses Water Scott, W.B. and E.J. Crossman Freshwater Fishes of Canada. Government of Canada, Fisheries and Oceans. Bulletin 184, Fisheries Research Board of Canada, Ottawa. Twomey, K.A., K.L. Williamson and P.C. Nelson Habitat Suitability Index Models and Instream Flow Suitability Curves: White Sucker. U.S. Fish Wildl. Serv. FWS/OBS-82/ Question 14 SIR1, Volume 1, Section 10, SIRs 72 and 73, Pages SIR1, Volume 1, Section 5.5, SIR 111a, Pages to SIR 112, Pages to SIR1, Volume 1, Section 10, SIR 71 b, Page 148 SIR2, Volume 1, Aquatics, SIR 30 Teck states that Diversions prior to initial construction will not result in an increase in sediments to downstream reaches and directs the reviewer to SIR1 Response 45a. Standard mitigation measures implemented to reduce sedimentation associated with diversion construction do not eliminate sedimentation entirely. a. Provide an assessment of the effects associated with sedimentation and the construction and operation of diversion ditches. Update the aquatic ecology assessment accordingly. Response 14 a. The water management plan for the Frontier Project includes the use of polishing ponds as part of the Project s release water drainage system. During operation, water will be conveyed to polishing ponds before releasing flows of non-process-affected waters to receiving watercourses (see Volume 1, Section 7.7.4, Pages 7-19 to 7-22). During operation and at closure, major creeks (Redclay Creek and Big Creek) within the revised aquatics LSA will be disturbed by mine development activities. As a result, these creeks will be diverted through new diversion channels to the Athabasca River. Diversion channels will be designed using: standard mitigation techniques that prevent erosion (e.g., revegetation, berms, rip-rap) and limit sediment transport to downstream areas (see Volume 5, Section 3.6.5, Pages 3-84 to 3-87) a geomorphic approach so that erosion and sedimentation characteristics are similar to natural regional drainage systems Therefore, the Frontier Project is expected to result in negligible changes in the sedimentation regime of the Athabasca River. Changes in sediment loading to the tributary creek that flows into Ronald Lake were evaluated as part of the hydrology assessment (see Volume 5, Section , Table 3-39, Page 3-86). Results show that the mean annual TSS concentrations closely approximate those of predevelopment October 2014 ESRD/CEAA Page 123

126 ESRD and CEAA Responses Water Frontier Oil Sands Mine Project conditions. At closure, the estimated flood discharge is expected to be smaller than the predevelopment flood flow. As a result, additional erosion from the Frontier Project is unlikely; however, some sediment deposition is possible during small flood events. The revised fish and fish habitat assessment considered these mitigation measures (see the response to ESRD/CEAA Round 2 SIR 30a, Appendix 30a.1) and concluded that there would be no adverse effects resulting from sedimentation. Although the fish and fish habitat assessment may be revised further as part of the Project Update (see the response to AER Round 3 SIR 1), the assessment remains valid for the current plan. Mitigation to limit changes in sedimentation will be considered as part of the Project Update. Question 15 SIR1, Volume 1, Section 10, SIRs 72 and 73, Pages SIR1, Volume 1, Section 5.5, SIR 111a, Pages to SIR 112, Pages to SIR1, Volume 1, Section 10, SIR 71 b, Page 148 SIR2, Volume 1, Aquatics, SIR 30 a. Address the following in the aquatic ecology assessment: i. Revisit each water quantity conclusion used to support the aquatic effects assessment and consider whether the conclusion is appropriate to fully invalidate a linkage, support the conclusion, and/or has considered the broad suite of potential aquatic ecological effects and the uncertainty associated with the conclusion. Response 15 a. Confidence in water quantity predictions is influenced by the quality and quantity of baseline hydrologic information, understanding of hydrologic processes, confidence in measurements or analytic techniques, and uncertainties in potential climate change predictions. Expected uncertainties associated with water quantity are described and quantified in Volume 5, Section Page 3-71 to 3-74 and Volume 5, Appendices 3B and 3C. These uncertainties are summarized as follows: The baseline information used to quantify water quantity was adequate in terms of record length, spatial coverage and temporal resolution. Data obtained from Environment Canada and data collected as part of Frontier Project baseline study are considered of good quality. Water quantity measurements (i.e., flow and water level data) are accurate to about ± 5% for most flow conditions and from ± 10% to ± 20% for low-flow and flood-flow conditions. ESRD/CEAA Page 124 October 2014

127 Frontier Oil Sands Mine Project ESRD and CEAA Responses Water The uncertainty associated with predicting changes in water quantity using a hydrologic model was evaluated for watercourses and waterbodies in the aquatics LSA. Results show that the predicted values are within ± 5% for all flow statistics and within ± 1% for the mean flow and 10-year flood peak-flow statistics. Results of an uncertainty analysis associated with potential climate change show that winter low flows tend to increase, whereas changes in the other flow statistics range from 4% to 30% under future median conditions. Warmer and drier climate conditions tend to decrease all flow statistics; however, warmer and wetter conditions tend to increase all the flow statistics. The hydrology assessment concluded that there is a high level of confidence in the information used to validate linkages and assess changes in fish and fish habitat. Likewise, there is a high probability that the standard mitigation measures Teck plans to implement will prevent increases in suspended sediment or sedimentation from Project activities. Flow data that was extrapolated as part of the modelling process is subject to some uncertainty; however, the uncertainty analysis for test case parameters indicates that modelling results can be used with confidence (see Volume 5, Section , Page 3-72). Some uncertainty was identified in evaluating predicted decreases in peak flows at closure and the effects on channel regime. This uncertainty resulted from current knowledge gaps (i.e., determining the stream-specific effective channel-forming flows and potential interactions with reduced suspended sediment loads downstream of pit lakes; see the response to ESRD/CEAA Round 3 SIR 16d). As a result, hydrologic monitoring will be conducted to obtain additional site-specific data as follow-up to the assessment. This data will be used to verify assessment predictions, including that reduced peak flows will have negligible effects on channel regime. Although the fish and fish habitat assessment may be revised as part of the Project Update (see the response to AER Round 3 SIR 1), the assessment remains valid for the current plan. Based on the factors listed above, and given the availability of additional regional hydrology data, any update to the assessment will be based on water quantity predictions and mitigation measures that have the same high level of confidence. Question 16 SIR1, Volume 1, Section 10, SIRs 72 and 73, Pages SIR1, Volume 1, Section 5.5, SIR 111a, Pages to SIR 112, Pages to SIR1, Volume 1, Section 10, SIR 71 b, Page 148 SIR2, Volume 1, Aquatics, SIR 30 October 2014 ESRD/CEAA Page 125

128 ESRD and CEAA Responses Water Frontier Oil Sands Mine Project Teck states that Changes in channel regimes can occur through watercourse diversions if they result in increased peak flows in receiving waters. Teck then concludes that because increased peak flows are not predicted, there will be little effect and the linkage between flows and changes in channel regimes is determined to be invalid. a. Provide peer-reviewed rationale for the implied assumption that only increased flows would affect the channel regime. b. Discuss the channel and habitat maintenance function of peak flow volume. c. Describe how decreases in peak flood flow volume and frequency could influence channel regime and habitat, including; but, not limiting the discussion to increased sedimentation, and riparian and aquatic vegetation incursion. d. Revise the assessment to include the potential effects associated with a reduction in peak flows. Provide peer-reviewed literature or data to support the above discussion and assessment conclusions. e. Update the fish habitat compensation plan as appropriate. f. Confirm that monitoring will address potential habitat changes associated with changes in peak flows and that should habitat change be noted, the habitat compensation will be updated accordingly. Generally describe how this monitoring will be undertaken. In the discussion of habitat losses associated with flow change, Teck uses the 15% instantaneous flow criterion from the Alberta Desktop Method for instream flow assessment. Teck applies the 15% criterion to mean flows. g. Provide support for the application of the 15% instantaneous flow criterion to mean flows. Response 16 As discussed in the response to AER Round 3 SIR 1, Teck intends to update the for the Project to: recover additional resource from leases acquired from Shell during the Teck Shell asset exchange optimize the tailings management strategy in consideration of the current state of engineering practice and improved understanding of site-specific conditions reflect additional engineering studies and information obtained from Shell as part of the asset exchange consider input received from regulators and potentially affected Aboriginal communities during the review process Portions of this SIR response will be reevaluated as part of the Project Update; however, most of the following discussion provides appropriate and relevant context for the SIR. ESRD/CEAA Page 126 October 2014

129 Frontier Oil Sands Mine Project ESRD and CEAA Responses Water a. Channel regime is generally affected by either long-term increases or decreases in natural flows. In addition, channel regime is affected by channel form (width, depth and slope), substrate and vegetation. A significant amount of scientific literature, dating back to the early 20 th century, is available that provides results of investigations into the characteristics of natural channels. The Geomorphic Characterization and Design of Alluvial Channels in the Athabasca Oil Sands Region (Golder 2008) provides an extensive review of the literature and characteristics of natural alluvial channels in the Athabasca Oil Sands Region. In the hydrology assessment, potential effects on channel regime were assessed with respect to increases in peak flows (as represented by the 10-year peak discharge parameter) and the potential for changes in the morphology of natural receiving streams due to channel scour or destabilization. A reduction in the peak discharge was considered neutral with respect to changes in channel regime. Although a reduction in peak discharge would reduce channel erosion rates, it could also cause localized sediment deposition in the stream channel (see Volume 5, Section 3.6.1, Page 3-81). b. Effective discharge is the flow parameter generally used to represent geomorphic processes responsible for determining and maintaining the physical form of alluvial channels (Harrelson et al. 1994). Effective discharge is the flow that transports the greatest volume of sediment over long temporal scales under current climatic conditions. One study suggests that the recurrence interval of the effective discharges at 15 gauging stations in the Yampa River basin ranged from 1.18 to 3.26 years on the annual flood series. In addition, the effective discharge and the bankfull discharge were nearly equal (Andrews 1980). Effective discharge has been equated with the bankfull discharge, and both have been used more frequently in recent years in stream-restoration strategies. It is commonly understood that the measured bankfull discharge represents the channel-forming flow, that flows below bankfull are ineffective at significantly altering the channel form, and that flows greater than bankfull are too infrequent to dominate channel form (Smith and Prestegaard 2005). Bankfull discharge is the flow rate that corresponds to bankfull conditions, which occur when the river exceeds the stream s natural banks and overflows onto the active floodplain. The active floodplain is the flat area adjacent to the channel developed by the stream and used by flood flows at a recurrence interval of two years or less (Wolman and Leopold 1957). Bankfull discharge is often characterized by a 1.5-year recurrence interval (Leopold et al. 1964; Rosgen 1994); however, this value may not be constant, even within a single basin (Pickup and Warner 1976; Andrews 1980). In a study of 36 monitoring stations, Williams (1978) found an average recurrence interval of 1.5 years, although actual values ranged from 1.01 to 32 years and only 62% of the recurrence intervals were between one and two years. The bankfull discharge may have a constant recurrence interval in an individual stream, but the literature suggests that the variability can be high even within a drainage basin. Therefore, hydrological analyses should be conducted before assigning a recurrence interval to a bankfull discharge for a stream. October 2014 ESRD/CEAA Page 127

130 ESRD and CEAA Responses Water Frontier Oil Sands Mine Project c. Channel maintenance flows are non-consumptive instream flows that maintain the physical characteristics of the stream channel. Effective channel maintenance flow regimes have naturally variable flows of sufficient duration, magnitude, frequency, and timing to maintain channel morphology and streamside vegetation so that the capacity of the channel to convey natural flows is unimpaired over the long-term. Many approaches that deal with maintaining channel form and processes have addressed channel maintenance flows in natural channels (Andrews and Nankervis 1995; McNamara et al. 2000). Other approaches with broad geomorphic and ecosystems-based perspectives have also been presented (e.g., Hill et al. 1991; Whiting 2002). Channel maintenance in gravel-bed streams requires a range of instream flows that transport bedload sediment through the channel network. This flow regime prevents the stream from constricting because of in-channel sediment deposition or in-channel vegetation establishment. The range of flows provides sufficient high and low flows to sustain vital stream bank and floodplain vegetation. In coarse-grained, gravel-bed streams of the Rocky Mountains, low flows (which occur most of the year) transport a negligible amount of bed-load sediment. However, when higher flows begin to fill the channel near its capacity, coarse bed-load transport and scour of vegetation within the channel combine to help maintain channel morphology. These high flows also periodically inundate the floodplain, helping to sustain and regenerate stream bank and floodplain vegetation. Consequently, the intermediate to high flows (which typically occur only for a limited time during the year) provide the necessary stream channel maintenance (Schmidt and Potyondy 2004). Conceptually, the required maintenance flow regime begins at a discharge where transport-limited gravels making up the bed of the channel begin to move (Qtrigger). It includes all flows up to and including the instantaneous 25-year flow (Qcap). This range of flows moves all bed-load sediment, scours vegetation from the channel, partially inundates the floodplain, and provides high flow functions needed to sustain streamside vegetation. However, each site has unique requirements. Schmidt and Potendy (2004) summarized the scientific basis for channel maintenance based on sediment transport flows. They concluded that: bed-load transport is more important to channel formation and channel maintenance than suspended sediment in gravel-bed streams all flows capable of transporting bed-load sediment are important to channel morphology intermediate discharges (i.e., flows near bankfull or effective discharge) transport more sediment overall than other flows in gravel-bed channels because higher flows transport more bed-load sediment per unit volume of water, they are more efficient at transporting bed-load sediment a range of intermediate to high flows is needed to transport all bed-load sediment over the longterm using natural flows to assure transport of all of the mass and sizes of bed-load sediment (i.e., high flows by themselves lack sufficient duration and frequency to transport the entire load) ESRD/CEAA Page 128 October 2014

131 Frontier Oil Sands Mine Project ESRD and CEAA Responses Water d. The potential for decreased peak flows to affect fish habitat (i.e., through potential changes in channel regime) was assessed based on the assumption that a reduction in peak discharge would be neutral with respect to changes in channel regime. Although a reduction in peak discharge would reduce channel erosion rates, it could also cause localized sediment deposition in the stream channel. In the case of predicted reductions in peak flows for watercourses downstream of the Project area (i.e., Big Creek and Redclay Creek), the potential for in-channel sedimentation is low because of the presence of large waterbodies (pit lakes) upstream. These large, upstream waterbodies are expected to reduce the sediment supply to downstream watercourses and limit the opportunity for sediment aggradation. However, there are knowledge gaps and a high level of uncertainty associated with this prediction. For example, stream-specific effective channel maintenance flows (described in response to part b) are not known for Big Creek or Redclay Creek. Similarly, the prediction that reduced peak flows will have a neutral effect on the morphology of these two watercourses is also uncertain. In light of these gaps and uncertainties, Teck will monitor the flow regime, channel morphology and physical fish habitat characteristics for these watercourses. This monitoring would focus on: confirming the prediction that reduced peak flows will have a neutral effect on watercourse morphology identifying whether adverse effects occur quantifying potential effects on fish habitat productivity identifying appropriate compensation measures for inclusion in the Project s CFHCP In assessing the potential need for additional habitat productivity compensation measures, Teck considered that compensation is already provided for flow-related changes in lower Big Creek and Redclay Creek (i.e., reductions in mean annual flow and changes in habitat). Compensation is described in the revised CFHCP (see the response to ESRD/CEAA Round 2 SIR 30j, Appendix 30j.1). e. No updates to the CHFCP are proposed at this time based on the current assessment and the potential for reduced peak flows to affect channel regime. However, as discussed in the response to AER Round 3 SIR 1, an update to the is planned and will reflect revisions to the Project. The CHFCP may be revised as part of the updated application. In addition, if future monitoring results identify a change in channel regime or effects on fish habitat productivity beyond those currently predicted for the Project, appropriate compensation measures will be provided. October 2014 ESRD/CEAA Page 129

132 ESRD and CEAA Responses Water Frontier Oil Sands Mine Project f. As described in the responses to parts d and e, monitoring will be conducted to address potential habitat changes associated with reductions in peak flows. The plan will be updated accordingly should habitat change be documented beyond what is currently predicted and included in the CFHCP. The conceptual monitoring plan (see the response to ESRD/CEAA Round 3 SIR 24) will include monitoring of lower Big Creek and lower Redclay Creek to assess changes in peak flows, changes in the physical characteristics of the channels, and changes in fish habitat productivity. The plan will likely include: hydrologic monitoring of flows during Project operations and closure to establish the flow regime and identify changes that occur over time monitoring and measurement of physical channel dimensions (e.g., wetted width and depth, channel width and depth) to document changes in channel regime and available habitat area monitoring of fish habitat characteristics (e.g., channel unit type, distribution and area, instream and riparian cover and substrate particle size distribution) monitoring benthic invertebrate communities and fish populations relative to habitat productivity measures such as abundance and biomass The monitoring plan will be designed to confirm predicted reductions in peak flows and potential changes in channel regime. Data collected would help identify whether changes occur and what the effects would be (if any) on fish habitat productivity. The plan would also help determine the appropriate habitat productivity compensation to be incorporated into the CFHCP for the Project. This monitoring component would occur only if the PRM does not proceed, as this development will result in complete alteration of the relevant sections of lower Redclay Creek and Big Creek. g. The application of the 15% flow criteria presented in the Alberta Desk-top Method for Establishing Environmental Flows in Alberta Rivers and Streams (ESRD 2011) was based on the specific flow statistics provided in the hydrology assessment. For watercourses where a reduction in flow was predicted, mean annual flows were compared to the 15% flow criterion as an initial screening of the potential for the flow reductions to have flow-related effects on fish habitat. Mean annual flows were used in the initial screening to represent potential changes in average habitat conditions, which the Desk-top Method refers to as potential chronic effects of flow reduction on habitat availability and the aquatic ecosystem over the long-term. The Desk-top Method indicates that a reduction of 10% in average conditions would be considered small. Therefore, for cases where the predicted mean annual flow reductions were well below the 15% criteria (i.e., 10% change or less), no further analysis was conducted. If the change in mean annual flow was 15% or greater, the flow reduction was considered to have potential flow-related habitat effects. If the change in mean annual flow was between 10% and 15%, a secondary-level screening assessment was conducted that consisted of hydrological analysis to provide mean monthly flows, and screening mean monthly flows to determine if there are specific periods of the year where flow reductions are predicted to be 15% or greater. This screening was based on the consideration in ESRD/CEAA Page 130 October 2014

133 Frontier Oil Sands Mine Project ESRD and CEAA Responses Water the Desk-top Method that aspects of the assessment can be done on a monthly or weekly time-step. Once the potential for flow-related effects was identified, the actual assessment of potential changes in habitat was conducted based on an assessment of expected changes in habitat area using crosssectional profile data and predicted changes in flows and water levels. REFERENCES Andrews, E.D Effective and bankfull discharges of streams in the Yampa River basin, Colorado and Wyoming, Journal of Hydrology 46: Andrews, E.D. and J.M. Nankervis Effective discharge and the design of channel maintenance flows for gravel-bed rivers. In Costa, J. E., A.J. Miller, K.W. Potter, and P.R. Wilcock [eds.] Natural and Anthropogenic Influences in Fluvial Geomorphology. Geophysical Monograph 89. Washington, D.C.: American Geophysical Union: ESRD (Alberta Environment and Sustainable Resource Development) A Desk-top Method for Establishing Environmental Flows in Alberta Rivers and Streams. Government of Alberta: Water for Life. Alberta Environment and Sustainable Resource Development. April Golder (Golder Associates Ltd.) Geomorphic Characterization and Design of Alluvial Channels in the Athabasca Oil Sands Region. Prepared for Canadian Oil Sands Network for Research and Development and Department of Fisheries and Oceans. Harrelson, C.C., C.L. Rawlins and J.P. Potyondy Stream Channel Reference Sites: An Illustrated Guide to Field Technique. General Technical Report RM-245, Fort Collins, Colorado, United States Department of Agriculture, Forest Service, Rocky Mountain Forest and Range Experiment Station. Hill, M.T., W.S. Platts and R.L. Beschta Ecological and geomorphological concepts for instream and out-of-channel flow requirements. Rivers 2: Leopold, L.B., M.G. Wolman and J.P. Miller Fluvial Processes in Geomorphology. W.H. Freeman and Company, San Francisco, CA. McNamara, M. L., P.C. Klingeman, P.D. Bakke and R.J. Sullivan Channel maintenance flows in the Upper Klamath Basin, Oregon. In Wigington, P.J. and R.L. Beschta [eds.] Riparian Ecology and Management in Multi-land use Watersheds. TPS Middleburg, VA: American Water Resources Association. Pickup, G. and R. F. Warner Effects of hydrologic regime on the magnitude and frequency of dominant discharge. J. Hydrol. 29: Rosgen, D.L A classification of natural rivers. Catena 22: Schmidt, L.J. and J.P. Potyondy Quantifying Channel Maintenance Instream Flows: An Approach for Gravel-Bed Streams in the Western United States. Gen. Tech. Rep. RMRS-GTR-128. Fort Collins, CO: U.S. Department of Agriculture, Forest Service, Rocky Mountain Research Station. October 2014 ESRD/CEAA Page 131

134 ESRD and CEAA Responses Water Frontier Oil Sands Mine Project Smith, S.M. and K.L. Prestegaard Hydraulic performance of a morphology-based stream channel design. Water Resources Research 41: W Williams, G.P Bankfull discharge of rivers. Water Resources Research 14: Whiting, P. J Streamflow necessary for environmental maintenance. Annual Reviews Earth Planet. Science 30: Wolman, M.G. and L.B. Leopold River Flood Plains: Some Observations on Their Formation. U.S. Geological Survey Professional Paper 282-C. Question 17 SIR1, Volume 1, Section 10, SIRs 72 and 73, Pages SIR1, Volume 1, Section 5.5, SIR 111a, Pages to SIR 112, Pages to SIR1, Volume 1, Section 10, SIR 71 b, Page 148 SIR2, Volume 1, Aquatics, SIR 30 Teck refers repeatedly to the fish habitat compensation plan as offsetting the potential effects to fish and fish habitat associated with the Frontier Project. The most recent compensation plan provided in the SIR2 Response documents, although updated, retains notable gaps. (Note: these are examples and not a complete list of gaps and inconsistencies). a. Update the compensation plan and address the following in the aquatic ecology assessment: Revisit each conclusion for which the compensation plan is used to support the aquatic effects assessment and consider whether the certainty of the outcomes associated with compensation plan as presented is appropriate to fully invalidate a linkage, support the conclusion, and has considered the broad suite of potential aquatic ecological effects and the uncertainty. Response 17 a. The linkage pathways considered in the fish and fish habitat assessment are provided in the response to ESRD/CEAA Round 3 SIR 42b, Table 42b-1. For each assessment pathway, Table 42b-1 summarizes the assessment conclusions and identifies conclusions that reference the CFHCP or FHCL as mitigation. Table 42b-1 also indicates the level of confidence and any knowledge gaps associated with each assessment conclusion. The CFHCP does not invalidate any of the pathway linkages, but is considered to mitigate potential effects of the Project on: fish habitat (i.e., predicted changes in streamflow, habitat area, suspended sediment levels and benthic invertebrate communities) fish abundance (based on predicted effects on habitat) fish and fish habitat diversity (based on predicted effects on habitat) ESRD/CEAA Page 132 October 2014

135 Frontier Oil Sands Mine Project ESRD and CEAA Responses Water As described in Table 42b-1, there is a high level of confidence that the FHCL will provide the required compensation for fish habitat productivity, fish abundance, and fish and fish habitat diversity based on current expectations for fish community development (see the response to ESRD/CEAA Round 3 SIR 20 and SIR 35a) and productivity (see the response to ESRD/CEAA Round 3 SIRs 20bc, 23 and 29b). Based on the conclusions of the fish and fish assessment, updating the CFHCP is not necessary. However, further development of the CFHCP is ongoing, in consultation with regulators and potential Aboriginal communities, as part of detailed compensation planning for the Project (see the response to ESRD/CEAA Round 3 SIR 23). In addition, revisions to the fish and fish habitat assessment will be considered as part of the Project Update (see the response to AER Round 3 SIR 1). As a result, the CFHCP might also require updating. Question 18 SIR1, Volume 1, Section 10, SIRs 72 and 73, Pages SIR1, Volume 1, Section 5.5, SIR 111a, Pages to SIR 112, Pages to SIR1, Volume 1, Section 10, SIR 71 b, Page 148 SIR2, Volume 1, Aquatics, SIR 30 TOR [A] directs Teck to provide documentation of calibration, validation, and assumptions, a discussion of model limitations and how they were addressed, and to include a discussion of error and accuracy. Teck references Shell 2008 with respect to habitat suitability index models applied in the fish compensation plan and habitat assessment. Shell 2008 is neither peer-reviewed nor easily publicly accessible. a. Provide the HSI models applied for both habitat losses and gains. b. Provide the above-noted discussion of calibration, validation, assumptions, model limitations, and a discussion of error and accuracy. c. Provide peer-reviewed support for the use of area as a proxy for aquatic productivity. d. Provide peer-reviewed support for the implied conclusion that aquatic productivity is similar on an aerial basis for lentic and lotic habitat. e. Provide reference to and discussion of instrumented watersheds, previously constructed and currently operating compensation habitats, or monitoring/research that has been undertaken to confirm that the chosen approach will reasonably compensate for habitat and fish productivity losses associated with the mine. October 2014 ESRD/CEAA Page 133

136 ESRD and CEAA Responses Water Frontier Oil Sands Mine Project Response 18 a. Species-specific habitat suitability index (HSI) models were applied to the watercourses and waterbodies where habitat losses were identified as part of the revised CFHCP (see the response to ESRD/CEAA Round 2 SIR 30j, Appendix 30j.1). The revised CFHCP used an updated version of the fish HSI models developed specifically for the oil sands region (Golder 2008). Development of the updated regional oil sands HSI model document was facilitated by Fisheries and Oceans Canada (DFO) and copies are available through DFO. The updated HSI document (Golder 2008) is also provided in Appendix 18a.1. Results of HSI modelling completed for the Project, including the model components and calculated HSI values for habitat losses, are provided in the revised CFHCP (see Appendix 30j.1, Attachment 30j.1A). As described in response to ESRD/CEAA Round 3 SIR 20a, the revised CFHCP provides a list of candidate fish species that could be included in the FHCL fish community, but the actual proposed species assemblage has not yet been determined and will be finalized as part of development of the detailed compensation plan. This plan will be developed in consultation with regulators, potentially affected Aboriginal communities and stakeholders. Detailed HSI modelling has not yet been completed to predict the specific habitat gains expected for the FHCL. Once the target fish community for the FHCL is finalized, detailed design of the lake will be completed based on the habitat requirements of the target species and their various life stages. Regional HSI models (Golder 2008, lactustrine component) for these fish species will be applied to the FHCL to calculate the expected habitat gains. Model components and calculated HSI values will be provided in the detailed compensation plan, along with any updates to the HSI modelling results for habitat losses. b. Development of HSI models for the Alberta oil sands region was completed by experts in fish biology and the habitat requirements of species occurring in the oil sands region. These models are based on previously published HSI models (where available), current scientific literature, fisheries survey data, comparisons to habitat requirements of sympatric species and the professional knowledge and experience of fisheries scientists and technicians (Golder 2008). These models can be modified or refined as new information becomes available (i.e., through ongoing fish and fish habitat monitoring and HSI validation efforts for developments in the oil sands region). As described in response to ESRD/CEAA Round 1 SIR 105a, HSI models developed for use in the oil sands region (Golder 2008) have not yet been validated. The 2008 versions of the models have been used in various validation exercises being conducted by other oil sands proponents; however, this work is still in progress. Recently, the Fisheries Sustainable Habitat (FiSH) Committee of the Oil Sands Developers Group (OSDG), of which Teck is a member, was formed to develop a standardized and more focused approach to the Fisheries Act monitoring required of various oil sands developers. The FiSH Committee has begun work to centralize the data associated with predisturbance monitoring and HSI model validation, with the goal of better coordinating validation ESRD/CEAA Page 134 October 2014

137 Frontier Oil Sands Mine Project ESRD and CEAA Responses Water exercises for the region. It is not known when the regional assessment of HSI validation data will be complete or when revisions to the 2008 version of the models will be available. Recent authorizations for oil sands operations provided by DFO under the Fisheries Act typically require that the proponent: conduct HSI model validation exercises within the affected habitats in the Project area adjust the models based on the Project as well as regional validation results apply the adjusted models to Project habitat losses and gains to refine the accuracy of model predictions The specific error or accuracy of the current version of the regional HSI models is unknown, but it is under investigation as part of the regional verification exercise. At present, the FiSH Committee has completed Phases 1 and 2 of its model validation efforts, but actual model refinement has not yet been conducted (Ecofish and Hatfield 2014). HSI models typically assume that: an area of aquatic habitat can be composed of a variety of habitat types these habitat types will have differing levels of suitability for different fish species habitat suitability can be quantified based on measurable biological, chemical and physical characteristics of habitat that are required by a species throughout its life cycle (e.g., suitable food, cover, reproduction) (USFWS 1980a; Golder 2008) Teck took a conservative approaching applying HSI models to the affected habitats. In cases where there was insufficient field data to determine a HSI value for a variable, a value of 1.0 (optimal) was assigned. In other words, Teck assumed that no habitat limitation was present in instances where no habitat limitation was defined. Another important consideration when applying HSI models to calculate habitat losses is the distribution of fish species within the study area (Golder 2008). Again, Teck took a conservative approach and applied HSI models for fish species documented to be present in the affected habitats as well as species assumed to be present (i.e., species that could be present). For details, see the revised CFHCP provided in the response to ESRD/CEAA Round 2 SIR 30j, Appendix 30j.1. The HSI approach is intended for situations in which measureable and predictable habitat changes are an important variable (USFWS 1980b); this is true of the Frontier Project. However, a habitatbased approach might not include all of the environmental or behavioural variables that can limit populations below the habitat potential. To accommodate this limitation, Teck applied the HSI models to all fish species present in the affected habitats, and all fish species expected in the compensation habitats, to account for the same level of habitat partitioning. October 2014 ESRD/CEAA Page 135

138 ESRD and CEAA Responses Water Frontier Oil Sands Mine Project c. Habitat suitability models and the evaluation process for quantifying habitat losses and gains do not rely exclusively on habitat area as a proxy for aquatic productivity. As described in response to ESRD/CEAA Round 3 SIR 20b, the revised CFHCP uses the habitat evaluation procedures (HEP) developed by the U.S. Fish and Wildlife Service (USFWS 1976). This methodology documents both the quantity and quality of available habitat for selected species. Habitat quantity is defined by surface area and habitat quality is defined based on species-specific HSI that describe the ability of key habitat components to supply the life requisites of the species. Habitat quantity and habitat quality are combined to derive habitat units (HUs), which are used to represent the overall value of the habitat and to assess the degree to which productive capacity is affected or provided (Bradbury et al. 2001; Golder 2008; Packman et al. 2006). Although habitat area is a key component of HU calculations, it is not a proxy for habitat productivity. Habitat area is combined with another vital component, habitat suitability, which is the suitability of the habitat to supply the space, cover and other key requirements for the species (USFWS 1980b). d. There is no conclusion in the HSI modelling approach or in the revised CFHCP that productivity is similar on an aerial basis for lentic and lotic habitats. The FHCL includes the development of lentic habitats to compensate for productivity losses in affected habitats. Small portions (23%) of the affected areas are lotic habitats compared to affected lentic habitats (77%). However, each of the affected habitat areas and compensation habitat areas (lotic or lentic) are evaluated individually based on the specific level of productivity they provide for each of the potentially affected species. This is achieved by calculating HUs, as described in the response to part c. A key part of the HU calculations is determining the ability of key habitat components to supply the life requisites of the species through the application of the species-specific HSI models. The relevant component (i.e., lacustrine or riverine) of each HSI model is used, depending on whether the habitat under consideration is lentic or lotic. Although habitat area is a component of the HU calculations, habitat type and suitability are also fully considered. e. As described in the response to ESRD/CEAA Round 1 SIR 120f: Although similar habitat compensation works are in development in the oil sands region (i.e., planning, construction, filling or post-filling), their success... [in providing full compensation for predicted effects on habitat productivity] has not yet been demonstrated. The most advanced of the compensation works is the Horizon project s compensation lake. Following filling, the biological development of this lake has been monitored from 2008 to... [2012 (Golder 2013)]. Results to date indicate that aquatic macrophytes have established and are expanding naturally. Benthic invertebrate and planktonic communities are well established, and fish populations for some species (i.e.,... [Arctic grayling,] both white and longnose suckers [and several forage fish species]) have naturally colonized the lake. Fish populations are expanding with successful spawning and recruitment documented, and the one introduced forage fish species is establishing well. ESRD/CEAA Page 136 October 2014

139 Frontier Oil Sands Mine Project ESRD and CEAA Responses Water Another compensation lake for which preliminary monitoring data is available is the Shell Jackpine compensation lake. This lake is also in the early stages of development, having been filled in spring 2010 and monitored for biological development for three years (2010 to 2012). Monitoring results for primary productivity, secondary productivity and fish populations indicate that, based on the biological colonization observed to date for plankton, macrophytes, benthic invertebrates and fish, the compensation lake has progressed at the anticipated rate of biological development (Hatfield 2013). At present, the lake has achieved similarity to the reference lake (i.e., Kearl Lake) for some benthic invertebrate metrics, but at this early date has not yet achieved anticipated end-point productivity levels. The documented fish community to date consists of sport fish, suckers and forage fish species, including northern pike, white sucker, longnose sucker, lake chub and fathead minnow. In addition to monitoring data from the Horizon and Jackpine compensation lakes, other oil sands operators have recently initiated or will soon be starting monitoring and research programs for their compensation habitats. These monitoring programs are designed to assess the effectiveness of the compensation habitats and will provide future information about the success (or lack thereof) of these compensation measures that will be useful to inform regional operators, regulators and stakeholders. For compensation works outside the oil sands region, Quigley and Harper (2006) presented a metaanalysis on compensation habitats in Canada. None of the case studies presented are directly applicable to the Project because compensation habitats were not located in the oil sands region and the type of habitat compensation was primarily creation or enhancement of in-channel habitat within lotic systems. The study determined that 37% of the compensation projects analyzed were successful in providing effective compensation or increased productivity; however, 63% of the projects did not fully compensate for productivity losses. Quigley and Harper (2006) identified several causes contributing to the failure to achieve complete compensation. These included: habitat loss or alteration greater than that which was authorized actual areas of compensation habitats less than required compensation habitats selected opportunistically rather than based on ecology lack of baseline and post-construction monitoring lack of sufficient oversight and enforcement These results provide a valuable indication of factors to avoid in developing effective compensation habitats. However, they are not considered relevant to the Frontier Project, the CFHCP, or current compensation works in the oil sands region given that Fisheries Act authorizations provided by DFO for oil sands compensation works typically include specific requirements for: identifying authorized habitat losses and alterations identifying compensation habitat areas designing compensation habitats based on fish habitat requirements monitoring and evaluating fish habitat productivity October 2014 ESRD/CEAA Page 137

140 ESRD and CEAA Responses Water Frontier Oil Sands Mine Project continually overseeing the authorized works providing additional compensation, if necessary REFERENCES Bradbury, C., A.S. Power and M.M. Roberge Standard Methods Guide for the Classification / Quantification of Lacustrine Habitat in Newfoundland and Labrador. Fisheries and Oceans, St. John s, Newfoundland. Ecofish (Ecofish Research) and Hatfield (Hatfield Consultants) Refinement of Fish Habitat Pre- Disturbance Models Phase 2. Prepared for OSDG FiSH Committee. Fort McMurray, Alberta. February FISH Golder (Golder Associates Ltd.) Fish Species Habitat Suitability Index Models for the Alberta Oil Sands Region. Version 2.0. October Golder Horizon Lake Monitoring Report. Prepared for Canadian Natural Resources Limited. Calgary, Alberta. June Hatfield (Hatfield Consultants) Jackpine Compensation Lake Monitoring Program, Prepared for Shell Canada Energy, Fort McMurray, Alberta. April Quigley, J.T. and D.J. Harper Effectiveness of fish habitat compensation in Canada in achieving no net loss. Environmental Management 37: Packman, G.A., D.J. Harper, S.C. Samis and D. Lampi Review of Approaches for Estimating Changes in Productive Capacity from Whole-Lake / Stream Destruction and Related Compensation Projects. Canadian Technical Report of Fisheries and Aquatic Sciences USFWS (U.S. Fish and Wildlife Service) Habitat Evaluation Procedures. Division of Ecological Services, Department of the Interior. Washington, D.C. USFWS. 1980a. Habitat Evaluation Procedures Ecological Services Manual (102 ESM). Division of Ecological Services, Department of the Interior. Washington, D.C. USFWS. 1980b. Habitat as a Basis for Environmental Assessment Ecological Services Manual (101 ESM). Division of Ecological Services, Department of the Interior. Washington, D.C. ESRD/CEAA Page 138 October 2014

141 Frontier Oil Sands Mine Project ESRD and CEAA Responses Water Question 19 SIR1, Volume 1, Section 10, SIRs 72 and 73, Pages SIR1, Volume 1, Section 5.5, SIR 111a, Pages to SIR 112, Pages to SIR1, Volume 1, Section 10, SIR 71 b, Page 148 SIR2, Volume 1, Aquatics, SIR 30 Flooding of terrestrial habitat to create aquatic habitat has known risks with respect to the elevation of certain water quality constituents. a. Provide water quality predictions for the compensation lake during filling, operations, and postclosure. b. Identify how any water quality concerns will be addressed. c. Clarify whether downstream habitat and aquatic systems will be influenced. d. Support the conclusions with reference to peer-reviewed literature and data from similar operations. Response 19 a. The fish habitat compensation lake (FHCL) for the Project will be developed by constructing a containment landform across Redclay Creek downstream from the confluence with Unnamed Creek 8 (see Volume 1, Section , Page 15-19). As explained in Volume 5, Section , Page 4-65, for all snapshots after construction, water quality of the FHCL was modelled at the Redclay Creek assessment node. This includes predictions for both the Application Case and Planned Development Case (PDC). For both assessment scenarios, predicted water quality of the FHCL is represented by the predictions at the Redclay Creek assessment node. Water quality predictions at the Redclay Creek assessment node during operation, closure and postclosure are presented in Volume 5, Section , Table 4-12, Pages 4-69 to 4-71, and revised in the response to ESRD/CEAA Round 1 SIR 45a, Appendix 45a.7. Revisions made to the CFHCP (see the response to ESRD/CEAA Round 2 SIR 30j, Appendix 30j.1) would reduce predicted peak concentrations in the FHCL because of the longer residence time. Water quality predictions for the FHCL that are specific to fish habitat requirements will be considered as part detailed compensation planning. The assessment may be updated further as part of the Project Update (see AER Round 3 SIR 1), if required, during future stages of engineering. b. The methods for addressing water quality concerns will depend on the specific nature and details of the concerns. For example, concerns related to DO or temperature will be addressed by modifying the physical or hydrologic design to the lake, if necessary. October 2014 ESRD/CEAA Page 139

142 ESRD and CEAA Responses Water Frontier Oil Sands Mine Project A concern that may be identified through monitoring is methylmercury concentrations. As indicated in the response to ESRD/CEAA Round 1 SIR 424d: Inundated reservoirs typically experience increased mercury concentrations in water and biotic components relative to baseline conditions because of flooding and decomposition of formerly terrestrial areas and peatlands that result in mercury methylation and liberation. Mitigation measures that might be implemented to reduce the potential for mercury production or accumulation in fish include: intensive and selective fishing manipulation of growth and food web structure prohibition of recreational and consumption uses of fish during the first years of impoundment excavation of the potential FHCL site instead of flooding a vegetated area increasing the water ph These strategies are described in the responses to ESRD/CEAA Round 1 SIR 424d and ESRD/CEAA Round 2 SIR 174a. Teck will follow adaptive management practices for constructed waterbodies (see the response to ERCB Round 1 SIR 88a) and will monitor the quality of onsite and receiving waters throughout construction, operations and closure. As information becomes available, Teck will periodically revisit the water quality model predictions to validate the inputs. If the results of monitoring or modelling indicate that water quality may be compromised in receiving waters, additional follow-up monitoring and modelling will be used to inform which adaptive management strategies can be implemented. c. The proposed fish habitat compensation lake for PRM will be located downstream of the FHCL for the Frontier Project (see Volume 1, Section , Page and the response to ESRD/CEAA Round 1 SIR 40b). Water quality predictions for the PRM fish habitat compensation lake are presented in Volume 5, Section , Table 4-15, Pages 4-78 to 4-80 and revised in the response to ESRD/CEAA Round 1 SIR 45a, Appendix 45a.7. As mentioned in the response to ESRD/CEAA Round 1 SIR 89a, some water quality parameters for the PRM fish habitat compensation lake are predicted to be above screening criteria. These predictions are the result of naturally high levels of metals associated with high TSS that is, in turn, associated with erosion of the polymetallic black shales that outcrop on the Birch Mountains west of the Project. The PRM compensation lake is expected to be viable for fish despite some values being potentially above guidelines (see the response to ESRD/CEAA Round 1 SIR 393a). For example: Because CEBs for aluminum and iron are highly conservative (see the response to ESRD/CEAA Round 3 SIR 11), predicted exceedances of these thresholds do not likely indicate adverse effects to aquatic health. ESRD/CEAA Page 140 October 2014

143 Frontier Oil Sands Mine Project ESRD and CEAA Responses Water Predicted concentrations of strontium are below thresholds that were derived in conjunction with a thorough review of applicable toxicological literature. It is expected that the mitigation strategies implemented to reduce the potential for mercury production or reduce mercury levels in fish in the Project FHCL will limit mercury transfer rates to downstream habitats and aquatic systems (see the responses to ESRD/CEAA Round 1 SIR 424d, ESRD/CEAA Round 2 SIR 174a, and part b of this SIR). These mitigation strategies would minimize the influence on the downstream aquatic habitats. d. Mailman et al. (2006) reviewed several mitigation strategies aimed at minimizing production and biological uptake of methylmercury (MeHg) in reservoirs and lakes. Several of these strategies are described in the responses to ESRD/CEAA Round 1 SIR 424d and ESRD/CEAA Round 2 SIR 174a. Although the appropriateness of different mitigation strategies depends on the design and site-specific conditions of the reservoir, a summary of their effectiveness and relevance to the Project follows. Site selection and Project configuration: Excavation of the FHCL site reflects this mitigation strategy. Constructing the FHCL in a site with exposed bedrock, low organic matter density (or both) would limit the number of microorganisms and amount of labile organic carbon available. Mercury methylation by microorganisms is stimulated by organic carbon found in soils, vegetation and peat, and is enhanced by anoxic conditions typically present in reservoirs (Mailman et al. 2006). Since methylation rates are greater in warm temperatures (Mailman et al. 2006), excavating the FHCL site would create a deeper system that is less prone to warmer bed temperatures in the summer. Hall et al. (2009) found that the amount of terrestrial carbon in the flooded site was not correlated to the concentration of MeHg in zooplankton, but was correlated to the duration of elevated MeHg concentrations. Therefore, sites with lower carbon contents are expected to sustain high MeHg concentrations for shorter periods of time than sites with high carbon contents. Intensive fishing: This strategy involves manipulating the growth and food web structure as described in the responses to ESRD/CEAA Round 1 SIR 424d and ESRD/CEAA Round 2 SIR 174a. This strategy may reduce MeHg in the system by: physically removing MeHg from the system through intensive fishing modifying fish growth rates, which would result in new fish having lower MeHg tissue concentrations altering the food web structure such that larger fish would prey on smaller fish with lower MeHg concentrations (Mailman et al. 2006). This mechanism would be most effective when combined with stocking of relatively high-quality, low-mercury forage fish developed elsewhere (Lepak et al. 2012). Although the prohibition of recreational and consumption uses of fish during the initial years of impoundment is not explicitly described by Mailman et al. (2006), it has been found that elevated fish MeHg concentrations do appear during the first few years of impoundment (Mailman et al. 2006). Hall et al. (2009) reported a decrease of zooplankton MeHg concentrations to pre- October 2014 ESRD/CEAA Page 141

144 ESRD and CEAA Responses Water Frontier Oil Sands Mine Project impoundment values five years after impoundment. As mentioned, reduced zooplankton MeHg concentrations would likely result in reduced fish MeHg concentrations. Lime addition to acidified systems: As mentioned in the responses to ESRD/CEAA Round 1 SIR 424d and ESRD/CEAA Round 2 SIR 174a, ph levels might decrease because of increased dissolved organic carbon. This typically results from organic matter degradation, but the mechanisms remain unclear (Mailman et al. 2006). Some studies report that methylation increases at lower ph (Hintelmann et al. 1995; Miskimmin et al. 1992); however, this result might have been because mercury bound to dissolved organic carbon decreases with acidity and results in the release of MeHg from sediments. It might also be related to the effect ph has on the structure of the microbial ecosystem or the availability of Hg to methylating organisms (Mailman et al. 2006). In consequence, adding lime could be a useful mitigation strategy for fish MeHg concentrations in systems with low ph. As discussed in the responses to ESRD/CEAA Round 1 SIR 420a and ESRD/CEAA Round 2 SIR 174a, plans for the FHCL are still at a conceptual level. All of the MeHg mitigation strategies described, and the detailed design of the other components of the FHCL, will be carefully considered in consultation with regulators and potentially affected Aboriginal communities before submitting of the final plan. Several other mitigation strategies are discussed in Mailman et al. (2006) and elsewhere (e.g., Winfrey and Rudd 1990; Bloom et al. 1991; Miskimmin et al. 1992; St. Louis et al. 2004; Bodaly et al. 2007). Teck will consider these strategies and any relevant new research in developing the final fish habitat compensation plan. Habitat compensation similar to the FHCL is being developed elsewhere in the oil sands region (see the responses to ESRD/CEAA Round 1 SIR 120f and ESRD/CEAA Round 2 SIR 49a). The Horizon project s fish habitat compensation lake is the most advanced of the compensation works, and results of biological monitoring between 2008 and 2011 (Golder 2012) indicate that: aquatic macrophytes have established and are expanding naturally benthic invertebrate and planktonic communities are well established some species (i.e., forage fish, white sucker and both white and longnose suckers) have naturally colonized the lake fish populations are expanding with successful spawning and recruitment documented the one introduced forage fish species is establishing well Based on these results, Teck expects that the Frontier Project FHCL will meet the habitat requirements of the various life stages of fish that use the constructed habitat, and will do so in a similar timeframe. ESRD/CEAA Page 142 October 2014

145 Frontier Oil Sands Mine Project ESRD and CEAA Responses Water REFERENCES Bloom, N.S., C.J. Watras and J.P. Hurley Impact of acidification on the methylmercury cycle of remote seepage lakes. Water, Air and Soil Pollution 56: Bodaly, R.A.D., W.A. Jansen, A.R. Majewski, R.J.P. Fudge, N.E. Strange, A.J. Derksen and D.J. Green Postimpoundment time course of increased mercury concentrations in fish in hydroelectric reservoirs of northern Manitoba, Canada. Archives of Environmental Contamination and Toxicology 53: Golder (Golder Associates Ltd.) Horizon Lake Monitoring Report. Submitted to Canadian Natural Resources Limited. Calgary, Alberta. June Hall, B.D., K.A. Cherewyk, M.J. Paterson and R.A. Bodaly Changes in methyl mercury concentrations in zooplankton from four experimental reservoirs with differing amounts of carbon in the flooded catchments. Canadian Journal of Fisheries and Aquatic Science 66: Hintelmann H., P.M. Welbourn and R.D. Evans Binding of methylmercury compounds by humic and fulvic acids. Water, Air and Soil Pollution 80: Lepak, J.M., K-D. Kinzli, E.R. Fetherman, W.M. Pate, A.G. Hansen, E.I. Gardunio, C.N. Cathcart, W.L. Stacy, Z.E. Underwood, M.M. Brandt, C.A. Myrick and B.M. Johnson Manipulation of sport fish growth to reduce mercury bioaccumulation on a whole-system scale. Canadian Journal of Fisheries and Aquatic Sciences 69: Mailman, M., L. Stepnuk, N. Cicek and R.A. Bodaly Strategies to lower methyl mercury concentrations in hydroelectric reservoirs and lakes: A review. Science of the Total Environment 368: Miskimmin, B.M., J.W.M. Rudd and C.A. Kelly Influence of dissolved organic carbon, ph, and microbial respiration rates on mercury methylation and demethylation in lake water. Canadian Journal of Fisheries and Aquatic Sciences 49: St. Louis, V.L., J.W.M. Rudd, C.A. Kelly, R.A.D. Bodaly, M.J. Paterson and K.G. Beaty The rise and fall of mercury methylation in an experimental reservoir. Environmental Science and Technology 38: Winfrey, M.R. and J.W.M. Rudd Environmental factors affecting the formation of methylmercury in low ph lakes. Environmental Toxicology and Chemistry 9: October 2014 ESRD/CEAA Page 143

146 ESRD and CEAA Responses Water Frontier Oil Sands Mine Project Question 20 SIR1, Volume 1, Section 10, SIRs 72 and 73, Pages SIR1, Volume 1, Section 5.5, SIR 111a, Pages to SIR 112, Pages to SIR1, Volume 1, Section 10, SIR 71 b, Page 148 SIR2, Volume 1, Aquatics, SIR 30 The proposed compensation lake fish species complement includes walleye, yellow perch, northern pike, white sucker, longnose sucker, and a forage fish complement. The proposed compensation lake is 107 ha in size. The mean species complement for a natural lake of this size and latitude in northern Alberta appears to be 3-4 species. Teck proposes seven species for the compensation lake, three sport fish and two sucker species, which is also inconsistent with what might be expected in a natural lake of this size and latitude. Teck also seems to suggest that the successful species complement can be predicted based on habitat alone. a. Provide a rationale for why the species assemblage would be anticipated to differ so greatly from what would be expected in a similar natural lake. Support the rationale with reference to stable and successful compensation habitats similar in size and proposed species complement. b. Provide a rationale for predicting a successful species complement based on habitat alone. Support this with peer-reviewed literature. c. Provide a discussion of other biological factors which might influence the final stable species complement such as inter- and intra-specific interaction, competition, and predation. Support the discussion with peer-reviewed literature. d. Adjust the proposed species complement to one that is precautionary and consistent with what would be expected in a natural, northern Alberta lake of this size, depth and latitude. e. Identify whether, with the adjusted species complement, additional lake area will be required to meet compensation requirements. If additional lake area will be required, update the terrestrial effects conclusions to consider the additional terrestrial habitat losses. Response 20 a. The revised CFHCP for the Project (see the response to ESRD/CEAA Round 2 SIR 30j, Appendix 30j.1) identifies candidate species that would be considered for inclusion in the fish habitat compensation lake (FHCL) species assemblage (see Appendix 30j.1, Section ). This list consists of nine fish species and includes: sport fish (walleye, yellow perch and northern pike) ESRD/CEAA Page 144 October 2014

147 Frontier Oil Sands Mine Project ESRD and CEAA Responses Water suckers (longnose and white sucker) some of the main forage fish species that occur in the affected habitats (brook stickleback, lake chub, fathead minnow and pearl dace) The final species assemblage for the FHCL has not yet been determined and will be finalized in consultation with regulators and potentially affected Aboriginal communities as part of the detailed compensation plan. Teck expects that some or all of the fish species included in the FHCL will come from the list of candidate species; therefore, the conceptual design of the FHCL is based on this candidate list. Although the specific composition of the FHCL fish community is still to be determined, the revised CFHCP proposes a total of seven fish species for the FHCL, including a currently undetermined mix of sport fish, suckers and forage fish species. Teck plans to consult with regulators and potentially affected Aboriginal communities about an appropriate fish community assemblage for the FHCL and will consider factors such as regional management objectives, fish communities present in regional waterbodies, and balancing the various trophic levels represented by sport fish, suckers and forage fish species to achieve a sustainable FHCL fish community. Teck expects to finalize the species composition for the FHCL fish community in conjunction with refinement of the physical characteristics of the FHCL, moving progressively from the conceptual stage to the detailed design stage. The detailed design of the FHCL will be driven largely by the preferred fish community and life history requirements of the target fish species. The final size and dimensions of the FHCL will be determined based on the number of species to be included in the target fish community, and further refinement of habitat gain calculations. Both of these tasks are part of the detailed compensation planning phase. COMPARISON TO NATURAL WATERBODIES A FHCL community comprising seven fish species does not differ from what would be expected in a similar natural lake at this latitude. The graph shown in Figure 20a-1 plots the number of fish species reported in northern Alberta lakes up to 150 ha in size (surface area). The figure includes 57 named and unnamed waterbodies located in northern Alberta (i.e., Edmonton area and north). The number of fish species was obtained from the ESRD Fisheries and Wildlife Management Information System (FWMIS) database. This plot is similar to the one provided in response to ESRD/CEAA Round 1 SIR 106a, Figure 106a-1, but has been updated to include FWMIS data through 2013 and reflect the proposed number of fish species (seven) for the FHCL (as outlined in the revised CFHCP). October 2014 ESRD/CEAA Page 145

148 ESRD and CEAA Responses Water Frontier Oil Sands Mine Project Figure 20a-1 shows that lake size is not a good indicator or predictor for fish community size, and that lake size and surface area do not correlate well. Nonetheless, the size of the FHCL and number of fish species expected for the FHCL is within the range shown for naturally occurring waterbodies in northern Alberta. The number of fish species documented in waterbodies similar in size to the FHCL (i.e., ± 10 ha) ranges from one to eight species. In addition, seven or more fish species have been recorded in lakes ranging from 53 ha to 102 ha Number of Species Recorded Surface Area (ha) Regional Lakes Frontier FHCL Horizon Compensation Lake Kearl Compensation Lake Figure 20a-1 Surface Area Versus Number of Fish Species for Northern Alberta Waterbodies Not only is the number of fish species in the FHCL within the range recorded in natural waterbodies in the same region, but the number of fish species recorded in some of these natural waterbodies is likely under-represented because of sampling bias. Many of these waterbodies have not been sampled using techniques suitable for documenting the presence or absence of both large- and smallbodied fish species. For example, 6 of the 10 natural waterbodies closest in size to the FHCL were not sampled for both small and large-bodied fish species, and 7 of these 10 natural waterbodies do not show any forage fish species in their respective fish communities. Given this obvious sampling bias, the full fish species assemblage present in these natural waterbodies is not known and is likely ESRD/CEAA Page 146 October 2014

149 Frontier Oil Sands Mine Project ESRD and CEAA Responses Water higher than current data shows. As evidence of this, it was noted that the number of fish species documented in some of the lakes presented in Figure 20a-1 was higher in the FWMIS database in 2013 than previously seen for the same analysis (i.e., see the response to ESRD/CEAA Round 1 SIR 106a, Figure 106a-1), which was attributed to additional sampling effort. For natural waterbodies in the 53 ha to 102 ha range that support seven or more fish species, the species assemblage in some of these lakes is supported by stocking one or more sport fish species and, in one case, by aerating the lake in the winter to maintain dissolved oxygen levels. The need to stock or aerate is typically because of a lack of spawning and overwintering habitat, which limits the capacity for self-sustaining populations. By comparison, the FHCL is designed to provide year-round habitat to support a self-sustaining fish community. The Project s FHCL will include fish habitat features (e.g., deep-water overwintering habitats) that might not be present in some northern Alberta natural waterbodies of this size, but which are important aspects of fish productivity. Further, the FHCL is designed to provide specific habitat components to support the requirements of all life stages of every fish species in the target fish community, something that might also be lacking in natural waterbodies in this size range because of limited habitat diversity. As such, the FHCL has the potential to provide better-than-average fish habitat productivity compared to many natural waterbodies the same size. COMPARISON TO SIMILAR COMPENSATION LAKES There are currently no examples of stable and successful compensation lake habitats in in the oil sands region that are similar in size to the FHCL. Compensation lakes in the region are still relatively new, having been in operation for only a few years. The longest-operating regional compensation lake similar to the FHCL is the CNRL Horizon compensation lake, which is 76.7 ha in size and has a target assemblage of nine fish species. Horizon Lake was constructed and filled in 2008 and has been developing biologically for five years (2008 to 2013). Recent monitoring results (Golder 2013) show the presence of nine fish species in Horizon Lake, including one sport fish species (Arctic grayling), two sucker species (longnose and white sucker), and six forage fish species (brook stickleback, fathead minnow, finescale dace, lake chub, slimy sculpin and trout-perch). This fish community has developed largely by natural colonization, although one stocking event was conducted for fathead minnow. Given the early stage of development for the Horizon Lake, it is not yet considered stable, and it is not known what the species complement of the fish community will be as time progresses, adaptive management continues and the fish community matures. Nonetheless, early results are encouraging with respect to potential species abundance and diversity. October 2014 ESRD/CEAA Page 147

150 ESRD and CEAA Responses Water Frontier Oil Sands Mine Project b. The revised CFHCP, in part, uses the habitat evaluation procedures (HEP) developed by the U.S. Fish and Wildlife Service (USFWS 1976). This methodology documents the quantity and quality of available habitat for selected species and was developed for use in impact assessments, project planning and compensation analysis (USFWS 1980a). Habitat quantity is defined by surface area and habitat quality is defined based on a species-specific habitat suitability index (HSI). The HSI is derived from the ability of key habitat components to supply the life requisites of the species, and is considered an index of the species carrying capacity. Although HEP are considered a habitat-based approach, its developers describe them as: a species-habitat approach that is intended to incorporate concepts from both the population and habitat theories of impact assessment by evaluating habitat quality for specific species (USFWS 1980b) In the revised CFHCP, HEP were used to: quantify the quantity and quality of affected habitats and species estimate the size of the FHCL, based on achieving levels of habitat suitability typically estimated for constructed habitats in the oil sands region for the proposed fish community of seven species The HEP developers recognize that habitat is not the only basis for environmental assessment and that predation and competition can affect the number of individuals using a particular habitat (USFWS 1980b). Therefore, the candidate species list and the final proposed fish community for the FHCL will depend on what can feasibly be achieved, based on consultation with regulators and potentially affected Aboriginal communities and considering factors such as regional management objectives, fish communities present in regional waterbodies, and a sustainable mix of the trophic levels represented by sport fish, suckers and forage fish species. The HEP methodology was applied to the affected habitats and their associated fish communities as well as the FHCL. The affected habitats currently support several fish species and include some habitats that support a mix of sport fish, suckers and forage fish species. For habitats that support a variety of fish species, species-specific HSI values were assigned to the same habitat area, and the same process was used for both the affected and compensation habitats. The list of candidate fish species for the FHCL, with the exception of yellow perch, is similar to the species complement in the affected habitats that have sufficient habitat diversity to support cohabitation by a mix of sport, sucker and forage fish species. In addition to using HEP to predict habitat productivity in the FHCL, Teck examined fish communities in northern Alberta lakes to further evaluate the list of candidate species for the FHCL (see the response to part a) and the proposed mix of sport fish, suckers and forage fish. Data indicate that fish communities similar to the FHCL candidate species list occur in several natural lakes in northern Alberta that are smaller or similar in size to the FHCL. Although the full species complements are not necessarily known for all lakes in the FWMIS database (represented in Figure 20a-1), there are 11 lakes less than or equal to 117 ha that have a fish community that includes ESRD/CEAA Page 148 October 2014

151 Frontier Oil Sands Mine Project ESRD and CEAA Responses Water northern pike, yellow perch and one or more sucker species. Some of these lakes are also known to support walleye and one or more forage fish species, based on the level of sampling conducted to date. These lakes include: Matthews Lake (21 ha) Sulphur Lake (53 ha) Little Perch Lake (60 ha) Kaduk Lake (63.4 ha) Minnie Lake (83 ha) Lost Magician Lake (97 ha) Ross Lake (104 ha) Unnamed Lake (105 ha) Unnamed Lake (108 ha) Fletcher Lake (109 ha) Narrow Lake (114 ha) c. The HEP developers recognize that habitat is not the only basis for environmental assessment and that predation and competition can affect the number of individuals using a particular habitat. They also recognize that professional judgement is required where a limitation of the application is identified (USFWS 1980b). Therefore, the final proposed fish community for the FHCL will depend on a fish community that feasibly can be achieved, based on consultation with regulators and potentially affected Aboriginal communities, and considering factors such as regional management objectives, fish communities present in regional waterbodies, and a sustainable mix of the trophic levels represented by sport fish, suckers and forage fish species. As described in the response to part b, several natural lakes in northern Alberta have a fish species assemblage or species complement similar to the candidate list for the FHCL; these fish communities would be influenced by similar biological interactions, including inter- and intra-species interaction, competition and predation. d. As described in response to parts a and b, the proposed species complement is consistent with what occurs in natural, northern Alberta lakes similar in size to the FHCL. No adjustment is needed to the proposed species complement at this stage of planning. Further review and refinement of the proposed species complement, including the specific fish species and number of species that will be targeted for inclusion in the FHCL will occur as part of the finalization of the compensation plan. The final species complement will be determined in consultation with regulators and potentially affected Aboriginal communities, and will consider factors such as regional management objectives, fish communities present in regional waterbodies, and a sustainable mix of the trophic levels represented by sport fish, suckers and forage fish species. October 2014 ESRD/CEAA Page 149

152 ESRD and CEAA Responses Water Frontier Oil Sands Mine Project e. As described in response to part d, no adjustment of the proposed species complement is warranted for the FHCL at this time. Therefore, additional lake area is not required based on the target number of fish species. The final species complement will be determined as part of final compensation planning in consultation with regulators and stakeholders. The final size and design of the FHCL will be determined based on the identified target species list and associated habitat requirements for all of their life stages. REFERENCES Golder (Golder Associates Ltd.) Horizon Lake Monitoring Report. Prepared for Canadian Natural Resources Limited. Calgary, Alberta. June USFWS (U.S. Fish and Wildlife Service) Habitat Evaluation Procedures. Division of Ecological Services, Department of the Interior. Washington, D.C. USFWS. 1980a. Habitat Evaluation Procedures Ecological Services Manual (102 ESM). Division of Ecological Services, Department of the Interior. Washington, D.C. USFWS. 1980b. Habitat as a Basis for Environmental Assessment Ecological Services Manual (101 ESM). Division of Ecological Services, Department of the Interior. Washington, D.C. Question 21 SIR1, Volume 1, Section 10, SIRs 72 and 73, Pages SIR1, Volume 1, Section 5.5, SIR 111a, Pages to SIR 112, Pages to SIR1, Volume 1, Section 10, SIR 71 b, Page 148 SIR2, Volume 1, Aquatics, SIR 30 Teck concludes that Assuming the FHCL provides habitat suitability values typical of constructed compensation lakes in the oil sands region for a fish community composed of sport fish, suckers, and forage fish (i.e., average HSI of 0.6), the FHCL will provide the required habitat gains to offset the habitat losses associated with the development of the Frontier Project. a. Provide information on other similar compensation habitats in the oil sands region, to support this conclusion, including information on success, longevity, stability, species complement, comparisons with pre-construction predictions, and explicit productivity assessments for the disturbed and replaced habitat. Several waterbodies/watercourses that are identified as providing fish habitat based on sampling data do not appear have a colonization/recolonization pathway identified. ESRD/CEAA Page 150 October 2014

153 Frontier Oil Sands Mine Project ESRD and CEAA Responses Water b. For all waterbodies (e.g. Unnamed Waterbody 13, Unnamed Lakes 22 and 12) and watercourses that support fish identify a pathway by which they would be colonized/recolonized. Ensure colonization pathways are identified as habitat for all species present in the upstream habitat (e.g. Unnamed Lake supports sport fish and suckers, but the connecting watercourse is only described as forage fish habitat). c. Update the habitat assessment, habitat loss calculations and compensation plan to include any additional habitat not accounted for in the most recently presented habitat compensation plan. Response 21 a. As described in the response to ESRD/CEAA Round 1 SIR 120f: Although similar habitat compensation works are in development in the oil sands region (i.e., planning, construction, filling or post-filling), their success... [in providing compensation for predicted effects on habitat productivity] has not yet been demonstrated. The most advanced of the compensation works is the Horizon project s compensation lake. Following filing, the biological development of this lake has been monitored from 2008 to 2011 [now 2012] (Golder 2013). Results to date indicate that aquatic macrophytes have established and are expanding naturally. Benthic invertebrate and planktonic communities are well established, and fish populations for some species (i.e.,... [Arctic grayling,] both white and longnose suckers [and several forage fish species]) have naturally colonized the lake. Fish populations are expanding with successful spawning and recruitment documented, and the one introduced forage fish species is establishing well. As described in the response to ESRD/CEAA Round 3 SIR 20a, the CNRL Horizon compensation lake has, at present, achieved its goal of supporting nine fish species, including one sport fish species (Arctic grayling), two sucker species (longnose and white sucker), and six forage fish species (brook stickleback, fathead minnow, finescale dace, lake chub, slimy sculpin and trout-perch). However, given the early stage of development for the Horizon compensation lake, it is not yet considered stable and it is not known what the species complement of the fish community will be as time progresses, colonization continues, stocking programs are implemented and the fish community matures. For details on the development of the Horizon compensation lake, see the response to ESRD/CEAA Round 1 SIR 120. Another compensation lake for which preliminary monitoring data is available is the Shell Jackpine compensation lake. This lake is also in the early stages of development, having been filled in spring 2010 and monitored for biological development for three years (2010 to 2012). Monitoring results for primary productivity, secondary productivity and fish populations indicate that, based on the biological colonization observed to date for plankton, macrophytes, benthic invertebrates and fish, the compensation lake has progressed at the anticipated rate of biological development (Hatfield 2013). At present, the lake has achieved similarity to the reference lake (i.e., Kearl Lake) for some October 2014 ESRD/CEAA Page 151

154 ESRD and CEAA Responses Water Frontier Oil Sands Mine Project benthic invertebrate metrics, but at this early date has not yet achieved anticipated endpoint productivity levels. The documented fish community to date consists of sport fish, suckers and forage fish species, including northern pike, white sucker, longnose sucker, lake chub and fathead minnow. Monitoring programs are in place for the Horizon and Jackpine compensation lakes, and for other compensation works in the oil sands region to specifically assess success, longevity, stability, species complement and productivity for the disturbed and replaced habitat, and facilitate comparisons with preconstruction predictions. A similar detailed monitoring program will be developed for the Frontier Project in consultation with regulators, potentially affected Aboriginal communities and stakeholders as part of detailed compensation planning. It is expected that similar monitoring requirements will be specified in the anticipated future Fisheries Act authorization for the Project. b. Most waterbodies identified in the revised CFHCP (see the response to ESRD/CEAA Round 2 SIR 30j, Appendix 30j.1) as supporting fish will not be affected by Project development and will not experience altered access for fish. These include Ronald Lake and Unnamed Waterbodies 12, 15, 16, 19 and 20 (see Appendix 30j.1, Table ). Unnamed Waterbodies 13 and 22 will be permanently lost because of Project development and will not be available for recolonization at closure. Similarly, as part of the Project Update (see AER Round 3 SIR 1), Teck proposes to place an EDA over Unnamed Lake 1 such that it will not be available for recolonization. Unnamed Creek 2 discharges from Unnamed Lake 1 and will be altered by Project development. The persistence of the Unnamed Creek 2 channel, and the possibility of recolonization, will be reevaluated in the Project Update. The need for permanent compensation for these habitats was identified by the and considered by the CFHCP. The CFHCP might be revised as part of the Project Update that is discussed in the response to AER Round 3 SIR 1. c. Pending the results of the Project Update identified in part b, habitat loss calculations and the CFHCP might be revised. REFERENCES Golder (Golder Associates Ltd.) Horizon Lake Monitoring Report. Prepared for Canadian Natural Resources Limited. Calgary, Alberta. June Hatfield (Hatfield Consultants) Jackpine Compensation Lake Monitoring Program, Prepared for Shell Canada Energy, Fort McMurray, Alberta. April ESRD/CEAA Page 152 October 2014

155 Frontier Oil Sands Mine Project ESRD and CEAA Responses Water Question 22 SIR1, Volume 1, Section 10, SIRs 72 and 73, Pages SIR1, Volume 1, Section 5.5, SIR 111a, Pages to SIR 112, Pages to SIR1, Volume 1, Section 10, SIR 71 b, Page 148 SIR2, Volume 1, Aquatics, SIR 30 The watercourse in the centre of the PAA (Figure ) is marked as not having been surveyed or assessed. a. Update the figure to identify the fish habitat status of this watercourse. b. If the watercourse has not been surveyed, identify when these baseline data will be collected and provided. c. Update the assessment, fish habitat losses, and compensation plan using a precautionary fish habitat classification for this watercourse. Provide a rationale for the classification chosen. d. Provide an assessment of the fish habitat losses associated with the river intake structure and update the compensation plan and effects assessment appropriately. If the intake structure location has not been finalized, provide assessments for each location under consideration. Response 22 a. Figure in the revised CFHCP (see the response to ESRD/CEAA Round 2 SIR 30j, Appendix 30j.1) identifies the fish and fish habitat status of surveyed watercourses and waterbodies in the revised aquatics LSA. The figure shows a drainage and a watercourse in the middle of the PDA for which the fish and fish habitat status is not identified. This drainage is a tributary to Unnamed Creek 2. The fish and fish habitat baseline report (Volume 2, Section 6.2.1, Figure 6-3, Page 6-8) indicates that surveys were not conducted in this drainage. This drainage was not surveyed (and therefore shows no fish and fish habitat status) because it consists entirely of bog and terrestrial habitats. There were no aquatic habitats present, including no defined watercourse channel or channel segments, and no ponds or beaver impoundments. The drainage appears as a watercourse on Figure in error based on its appearance in the 1:20,000 AltaLIS hydrography. However, there is no watercourse or pond habitats present in this drainage on aerial photographs or on the 1:50,000 National Topographic System (NTS) hydrography (stream network topology) for this area (Map 74 E/12 Asphalt Creek). This observation is consistent with the surface water ground-truthing study conducted as part of the hydrology baseline (see Volume 2, Appendix 4B). The ground-truthing study was conducted to verify the presence or absence of watercourses in the Redclay Creek and Unnamed Creek 16 and 17 October 2014 ESRD/CEAA Page 153

156 ESRD and CEAA Responses Water Frontier Oil Sands Mine Project drainages in response to differences noted between the AltaLIS and NTS data. Considerably fewer watercourses were evident in drainage areas on the NTS map relative to the AltaLIS map. During the study, it was determined that the examined drainage areas were more consistent with the NTS map. Revisions based on the surface water ground-truthing study were provided as part of the (for example, see Volume 2, Section 6.2.1, Figure 6-3, Page 6-8, where this watercourse is shown as undefined). An updated figure is provided that shows the correct fish and fish habitat status of watercourses in the revised aquatics LSA (see Figure 22a-1). This figure no longer shows a watercourse in the drainage in question. b. See the response to part a. c. See the response to part a. d. As discussed in the response to AER Round 3 SIR 1, Teck intends to update the Integrated Application for the Project to: recover additional resource from leases acquired from Shell during the Teck Shell asset exchange optimize the tailings management strategy in consideration of the current state of engineering practice and improved understanding of site-specific conditions reflect additional engineering studies and information obtained from Shell as part of the asset exchange consider input received from regulators and potentially affected Aboriginal communities during the review process Items identified in this SIR will be considered in the Project Update. Regarding the raw water intake (RWI), Option 3 is now the selected option. The decision to change the RWI location was made based on the failure of the thalwag to reestablish itself at RWI Option 4 in spite of the 1-in-5-year flood experienced on the Athabasca River in ESRD/CEAA Page 154 October 2014

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158 ESRD and CEAA Responses Water Frontier Oil Sands Mine Project Question 23 SIR1, Volume 1, Section 10, SIRs 72 and 73, Pages SIR1, Volume 1, Section 5.5, SIR 111a, Pages to SIR 112, Pages to SIR1, Volume 1, Section 10, SIR 71 b, Page 148 SIR2, Volume 1, Aquatics, SIR 30 Teck has provided a waterbody by waterbody calculation of the fish habitat losses. a. Provide the habitat gain calculations for fish habitat compensation lake. b. Provide maps/diagrams of the habitat gains by species, identifying how specific habitat in the compensation lake was considered for each species. Response 23 a. The fish habitat compensation plan for the Frontier Project is currently in the conceptual stage, as is typically the case for compensation plans for oil sands mining projects during the environmental impact assessment, application and approval process. Estimated habitat gains for the FHCL are preliminary because the design of the FHCL is conceptual. Presently, estimates are based on the potential fish community and the habitat suitability that could be achieved by appropriate lake design. Although detailed habitat gain calculations are not yet available, these will be completed as part of detailed compensation planning for the Project (i.e., once the target fish community is finalized and the detailed design of the FHCL is completed). TARGET FISH COMMUNITY Identifying the final species assemblage for the FHCL is a key part of the detailed lake design phase. Seven fish species are currently proposed for the FHCL (see the response to ESRD/CEAA Round 3 SIR 20a). The target species assemblage will be finalized as part of the detailed compensation plan and through consultation with regulators and potentially affected Aboriginal communities (see the response to ESRD/CEAA Round 3 SIR 20a). HABITAT UNITS AND HABITAT SUITABILITY The FHCL is designed to compensate for habitat losses and uses habitat units (HUs) as a measure of fish habitat productivity. Teck s goal is to provide greater-than-existing habitat productivity by providing HU gains that are greater than the number of HUs lost. Teck will consider the life-history requirements of target fish species in its FHCL design so that constructed habitats are able to support all life stages of the expected fish community, including spawning, nursery, rearing, feeding and overwintering habitats. To accomplish this, the detailed lake ESRD/CEAA Page 156 October 2014

159 Frontier Oil Sands Mine Project ESRD and CEAA Responses Water design will be based on the species-specific HSI models developed for use in the oil sands region (Golder 2008). For a fish community comprising sport fish, suckers and forage fish, constructed compensation lakes in the oil sands region have an average HSI value of 0.6. Assuming that the FHCL provides habitat suitability values similar to other compensation lakes in the region, the FHCL will provide the required HU gains to compensate for the HU losses associated with the development of the Frontier Project. The design of the FHCL is flexible and allows for a larger or smaller lake depending on the final habitat gain calculations. Once the detailed design is complete, final habitat gains will be calculated for the FHCL. These calculations will take the size of the FHCL into account as well as the HSI values for each fish species in the target fish community to determine the total number of HUs provided by the FHCL. b. Because the design of FHCL is conceptual, habitat gains in the FHCL are preliminary estimates, and maps and diagrams of the FHCL (other than its location and basic layout) are not yet available. During detailed compensation planning and detailed lake design, specific habitats in the FHCL will be considered for each species in the final target fish community. These habitats will be based largely on the species-specific HSI models and key habitat variables that define the habitat requirements of the fish species. This includes habitat to support all life stages, including spawning, nursery, rearing, feeding and overwintering habitats (see the response to part a). As with other constructed compensation lakes in the oil sands region, detailed design of the FHCL will consider the following physical habitat features of the lake: lake size (surface area) shoreline development and complexity proportion of shallow littoral and deeper pelagial areas (as percentage of total surface area) detailed bathymetry by depth contour (as percentage of total surface area) substrate particle size distribution (as a percentage of total surface area) and location of different substrate types (e.g., sediment, gravel, cobble, boulder) cover enhancement features (e.g., large woody debris structures) estimated density and distribution of aquatic vegetation estimated cover density and distribution detailed hydrology modelling of hydrologic feasibility, water balance and water level sustainability detailed water quality modelling of key habitat variables (e.g., ph, temperature, dissolved oxygen [DO], biochemical oxygen demand [BOD], nutrients, total dissolved solids [TDS], total suspended solids [TSS], toxicity) October 2014 ESRD/CEAA Page 157

160 ESRD and CEAA Responses Water Frontier Oil Sands Mine Project Once the detailed design work is complete, maps and drawings will be provided that show the habitat features of the FHCL. Habitat gains calculations will be included as part of the detailed compensation plan. REFERENCES Golder (Golder Associates Ltd.) Fish Species Habitat Suitability Index Models for the Alberta Oil Sands Region. Version 2.0. October Question 24 SIR1, Volume 1, Section 10, SIRs 72 and 73, Pages SIR1, Volume 1, Section 5.5, SIR 111a, Pages to SIR 112, Pages to SIR1, Volume 1, Section 10, SIR 71 b, Page 148 SIR2, Volume 1, Aquatics, SIR 30 Teck has not provided a conceptual monitoring study design associated with the fish habitat compensation plan, rather it has simply listed what will be monitored. a. Provide a conceptual monitoring plan that: i. Describes how Teck will confirm that there will be no loss of productive capacity, and how its effectiveness as an offsetting measure will be demonstrated. ii. Lists the assumptions associated with the habitat unit modelling, productivity losses and gains. iii. Describes how the monitoring will confirm assumptions. iv. Lists the aquatic ecology effects conclusions identified as mitigated/offset by the compensation plan, v. Describes how the monitoring plan will confirm the effectiveness of the approach at mitigating each listed effect. Response 24 a. i The conceptual fish and fish habitat monitoring plan for the Frontier Project is provided in this SIR response and is valid for the Project Update (see AER Round 3 SIR 1). The monitoring plan is conceptual at this stage and the content and details of the plan will be finalized in consultation with regulators and potentially affected Aboriginal communities, and as required by the conditions specified in the anticipated authorizations and approvals for the Project. In terms of scope, the conceptual monitoring plan includes water quality and hydrology monitoring parameters that ESRD/CEAA Page 158 October 2014

161 Frontier Oil Sands Mine Project ESRD and CEAA Responses Water specifically relate to results of the fish and fish habitat assessment. Additional, separate water quality and hydrology monitoring programs will be included in the overall monitoring plan for the Project. Project-specific monitoring programs will also be supported by regional monitoring programs such as the Regional Aquatics Monitoring Program (RAMP) and the Canada/Alberta Implementation Plan for Oil Sands Monitoring. These programs will provide data on regional conditions, other watersheds in which oil sands development is occurring, and additional assessment of cumulative effects. GOALS AND OBJECTIVES The conceptual monitoring program is intended to: confirm predictions related to effects on fish habitat productivity address uncertainties and knowledge gaps in the predictions identify if there are any unanticipated effects on fish habitat productivity demonstrate whether the FHCL is effective in providing the required compensation for all identified effects APPROACH The conceptual monitoring plan uses a before-after-control-impact (BACI) approach, monitoring in affected habitats before and after potential impacts. It also uses regional monitoring data as control data, including regional reference sites and information on the regional normal range of variability. This approach is recommended to be able to evaluate the quality of Project-specific monitoring data in relation to natural environmental patterns (CSAS 2012). CHANGES IN FISH HABITAT Changes in fish habitat are predicted because of changes in habitat area and effects of increased TSS levels and changes in flows. Predicted effects on productive fish habitats include: loss of habitats in Unnamed Lake 1 because of changes in suspended sediment loss of habitats in Unnamed Creek 2 and Unnamed Waterbody 22 because of loss of habitat area reduction in habitat area in lower Big Creek and lower Redclay Creek because of flow reductions during operations As a result, the fish and fish habitat monitoring program aims to: confirm assessment predictions regarding effects on fish habitat productivity (i.e., effects resulting from changes in fish habitat) address uncertainty or knowledge gaps associated with predicted effects October 2014 ESRD/CEAA Page 159

162 ESRD and CEAA Responses Water Frontier Oil Sands Mine Project confirm predictions of negligible effects where uncertainty or knowledge gaps were identified in the assessment determine the effectiveness of the CFHCP and FHCL in achieving the required compensation of fish habitat productivity and maintaining fish abundance and diversity identify whether additional measures are required to provide the necessary habitat compensation for Project effects on fish habitat productivity The FHCL was provided to compensate effects on fish habitat productivity resulting from these predicted effects. The FHCL will be updated as required to accommodate changes that might arise as a result of the Project Update (see the response to AER Round 3 SIR 1). The conceptual monitoring program includes measures to confirm these predictions and determine the effectiveness of the FHCL in providing the necessary fish habitat productivity compensation. The assessment conclusions include uncertainty associated with the habitat suitability index (HSI) models used to assess fish habitat productivity in the affected habitats, and with the FHCL. As a result, the conceptual monitoring plan includes model validation. UNCERTAINTY AND KNOWLEDGE GAPS IN ASSESSMENT PREDICTIONS The assessment identifies several uncertainties, particularly regarding the predictions of negligible effects on productive fish habitats. For example: There is moderate confidence in the predictions of temperature changes in Big Creek because the model being calibrated is for the Muskeg River watershed rather than local watercourses. The potential for ecological interactions is not well understood for biological components (i.e., primary productivity, benthic invertebrate communities, and fish populations and behaviour) in lower Big Creek given the predicted shift in thermal regime. Potential interactions between reduced sediment loading and reduced peak flows in lower Big Creek and lower Redclay Creek are uncertain, as are the overall effects on channel regime. Ecological interactions are possible but not well known in lower Big Creek and lower Redclay Creek because of predicted changes in flow and possible changes in channel regime. For Big Creek, such interactions are likely because of changes in thermal regime. Knowledge gaps relevant to the fish and fish habitat assessment related to: determining site-specific effective flows in lower Big Creek and lower Redclay Creek, which control channel morphology in these watercourses, and considering these flows in relation to predicted changes in channel regime ESRD/CEAA Page 160 October 2014

163 Frontier Oil Sands Mine Project ESRD and CEAA Responses Water temperature attenuation in lower Big Creek at closure, which could reduce the predicted changes in thermal regime spring spawning activity in lower Big Creek by longnose and white suckers The conceptual monitoring plan includes data collection to address these uncertainties and knowledge gaps. MONITORING SITES Specific monitoring locations will be determined as part of finalizing the Project monitoring plan. However, monitoring will include affected habitats in: Unnamed Lake 1 Unnamed Creek 2 Unnamed Waterbody 22 Lower Big Creek Lower Redclay Creek the FHCL the pit lakes waterbodies and watercourse channels in the closure drainage system SCOPE OF MONITORING ACTIVITIES To determine effects of the Project on fish habitat productivity, various monitoring activities are proposed for the affected habitats predicted to be lost because of Project development. These monitoring activities are summarized in Table 24a-1 for each of the affected habitats. Additional monitoring is proposed for lower Big Creek and lower Redclay Creek to address uncertainty and knowledge gaps associated with some of the assessment pathways. The FHCL will be monitored during its development, maturation and stabilization phases to determine its effectiveness in providing the required compensation for effects on fish habitat productivity. Proposed monitoring components are listed in Table 24a-1. The pit lakes, waterbodies and watercourse channels in the closure drainage system will be monitored to confirm predictions that they are suitable for the development of viable aquatic ecosystems and to support fish populations. Detailed design of these features is required to finalize the monitoring plan, but basic monitoring components are also listed in Table 24a-1. October 2014 ESRD/CEAA Page 161

164 ESRD and CEAA Responses Water Frontier Oil Sands Mine Project Table 24a-1 Proposed Conceptual Monitoring Plan Monitoring Activity or Component Purpose Unnamed Lake 1 Unnamed Creek 2 Unnamed Waterbody 22 Lower Big Creek Lower Redclay Creek HSI modelling Model validation Fish populations Benthic invertebrate communities Attached algae mass Temperature (e.g., thermograph deployment) Hydrologic monitoring Physical channel dimensions (e.g., wetted width, depth, channel width and depth) Fish habitat characteristics Water and sediment quality Plankton communities (zooplankton, phytoplankton) Fish tissue mercury concentrations HSI model validation and assessment of fish habitat productivity, abundance and diversity, including fish species composition, abundance and biomass. To assess habitat productivity, including composition, diversity and abundance. To assess habitat productivity (e.g., ash free dry weight and chlorophyll a). To determine the thermal regime and identify changes over time. Watercourses: To establish the flow regime and identify changes over time. Waterbodies: To assess water levels, stability and sustainability. To document changes in channel regime and available habitat area. To document changes in these characteristics. To assess relative to guidelines for aquatic life and to baseline conditions for local watersheds. To assess habitat productivity, including composition, density and biomass. To confirm predictions and determine need for additional mitigation measures. FHCL Pit Lakes, Closure Drainage System ,2 NOTES: 1 For watercourses, fish habitat characteristics include channel unit types, distribution, area, substrate characteristics, cover for fish, aquatic vegetation and riparian zone characteristics. 2 For waterbodies, fish habitat characteristics include bathymetry, substrate characteristics, cover for fish, aquatic vegetation (composition, distribution, density and vigour) and riparian zone characteristics. ESRD/CEAA Page 162 October 2014

165 Frontier Oil Sands Mine Project ESRD and CEAA Responses Water DEFINING FISH HABITAT PRODUCTIVITY The specific metrics to be used to define fish habitat productivity levels in the affected habitats and the FHCL will be determined in consultation with DFO and are expected to be defined as part of the anticipated Fisheries Act authorization for the Project. Specific parameters previously used by DFO for similar compensation works have included: validation of HSI models and HU calculations, including recalculation of HU based on any revisions to the models through the Project or regional validation exercises, to confirm whether compensation habitats provide sufficient habitat productivity compensation demonstrating that the fish populations comprising the fish community in the compensation habitats are self-sustaining demonstrating that compensation habitats have achieved specific productivity objectives, as defined in the Fisheries Act authorization Monitoring related to HSI model validation requires that the monitoring program for the Project coordinate with regional validation efforts currently underway by the Fisheries Sustainable Habitat (FiSH) Committee of the Oil Sands Community Alliance (OSCA). This type of coordination increases the efficiency and maximizes the value of the monitoring program. ii The assumptions associated with HU modelling conducted for productivity losses in the affected habitats and gains in the FHCL are that: the HUs provide a quantitative estimate of fish habitat productivity for the relevant fish species the variables included in the species-specific HSI models represent the life history requisites of each of the fish species and thereby provide a quantitative means of estimating habitat suitability iii iv The conceptual monitoring plan presented in this SIR response includes validation of the HSI models through Project monitoring of affected and compensation habitats. Validation efforts will occur in coordination with similar HSI validation studies being conducted in the oil sands region. The model validation consists of measurements of suitability index variables and calculation of HSI values in the affected and compensation habitats, and comparison of these values to measures of fish habitat productivity (e.g., fish biomass) to determine the accuracy of the models, and identify appropriate revisions of the models, where appropriate. The conceptual monitoring plan identifies the watercourses and waterbodies for which aquatic ecology effects were identified in the assessment and for which potential effects on fish habitat productivity are expected to be compensated by the FHCL. Any changes to effects on watercourses and waterbodies will be identified and discussed as part of the Project Update (see the response to AER Round 3 SIR 1), and the CFHCP and conceptual monitoring plan will be modified as needed. October 2014 ESRD/CEAA Page 163

166 ESRD and CEAA Responses Water Frontier Oil Sands Mine Project v The conceptual monitoring plan presented in the response to part a(i) describes how Teck plans to confirm the effectiveness of mitigation associated with the FHCL. The plan includes monitoring: habitats predicted to be affected by the Project compensation habitats to be provided by the Project habitats for which predictions of negligible effects were associated with uncertainty or knowledge gaps The conceptual monitoring plan is intended to identify predicted and unexpected effects on fish habitat productivity and the extent to which these effects are compensated by the FHCL. The specific metrics to be used in defining fish habitat productivity levels in the affected habitats and the FHCL will be determined by DFO and are expected to be defined in the anticipated Fisheries Act authorization for the Project. REFERENCES CSAS (Canadian Science Advisory Secretariat) Assessing the Effectiveness of Fish Habitat Compensation Activates in Canada: Monitoring Design and Metrics. Fisheries and Oceans Canada. CSAS Science Advisory Report 2012/060. Question 25 SIR1, Volume 1, Section 10, SIRs 72 and 73, Pages SIR1, Volume 1, Section 5.5, SIR 111a, Pages to SIR 112, Pages to SIR1, Volume 1, Section 10, SIR 71 b, Page 148 SIR2, Volume 1, Aquatics, SIR 30 Teck was asked about the effects on detrital inputs to aquatic systems. The discussion provided in response to SIR2 Responses 10 and 34, relies on several assumptions: habitat similar to what is currently present will develop in and around diversion channels and that if similar habitat develops detrital inputs will also be similar once the diversion habitat has stabilized; if the length of the diversion channel is similar to the original watercourse, the detrital inputs will be similar; flow volume is a reasonable proxy for detrital mass inputs, and because flows will be similar, detrital mass inputs will be similar. a. Provide peer-reviewed support for these assumptions and ensure supporting references are provided. ESRD/CEAA Page 164 October 2014

167 Frontier Oil Sands Mine Project ESRD and CEAA Responses Water b. Provide an assessment of the potential changes to detrital inputs in the aquatic ecology assessment. Connect potential change in detrital input to potential aquatic ecological changes c. Address seasonality in the assessment of effects to detrital inputs. Response 25 a. Effects of the Project on detrital inputs were assessed for watercourses in the PDA that are tributaries of the Athabasca River (i.e., Redclay Creek, Big Creek and Unnamed Creek 19) (see the response to ESRD/CEAA Round 2 SIR 10a). The assessment was based on flow changes in the revised aquatics LSA and other processes through which Project-related changes might influence detrital inputs to the Athabasca River. The assessment considered diversion channels that will be constructed to convey flows in some sections of these drainages as well as any changes to detrital inputs. As described in response to ESRD/CEAA Round 2 SIR 10a: Detritus present in watercourses consists of organic matter originating from within a watercourse... [autochthonous] and external inputs from the terrestrial ecosystem... [allochthonous]. The trophic structure of rivers and streams largely depends on active detrital processes. Most of the organic matter is undergoing microbial degradation, the rate of which typically is greater than autochthonous production (Wetzel 2001). Therefore, allochthonous inputs of terrestrial organic matter are commonly the dominant source of material and energy in stream and river ecosystems. The diversion channels constructed to replace portions of Redclay Creek and Big Creek will pass through similar habitats with comparable riparian vegetation. The disturbed area immediately adjacent to the constructed channel will be reclaimed and revegetated, ultimately resulting in similar allochthonous organic inputs as under predevelopment conditions. Allochthonous detrital inputs can differ depending on the type of plant matter (Eggert et al. 2012), canopy cover (England and Rosemund 2004), and the amount of retentive structures in the stream (e.g., large woody debris) (Webster et al. 1994). Most detrital input is expected to be local. Transport rates of detritus vary and depend on particle size, but overall transport distances for coarse particulate organic matter (CPOM) tend to be short (Wallace et al. 1995). Streams in forested areas, for example, tend to retain CPOM (Abelho 2001). Although CPOM tends to move only short distances before being broken down into fine particulate organic matter (FPOM), the FPOM can travel long distances and accounts for a substantial amount of the organic output of streams (Webster et al. 1999). In terms of the Project, once the habitat surrounding the diversion channel stabilizes in a state similar to predevelopment conditions, and plants establish and begin providing allochthonous inputs, the extent of canopy cover and the deposition of retentive structures should be similar. As a result, the amount of detrital input also is expected to be similar to predevelopment levels. Given the similarity of these factors, the rate of detrital decomposition, the rate of downstream movement, and the energy provided by the detrital inputs, should all approximate predevelopment conditions. October 2014 ESRD/CEAA Page 165

168 ESRD and CEAA Responses Water Frontier Oil Sands Mine Project In addition, after a period of acclimatization, the constructed channels should function similarly to naturally occurring watercourses in the area in terms of both autochthonous and allochthonous sources of organic matter. As stated in the response to ESRD/CEAA Round 2 SIR 10a: It has been shown that the export of organic matter to downstream reaches is highly pulsed. Wallace et al. (1995) showed that 63% to 77% of organic matter export occurred during the 20 largest flood events in an area over a nine-year period. Despite an initial lack of decaying organic matter in the constructed channels, the watercourses will still receive organic matter from the adjacent riparian area during flood events [This is expected to continue into the far future]. This input will contribute organic matter and detritus to downstream habitats in spite of an initial lack of decaying organic matter within the constructed channels. Because riparian habitat dictates the amount of detrital input and its quality (i.e., plant type) (Eggert et al. 2012), similar habitat along the diversion channel should provide the same detrital input per unit length as predevelopment streams. In addition, given the specific characteristics of the affected drainages (see the response to part b), the overall length of watercourse and riparian area that currently contributes detrital mass to the Athabasca River will be unaffected or enhanced by the diversions. At closure, the watercourses and riparian areas that will form the closure diversion system will also contribute detrital inputs, once they mature. Flow volume was not used as a proxy for detrital inputs in the assessment, but was considered in the assessment possibly contributing to potential changes in detrital mass. Downstream movement of detritus is correlated with flow (Wallace et al. 1995), with most movement of CPOM occurring during high-flow events (Webster et al. 1994). In addition to considering the allochthonous inputs to detrital mass, flow changes in the affected watercourses, and the development of the diversion channels, Teck also considered the specific characteristics of the affected drainages (before and after Project development) in assessing effects on detrital inputs (see the response to part b). b. An assessment of potential changes to detrital inputs and the connection to potential aquatic ecological changes was provided in response to ESRD/CEAA Round 2 SIR 10a and SIR 34. Further assessment is provided in response to ESRD/CEAA Round 3 SIR 4a. In addition to considering potential changes to detrital inputs associated with diversion channels and flow changes (provided previously and in the response to part a), the assessment also considered specific characteristics of the natural watercourse channels in Redclay Creek, Big Creek and Unnamed Creek 19, and characteristics of the planned diversions. Redclay Creek: As described in the response to ESRD/CEAA Round 3 SIR 4a, the Redclay Creek diversion will connect the upper and lower watercourse channels, which are currently separated by a large bog area that serves as a biological filter and limits downstream export of detritus from the upper watercourse to the lower watercourse and the Athabasca River. During Project operation and ESRD/CEAA Page 166 October 2014

169 Frontier Oil Sands Mine Project ESRD and CEAA Responses Water closure, the upper watercourse will be connected to the lower watercourse by well-defined channels, providing enhanced conveyance of flows and organic material to downstream areas. Big Creek: The upper portion of Big Creek is also separated from the lower watercourse by a bog area (see the responses to ESRD/CEAA Round 1 SIR 108c, Table 108c-1 and ESRD/CEAA Round 2 SIR 45a, Figure 45a-1) that limits downstream export of detritus from the upper watercourse to the lower watercourse and to the Athabasca River. Unlike the situation in Redclay Creek, the Big Creek diversion occurs upstream of the bog complex so that, even though the diversion will replace poorly defined watercourse in the upper watershed with an improved conveyance channel to downstream areas, the diversion channel will also drain to the bog. As a result, changes in the upper watershed are not expected to affect detrital inputs or transport in the lower watercourse or delivery to the Athabasca River. Unnamed Creek 19: There are no planned watercourse diversions or changes to defined watercourse channels for Unnamed Creek 19. Rather, a portion of the upper watershed drainage area will be cut off by construction of the Redclay Creek diversion. Unnamed Creek 19 itself will not be altered other than changes in flow volume resulting from reduced total drainage area. Based on all information provided in the referenced SIRs and in consideration of site-specific conditions (i.e., most the PDA is on the fluvial fan from the Birch Mountains), Teck concluded that the potential for changes in detrital inputs and transport from the watercourses in the PDA to the Athabasca River were negligible with no effects on the productivity of the Athabasca River. c. As described in part a, allochthonous inputs of terrestrial organic matter are commonly the dominant source of material and energy in stream and river ecosystems. Input of allochthonous material is expected to vary across seasons, with peak inputs in fall (Connors and Naiman 1984); however, peak movement of organic matter generally correlates with flood events, which typically occur in the spring. Development of similar riparian habitat in the diversion channels should maintain similar resource pulses as during predevelopment. Therefore, no net change in the amount or timing of detrital inputs into the system is expected once new channels have stabilized. REFERENCES Abelho, M From litterfall to breakdown in streams: a review. The Scientific World Journal 1: Conners, M.E. and R.J. Naiman Particulate allochthonous inputs: relationships with stream size in an undisturbed watershed. Canadian Journal of Fisheries and Aquatic Sciences 41: Eggert, S.L., J.B. Wallace, J.L. Meyer and J.R. Webster Storage and export of organic matter in a headwater stream: responses to long-term detrital manipulations. Ecosphere 3: Article 75. England, L.E. and A.D. Rosemond Small reductions in forest cover weaken terrestrial aquatic linkages in headwater streams. Freshwater Biology 49: October 2014 ESRD/CEAA Page 167

170 ESRD and CEAA Responses Water Frontier Oil Sands Mine Project Wallace, J.B., M.R. Whiles, S. Eggert, T.F. Cuffney, G.J. Lugthart and K. Chung Long-term dynamics of coarse particulate organic matter in three Appalachian Mountain streams. Journal of the North American Benthological Society 14: Webster, J.R., A.P. Covich, J.L. Tank and T.V. Crockett Retention of coarse organic particles in streams in the southern Appalachian Mountains. Journal of the North American Benthological Society 13: Webster, J.R., E.F. Benfield, T.P. Ehrman, M.A. Schaeffer, J.L. Tank, J.J. Hutchens and D.J. D Angelo What happens to allochthonous material that falls into streams? A synthesis of new and published information from Coweeta. Freshwater Biology 41: Wetzel, R.G Limnology: Lake and River Ecosystems. Third Edition. Academic Press, San Diego, CA. Question 26 SIR1, Volume 1, Section 10, SIRs 72 and 73, Pages SIR1, Volume 1, Section 5.5, SIR 111a, Pages to SIR 112, Pages to SIR1, Volume 1, Section 10, SIR 71 b, Page 148 SIR2, Volume 1, Aquatics, SIR 30 No reference is made to studies of land use change and allochthonous and autochthonous detrital inputs to describe what might be expected in response to land use change associated with the Project and expected recovery times. a. Provide a discussion of the peer-reviewed literature associated with land use change and detrital inputs. Update the aquatic ecology assessment to consider what is known about land use change and detrital inputs. b. Discuss and assess the potential effects of the large-scale deletion of small headwater stream habitat during mining operations into a closed-system, and implications to aquatic productivity. Consider both the Frontier Project, and oil sands mining in the broader regional context. Response 26 a. Loss of riparian vegetation from land-use change can affect detrital inputs. Reduction in litterfall reduces the amount of detritus entering systems, but detritus within streams can move longer distances if the number of retentive structures in the stream (e.g., large woody debris) has been reduced (Webster et al. 1994). Breakdown rates of detritus can also be altered during and after logging (Webster and Waide 1982; Benfield et al. 1991). In general, logging can increase export of materials from streams (Webster et al. 1990). ESRD/CEAA Page 168 October 2014

171 Frontier Oil Sands Mine Project ESRD and CEAA Responses Water Changes in detrital inputs resulting from oil sands mining have not been addressed in the literature. Oil sands mining often results in reduced stream drainage areas as new areas are used for mining. This could result in reduced output of detritus to receiving waters. However, because depositional streams (which represent the dominant stream habitat type in the oil sands region) tend to accumulate large amounts of detritus in bottom sediments, removing portions of stream drainage areas may not have measurable effects on the delivery of detritus to the Athabasca River. In the case of watercourses draining the Project area, large wetlands areas along affected watercourses (i.e., Big Creek and Redclay Creek) influence detrital inputs during predevelopment conditions. Specifically, these wetlands allow CPOM to settle, thereby potentially reducing the transport of CPOM to the Athabasca River (for details, see the response to ESRD/CEAA Round 3 SIR 4a and SIR 25b). This drainage pattern is not going to change during or after Project development in Big Creek, but improved transport of CPOM in Redclay Creek is expected where the diversion provides a defined channel that bypasses the wetlands area and connects the upper and lower watercourse. The assessment of land use change and potential effects on detrital inputs was provided in response to ESRD/CEAA Round 2 SIR 10a and SIR 34. Updates and further information is provided in response to ESRD/CEAA Round 3 SIR 4 and SIR 25. b. Based on the assessment of land use change and discussion of potential effects on detrital inputs provided in response to ESRD/CEAA Round 2 SIR 10a and SIR 34, Teck anticipates a negligible change in detrital input as a result of the Project, with no impact on aquatic productivity. Headwater streams will be diverted around development and will continue contributing to their lower reaches and draining and delivering detritus to the Athabasca River. Therefore, changes in detrital transport are also expected to be negligible. Landscape changes for other oil sands mines in the region were assessed as part of project-specific assessments completed for these developments. As described in the response to ESRD/CEAA Round 3 SIR 9a, there are no predicted residual effects on productivity in the Athabasca River associated with other oil sands mines because of changes in detrital inputs or benthic invertebrate drift from tributary watersheds. Regional monitoring activities relevant to this assessment have been conducted for benthic invertebrate communities, which are the source of invertebrate drift (see the response to ESRD/CEAA Round 3 SIR 27). To date, monitoring results demonstrate that benthic invertebrate communities throughout much of the watershed areas with oil sands mining activity remain similar or have higher metrics (e.g., diversity) relative to baseline conditions (see the response to ESRD/CEAA Round 3 SIR 9b). October 2014 ESRD/CEAA Page 169

172 ESRD and CEAA Responses Water Frontier Oil Sands Mine Project REFERENCES Benfield, E.F., J.R. Webster, S.W. Golladay, G.T. Peters and B.M. Stout Effects of forest disturbance on leaf breakdown in southern Appalachian streams. Verhandlungen der Internationalen Vereinigung für theoretische und angewandte Limnologie 24: Webster, J.R. and J.B. Waide Effects of forest clearcutting on leaf breakdown in a southern Appalachian stream. Freshwater Biology 12: Webster, J.R., S.W. Golladay, E.F. Benfield, D.J. D Angelo and G.T. Peters Effects of forest disturbance on particulate organic matter budgets of small streams. Journal of the North American Benthological Society 9: Webster, J.R., A.P. Covich, J.L. Tank and T.V. Crockett Retention of coarse organic particles in streams in the southern Appalachian Mountains. Journal of the North American Benthological Society 13: Question 27 SIR1, Volume 1, Section 10, SIRs 72 and 73, Pages SIR1, Volume 1, Section 5.5, SIR 111a, Pages to SIR 112, Pages to SIR1, Volume 1, Section 10, SIR 71 b, Page 148 SIR2, Volume 1, Aquatics, SIR 30 Teck provides a discussion of benthic invertebrate drift in SIR2 response 176. With respect to monitoring, Teck states that Teck has not conducted surveys of invertebrate drift rates in the three watercourses (Redclay Creek, Big Creek and Unnamed Creek 19) that are in the revised Project area and flow to the Athabasca River. Based on the negligible potential for adverse changes in invertebrate drift rates in the Athabasca River because of the Project, there are no plans to collect baseline invertebrate drift data or to monitor invertebrate drift in natural or constructed habitats in the future. a. Provide a plan to acquire baseline benthic invertebrate drift data. b. Describe how Teck will monitor to confirm impact assessment conclusions associated with benthic drift are accurate, and support adaptive management approaches and a better understanding of the ecological outcomes associated with oil sands mining. ESRD/CEAA Page 170 October 2014

173 Frontier Oil Sands Mine Project ESRD and CEAA Responses Water Response 27 a. Teck does not plan to collect baseline benthic invertebrate drift data. The value of such data is limited given the large number of local physical factors influencing drift, the associated high variability in drift rates, and the negligible effects predicted on invertebrate drift (see the response to part b). As described in response to ESRD/CEAA Round 2 SIR 176, invertebrate drift from the portions of the two Athabasca River tributaries that will be diverted by the Project (i.e., Redclay Creek and Big Creek) does not currently supplement invertebrate communities in downstream sections of these watercourses, or in the Athabasca River. This is because of a lack of watercourse channel connectivity in these creeks. The literature reviewed in response to ESRD/CEAA Round 2 SIR 176 indicates that invertebrate drift is generally local in origin with short drift distances; this suggests that benthic invertebrate communities in the lower portions of these tributary watercourses are the primary source of drift to the Athabasca River. These communities would therefore be more suitable for monitoring to assess potential changes in invertebrate drift. b. Teck plans to monitor benthic invertebrate communities in potentially affected watercourses, as per anticipated regulatory monitoring requirements, rather than monitoring invertebrate drift (for a conceptual monitoring plan, see the response to ESRD/CEAA Round 3 SIR 41). As explained in Rosenberg and Resh (1993), freshwater benthic invertebrates are often used to monitor the environmental quality of lakes and rivers because: they are present in nearly all waterbodies, are usually abundant and they remain in a small area throughout the aquatic phase of their life cycle they obtain food by various means (e.g., filtering fine particulates and feeding on algae, decaying organic material, aquatic plants or other invertebrates) they have relatively long life cycles (months to years), and thereby integrate the effects of disturbances over a relatively long period they are an important food source for organisms at higher trophic levels (e.g., fish) they are sensitive to a wide variety of disturbances, including but not limited to: addition of sediment, toxins, nutrients and organic material low DO levels changes in flow, substratum and temperature they respond to disturbances in a predictable manner they are relatively easily collected and identified using standard sampling methods a wide range of species inhabiting any given location means that animals of varying sensitivity are present In contrast, effects monitoring using invertebrate drift is uncommon, results are subject to influences of many local factors (e.g., flow conditions, weather, turbidity, temperature, time of day), and drift studies require large effort (i.e., repeated sampling extending over full days) to collect data that are representative of conditions only at the time of sampling. October 2014 ESRD/CEAA Page 171

174 ESRD and CEAA Responses Water Frontier Oil Sands Mine Project The benthic invertebrate community on the substratum is the source of invertebrate drift, and proven, quantitative field methods are available for monitoring potential effects on the benthic community (e.g., Rosenberg and Resh 1993). Monitoring the benthic community not only provides greater value for assessing potential effects of the Project than invertebrate drift monitoring, but also provides direct information about the source of the drift and reflects environmental conditions over time. A review of regional monitoring programs and data for RAMP and the Joint Canada/Alberta Oil Sands Monitoring Program (JOSMP) shows that monitoring benthic invertebrate communities is the preferred and most appropriate method of monitoring this key environmental component. Benthic invertebrate monitoring is currently being conducted in regional watersheds where oil sands development is underway (see the response to ESRD/CEAA Round 3 SIR 9b). Current monitoring sites include locations in tributary watercourses where mining is occurring, near their confluences with the Athabasca River. This is considered the appropriate method for monitoring: the communities themselves potential changes in invertebrate drift that could result from changes in the benthic invertebrate communities that are the source of drift potential changes in their contribution to the productivity of the Athabasca River Results of benthic invertebrate community monitoring for the Frontier Project and for regional monitoring programs will be used to confirm impact assessment conclusions and regional cumulative effects, and to identify adaptive management approaches. REFERENCES Rosenberg, D.M. and V.H. Resh Freshwater Biomonitoring and Benthic Macroinvertebrates. Chapman and Hall, New York. Question 28 SIR1, Volume 1, Section 10, SIRs 72 and 73, Pages SIR1, Volume 1, Section 5.5, SIR 111a, Pages to SIR 112, Pages to SIR1, Volume 1, Section 10, SIR 71 b, Page 148 SIR2, Volume 1, Aquatics, SIR 30 Teck concludes that an increase in benthic invertebrate diversity is likely due to the development of new habitat in the FHCL. a. Describe what additional lentic habitat types might be constructed and how they would differ from existing lake habitats to be disturbed as part of the proposed Project development. ESRD/CEAA Page 172 October 2014

175 Frontier Oil Sands Mine Project ESRD and CEAA Responses Water b. Provide peer-reviewed literature, studies or monitoring data to support the underlying conclusion that that additional species will colonize the constructed lake, beyond the existing complement of benthic invertebrates present in current LSA lentic habitat. c. Present and discuss benthic invertebrate data from other watersheds in which oil sands mining is currently occurring and their associated fish habitat compensation lakes to support assessment conclusions. d. Provide a conceptual monitoring plan with sufficient detail to describe how Teck will monitor to confirm benthic invertebrate diversity will increase beyond what is currently present. Response 28 a. Additional lentic habitats will be provided in the constructed FHCL that differ from the disturbed lake habitats. These additional habitat types are expected to provide increased diversity in benthic invertebrate communities. Waterbodies that will be disturbed by the Project and for which compensation is provided in the FHCL include Unnamed Lake 1 and Unnamed Waterbody 22. Both of these waterbodies are shallow and have limited habitat diversity. As described in the baseline study (see Volume 5, Section 6) and the supplemental baseline study (see the response to ESRD/CEAA Round 2 SIR 30d, Appendix 30d.1): Unnamed Lake 1 has a maximum depth of 2.8 m and a mean depth of 1.8 m. The lake consists entirely of shallow littoral habitat and the substrate is entirely fine sediment. Dissolved oxygen levels in the winter were low: 0.6 mg/l to 2.2 mg/l in winter 2011, and 0.4 mg/l to 2.2 mg/l in winter Benthic invertebrate community results for Unnamed Lake 1 showed low density, low richness and low diversity, with a total of five invertebrate taxa recorded. Unnamed Waterbody 22 is also shallow and consists entirely of littoral habitat, with a maximum depth of 1.2 m, a mean depth of 0.8 m, and substrate composed entirely of fine sediment. Winter DO levels were low: 1.2 mg/l to 2.2 mg/l. There is no benthic invertebrate community data from Waterbody 22. Deeper pelagic habitats and habitats with rocky substrate are two additional lentic habitats that will likely be constructed in the FHCL. In addition, the FHCL is expected to have an increased average depth that will provide improved winter DO levels. The FHCL will also include the types of littoral habitats, sediment substrates and aquatic vegetation present in the affected waterbodies. The inclusion of specific habitat types not present in the affected habitats, and the provision of improved winter DO levels, will enable benthic invertebrate taxa to colonize the FHCL. This is likely to include species not present in existing benthic invertebrate communities in shallow waterbodies such as Unnamed Lake 1. October 2014 ESRD/CEAA Page 173

176 ESRD and CEAA Responses Water Frontier Oil Sands Mine Project b. As indicated in the response to part a, the FHCL will be designed to include a greater variety of lentic habitat types than the affected natural waterbodies. The greater habitat diversity is expected to result in greater biological diversity. Monitoring data available for constructed lakes in the oil sands region support this conclusion. For example, both the CNRL Horizon project fish compensation lake (Horizon Lake) and Shell Jackpine Mine compensation lake (Jackpine Lake) show the potential for increased benthic invertebrate diversity. Horizon Lake: Annual benthic invertebrate surveys completed during the first four years of development of the Horizon Lake (2009 to 2012) indicate that the developing community is still relatively low in abundance, although increasing over time. The community has achieved low to moderate taxonomic richness and moderate to high diversity compared to natural lakes in the oil sands region (Golder 2013). This level of benthic invertebrate diversity is associated, in part, with sampling the larger range of depths available in the compensation lake relative to natural lakes. Results show that 7 to 24 taxa have been recorded at individual sampling sites throughout the lake. Jackpine Lake: Benthic invertebrate monitoring for the first three years of development of Jackpine Lake (2010 to 2012) indicates that the developing community is still low in abundance and diversity relative to a natural lake analogue (i.e., Kearl Lake); however, the number of recorded taxa ranged from 2 to 17, depending on the sampling site (Hatfield 2013). The benthic invertebrate communities in both Horizon Lake and Jackpine Lake represent a higher level of diversity than the waterbodies affected by the Frontier Project, even though the Horizon and Jackpine compensation lakes are still in the early stages of development. c. Publically available benthic invertebrate data do not exist for compensation habitats in other watersheds where oil sands mining is occurring. Regional monitoring programs such as RAMP and the Joint Canada/Alberta Oil Sands Monitoring Program (JOSMP) either sample downstream of potentially affected watersheds (to evaluate cumulative effects) or have not yet published results. Data generated by monitoring fish habitat compensation lakes are available from CNRL s Horizon Lake, which is continuing to develop aquatic communities, but is not fully colonized at this time. Nonetheless, monitoring data for Horizon Lake indicate a higher level of benthic invertebrate diversity then was observed in waterbodies that will be affected by the Frontier Project (see the response to part b). d. Teck will develop a compensation monitoring program with input from regulators, potentially affected Aboriginal communities and stakeholders. The aim of that program will be to monitor the development of aquatic communities, including benthic invertebrates, in the FHCL. The conceptual monitoring plan for the Frontier Project, which including monitoring benthic invertebrate community diversity, is provided in response to ESRD/CEAA Round 3 SIR 24. ESRD/CEAA Page 174 October 2014

177 Frontier Oil Sands Mine Project ESRD and CEAA Responses Water REFERENCES Golder (Golder Associates Ltd.) Horizon Lake Monitoring Report. Prepared for Canadian Natural Resources Ltd. Calgary, Alberta. June Hatfield (Hatfield Consultants) Jackpine Compensation Lake Monitoring Program, Prepared for Shell Canada Energy, Fort McMurray, Alberta. April Question 29 SIR1, Volume 1, Section 10, SIRs 72 and 73, Pages SIR1, Volume 1, Section 5.5, SIR 111a, Pages to SIR 112, Pages to SIR1, Volume 1, Section 10, SIR 71 b, Page 148 SIR2, Volume 1, Aquatics, SIR 30 a. Provide a discussion of the shift from lotic to lentic systems. Address productivity implications at all trophic levels. Consider that the local and regional fish community is supported by the lower order productive capacity of the local and regional watersheds. b. Referring to peer-reviewed literature discuss whether lotic and lentic habitat perform similarly with respect to lower order productivity and what the implications to local and regional aquatic systems might be if they do not. Response 29 a. Shifts from lotic to lentic systems may result in changes in lower trophic productivity and invertebrate standing stock available as fish food, especially if the habitat in a former lotic system was erosional (dominated by swift-flowing rocky habitats). Primary production in lotic systems may be higher than in lentic systems (Odum 1956), potentially because the nutrient supply is constantly renewed in streams and streams are subject to a lower degree of anoxia than lakes and ponds. Fish production may also be higher in rivers than lakes (Randall et al. 1995) because of higher production in the lower trophic levels. Production in streams also depends on stream order with production:biomass ratios in lotic systems typically lowest in the headwaters and highest at the mouth (Ryder and Pesendorfer 1989). Differences between lotic and lentic systems depend to some extent on the site-specific characteristics of these habitats, such as dissolved oxygen levels and the erosional or depositional nature of the lotic systems. In the oil sands region, depositional streams represent the dominant habitat type. Shifts from slow-flowing depositional stream habitat to lentic habitat are generally expected to result in a smaller change in invertebrate communities and productivity because benthic invertebrate communities in October 2014 ESRD/CEAA Page 175

178 ESRD and CEAA Responses Water Frontier Oil Sands Mine Project slow-moving streams tend to be similar in abundance and composition to those in ponds and small lakes. As described in response to ESRD/CEAA Round 2 SIR 30i, replacement of lotic habitats with lentic habitats is occurring or planned at several oil sands developments as part of the habitat compensation for project effects on watercourses. Although details are limited, regional habitat compensation plans suggest that about 5% of lotic habitat effects will be compensated by developing new lotic systems, while the remaining 95% will be replaced with lentic habitats (see the response to ESRD/CEAA Round 2 SIR 30i). The Frontier Project will have a small contribution to this cumulative change owing to its location on the fluvial fan of the Birch Mountains (see Volume 2, Section , Pages 7-40 to 7-50), which provides limited fish habitat due to high sediment loads. The Project is expected to contribute about 1% to the cumulative change in lotic habitat. Most of the affected habitats for the Project are lentic habitats that will be replaced with new lentic habitats. However, habitat losses in Unnamed Creek 2 and flow-related habitat effects in lower Big Creek and Redclay Creek will be compensated with lentic habitats in the FHCL. These areas represent a small portion of the total habitat area losses associated with the development of the Frontier Project. Teck took a conservative approach in developing the CFHCP for the Project to ensure that compensation habitats in the FHCL would provide a suitable level of replacement of fish productivity in affected watercourses and waterbodies. This included: recognizing the differences in lotic and lentic habitats between affected and compensation habitats and using appropriate HSI model components to assess productivity in lotic (riverine HSI models) or lentic (Lacustrine HSI models) habitats (see the response to ESRD/CEAA Round 3 SIR 18) using a compensation ratio greater than 1:1 (habitat gains:habitat losses) in the CFHCP (see the response to ESRD/CEAA Round 2 SIR 30j, Appendix 30j.1), in part to address the uncertainty involved with providing a different habitat type to replace watercourse habitat effects using assumed species distributions in assessing habitat losses and considering productivity losses for species know to be present in the affected habitats, as well as species likely to be present considering regional examples of waterbody habitats and the fish communities they support (see the response to ESRD/CEAA Round 3 SIR 20b) Similar considerations have been included in compensation planning for other oil sands mines. Teck will consider if an update to the fish and fish habitat assessment is needed to reflect planned changes to the Project (for details, see the response to AER Round 3 SIR 1). The CFHCP might also be updated as part of the Project Update. If an update is required, the same conservative methods will be applied. ESRD/CEAA Page 176 October 2014

179 Frontier Oil Sands Mine Project ESRD and CEAA Responses Water b. Lentic and lotic habitats are not expected to be similar in terms of lower trophic productivity, as described by Odum (1956) and Randall et al. (1995). The level of productivity in a given geographic area and habitat type is typically site specific and depends on many factors. Both lentic and lotic habitat provide lower-trophic support and food for resident fish, and the HSI models used to evaluate compensation habitats associated with the Project specifically considered habitat type. In developing the CFHCP for the Project, there has been no assumption that the lentic habitats provided in the FHCL will function exactly as the affected lotic habitats (i.e., with respect to lower order productivity). However, the CFHCP does assume that the lentic compensation habitats will suitably compensate for fish productivity losses in affected habitats (both lotic and lentic). As described in the response to part a, several factors were considered in developing the CFHCP, as well as other regional fish habitat compensation plans, so that the compensation habitats can be expected to provide sufficient productivity compensation. REFERENCES Odum, H.T Primary production in flowing waters. Limnology and Oceanography 1: Randall, R.G., C.K. Minns and J.R.M. Kelso Fish production in freshwaters: are rivers more productive than lakes? Canadian Journal of Fisheries and Aquatic Sciences 52: Ryder, R.A. and J. Pesendorfer Large rivers are more than flowing lakes: a comparative review. In D.P. Dodge [ed.] Proceedings of the International Large River Symposium. Canadian Special Publication in Fisheries and Aquatic Science: 106. Question 30 SIR1, Volume 1, Section 10, SIRs 72 and 73, Pages SIR1, Volume 1, Section 5.5, SIR 111a, Pages to SIR 112, Pages to SIR1, Volume 1, Section 10, SIR 71 b, Page 148 SIR2, Volume 1, Aquatics, SIR 30 Teck concludes that the loss of fish habitat will be offset by the Fish Habitat Compensation Lake and result in no net loss of fish habitat productivity and low environmental consequence. a. Address the following in the aquatic ecology assessment: i. Support the conclusions that overall fish habitat productivity within the LSA will be greater than at baseline, and that after closure, fish habitat is expected to develop naturally within reclaimed diversion channels and pit lakes. Provide reference to successful fish habitat compensation works, diversion channels, EPLs and mine closure drainage that have been demonstrated through monitoring to result in increased overall productivity as compared to October 2014 ESRD/CEAA Page 177

180 ESRD and CEAA Responses Water Frontier Oil Sands Mine Project measured pre-development productivity or a reference watershed. Provide a discussion of the uncertainty associated with these conclusions. ii. Describe how these assessment conclusions will be confirmed, describing specific monitoring approaches and study design to assess effects on productivity. Discuss the use of reference watersheds and before-after-control-impact (BACI) designs. iii. Update the fish habitat compensation plan and the aquatic ecology assessment to ensure potential habitat degradation associated with water quality changes has been considered and clearly discussed. Include a discussion of aquatic habitat not physically removed, but, influenced by water quality changes. Describe how the potential for reduced biotic availability or productivity, aquatic biota fitness or behavioral responses has been considered. Provide a discussion of the uncertainty associated with water quality changes and the uncertainty and knowledge gaps associated with consequent aquatic biota behavioral and fitness responses. Response 30 a. i. The conclusion that, during operations and at closure, overall fish habitat productivity in the aquatics LSA will be greater than at baseline is based on: the development of compensation habitat (i.e., the FHCL associated with the CFHCP) the potential for fish habitat productivity to develop in the pit lakes, waterbodies and watercourse channels that will constitute the closure drainage system The FHCL is specifically designed to compensate potential effects on fish habitat productivity, and the closure drainage system is designed and expected to support viable aquatic ecosystems, including fish habitat and fish populations. As described in response to ESRD/CEAA Round 3 SIR 31c, a high level of confidence is associated with the conclusion that the FHCL will result in an increase in fish habitat productivity and fish abundance. This conclusion is based on the processes and methods used to assess productivity effects and develop the CFHCP and on comparisons with regional waterbodies. The response to ESRD/CEAA Round 1 SIR 120a states: The Project s FHCL is predicted to have a high probability of success based on the following factors: The FHCL will be designed and constructed to provide habitat features that: (i) are suitable for use by the fish species targeted for inclusion in the lake; and (ii) will support development of self-sustaining fish populations. For example, features such as lake bathymetry, substrate particle sizes, ratios of littoral and pelagic areas, and shoreline development ratios will be built to suitable design specifications. ESRD/CEAA Page 178 October 2014

181 Frontier Oil Sands Mine Project ESRD and CEAA Responses Water... The FHCL is designed to provide productive... fish habitats (based on habitat unit [HU] calculations)... greater than the affected habitats. The FHCL is designed to provide habitat conditions that meet all life cycle requirements of the target fish species. Currently, the affected habitats have numerous habitat limitations relative to the needs of large-bodied species (i.e., sport fish and suckers) for spawning, rearing, feeding and overwintering, as well as some limitations for forage fish life cycle needs (e.g., overwintering). The timing to construct and develop the FHCL at the start of the Project will allow for monitoring and adaptive management of the FHCL during the early stages of Project development, including incorporating the results of monitoring programs and lessons learned by other operators engaged in similar habitat compensation works in the region. As described in response to ESRD/CEAA Round 3 SIR 20b, the CFHCP uses habitat evaluation procedures (HEP) to document the quantity and quality of available habitat for selected species. Habitat quantity is defined by surface area, and habitat quality is defined by species-specific habitat suitability indices (HSI), which describe the ability of key habitat components to supply the life requisites of the species. Habitat quantity and quality are combined to derive HUs, which are used to represent the overall value of the habitat and to assess the degree to which habitat productivity is affected or provided. As described in response to ESRD/CEAA Round 3 SIR 18c and SIR 29a, HUs are calculated in a conservative manner so that productivity losses will not be underestimated because of possible limitations in fish distribution data or habitat suitability data. In addition, the design of the FHCL provides HU compensation for the conservatively estimated HU losses on a more-than-equivalent basis. Overall, the FHCL is designed to provide a higher level of fish productivity than that provided by the affected habitats. In particular, there is a high level of confidence that the FHCL will provide increased habitat productivity for large-bodied fish species, including whichever sport fish and sucker species are selected for inclusion in the target fish community (see the response to ESRD/CEAA Round 3 SIR 20a for more information on selection of the target fish community). Comparison of the FHCL with regional waterbodies and their fish communities shows that the FHCL can be expected to support the proposed fish community type (see the response to ESRD/CEAA Round 3 SIR 20 and SIR 35a). Although confidence in the ability of the FHCL to support increased fish habitat productivity in the aquatics LSA, particularly for large-bodied species, is high, some uncertainty remains because of the lack of previously demonstrated success for similar compensation works. As described in response to ESRD/CEAA Round 1 SIR 120f, and cited in Round 3 SIR 18e and SIR 21a: Although similar habitat compensation works are in development in the oil sands region (i.e., planning, construction, filling or post-filling), their success... [in October 2014 ESRD/CEAA Page 179

182 ESRD and CEAA Responses Water Frontier Oil Sands Mine Project providing full compensation for predicted effects on habitat productivity] has not yet been demonstrated. The most advanced of these compensation works is the Horizon project s compensation lake. [Preliminary results of lake monitoring] indicate that aquatic macrophytes have established and are expanding naturally. Benthic invertebrate and planktonic communities are well established, and fish populations for some species (i.e., Arctic grayling, both white and longnose suckers, and several forage fish species) have naturally colonized the lake. Fish populations are expanding with successful spawning and recruitment documented, and the one introduced forage fish species is establishing well. The response to ESRD/CEAA Round 3 SIR 18e further states:... other oil sands operators have recently initiated or will soon be starting monitoring and research programs for their compensation habitats. These monitoring programs are designed to assess the effectiveness of the compensation habitats and in the future will provide information regarding the success or lack of success of these compensation measure that will be useful to inform regional operators, regulators and potentially affected Aboriginal communities. Examination of ecological restoration projects has identified the need for processes to address uncertainty in determining compensation effectiveness (see the response to ESRD/CEAA Round 3 SIR 31c). These processes might include limiting time lags, providing appropriate monitoring, and committing to adaptive management. For the Frontier Project, the time lag associated with constructing the FHCL will be limited to the extent possible. The Project will also include appropriate monitoring to confirm the effects of the Project on fish productivity and abundance, as well as the effectiveness in compensating the observed effects (see the conceptual monitoring plan provided in response to ESRD/CEAA Round 3 SIR 24). These factors will also be considered as part of the planned Project Update (see the response to AER Round 3 SIR 1) if any updates to the CFHCP and FHCL are required. Teck is also committed to adaptively managing the FHCL and to any additional compensation measures that might be required, as determined by the monitoring program. Some uncertainty also exists in the HSI models. As described in response to ESRD/CEAA Round 1 SIR 18b: HSI models developed for use in the oil sands region... have not yet been validated. The 2008 versions of the models have been used in various validation exercises being conducted by other oil sands proponents [for other oil sands developments]; however, this work is still in progress. Recently, the Fisheries Sustainable Habitat (FiSH) Committee of the Oil Sands Developers Group... [began] work to centralize the data associated with predisturbance monitoring and HSI model validation [to coordinate the validation exercises for the region.] It is not known when the regional ESRD/CEAA Page 180 October 2014

183 Frontier Oil Sands Mine Project ESRD and CEAA Responses Water assessment of HSI validation data will be complete or when revisions to the 2008 version of the models will be available. Recent authorizations for oil sands operations provided by DFO under the Fisheries Act typically include the condition that the proponent conduct HSI model validation exercises in the affected habitats in the development area, adjust the models based on the development and on regional validation results, and apply the adjusted models to habitat losses and gains to refine the accuracy of model predictions. It is expected that anticipated Fisheries Act authorization for the Project will require an HSI model validation exercise be completed. Following closure, viable, self-sustaining aquatic ecosystems (including additional productive fish habitats) are expected to develop naturally in the permanent lakes, wetlands and watercourse channels that will comprise the closure drainage system. These systems are expected to be able to support fish populations and lower trophic levels. Expectations are based on predictions that the constructed systems will have suitable water quality and sediment quality to support aquatic life because they will convey water from upstream unaffected areas or will provide suitable bioremediation of reclaimed water. The responses to ESRD/CEAA Round 1 SIR 97d and SIR 99b provided aspects of pit lake design that are expected to support the development of viable aquatic ecosystems in the pit lakes, and natural and biological components that are expected to develop in the pit lakes. The response to ESRD/CEAA Round 1 SIR 97c provided aspects of the geomorphic design of the closure drainage system that are expected to support the development of viable, self-sustaining aquatic ecosystems. Although the pit lakes, small lakes, shallow wetlands and watercourse channels of the closure drainage system are expected to develop viable aquatic ecosystems, no specific targets exist for production or species assemblages for fish or other trophic levels for these systems. As stated in the response to ESRD/CEAA Round 1 SIR 101: Unlike the FHCL, the components of the closure drainage system are not designed with the goal of providing a specific level of habitat productivity or fish production, but are designed to provide viable, self-sustaining aquatic ecosystems that will be able to support local natural aquatic species and communities. Success will be determined by monitoring the closure system for stability, sustainability and the physical features it is designed to provide. Water quality, sediment quality and the physical features of the closure drainage system will be monitored, and the results will be used to measure success relative to the goal of providing lentic and lotic aquatic habitats capable of supporting local aquatic life. Measurable targets will be developed as part of the detailed closure drainage monitoring plan once the final design of the drainage features is completed. Teck will steward towards viable, self-sustaining aquatic ecosystems using monitoring to confirm that the pit lakes are providing sufficient bioremediation. As stated in the response to ESRD/CEAA Round 1 SIR 97d, a monitoring plan will be used to evaluate the success of the pit October 2014 ESRD/CEAA Page 181

184 ESRD and CEAA Responses Water Frontier Oil Sands Mine Project lakes at providing suitable bioremediation. An adaptive management plan will be developed that outlines available mitigation and active treatment options if monitoring indicates that natural bioremediation is less successful than expected. Monitoring the development of physical characteristics of the early components of the closure drainage system will help adaptively manage the design of subsequent features, where appropriate. Because closure of the Frontier Project will occur later in the overall development schedule for the oil sands region, Teck will be able to learn from the closure activities and monitoring results of other oil sands mines currently approved or operating, and its ability to do so will be enhanced by it being a member of COSIA. All relevant information will be used in Teck s adaptive management plan for the Project to improve the design, operation and monitoring of the closure landscape. Confidence that the drainage system will function as fish and aquatic habitat is high based on confidence in predictions related to water quality, sediment quality and aquatic health, as well as the expected value of including fish habitat design considerations for the closure drainage features. Success of pit lakes in developing viable aquatic ecosystems has not yet been demonstrated in the oil sands region. However, monitoring results for one constructed watercourse, the Syncrude West Interceptor Ditch, provide a high level of confidence that aquatic ecosystems and fish habitat can be successfully developed in the watercourses of the closure drainage system. This ditch supported various components of aquatic ecosystems, including zooplankton, phytoplankton, macroinvertebrates and fish populations, despite it being designed as a sample water conveyance ditch and not as a geomorphic watercourse channel (Tsui et al. 1977). Although there is a low level of uncertainty regarding the development of fish and aquatic habitats in the closure drainage system, there remains uncertainty about the level of productivity that will develop, other than in the FHCL. Additional productivity in the closure drainage system is not needed to meet the compensation objective, but it will be important to providing functional aquatic habitats in the watercourses and waterbodies on the closure landscape. ii. The Project will include appropriate monitoring to confirm the effects of the Project on fish habitat productivity and the effectiveness in compensating for the observed effects. Teck is also committed to adaptively managing the FHCL and to any additional compensation measures that might be required, as determined by the monitoring program. The monitoring approach is described in the conceptual monitoring plan provided in response to ESRD/CEAA Round 3 SIR 24. The specifics of the study design will be finalized in consultation with regulators and stakeholders. ESRD/CEAA Page 182 October 2014

185 Frontier Oil Sands Mine Project ESRD and CEAA Responses Water The conceptual monitoring plan includes the following before-after-control-impact (BACI) elements: Before and after data will be collected at various Frontier Project monitoring locations, including potentially affected sites. Additional predisturbance data will be collected, and data will continue to be collected throughout Project construction, operation and at closure. These data, as well as data collected for the FHCL throughout the development, maturation and stabilization phases, will be used to assess fish habitat productivity. The data will also form the basis for evaluating effects of the Project and the effectiveness of compensation measures with respect to fish habitat productivity. Control site data will be obtained from RAMP for regional control (i.e., reference) watershed sites for which fish monitoring is conducted, and for the regional normal range of variability. Data from control sites will be compared to monitoring data to evaluate the monitoring data in relation to regional trends. iii. The potential for changes in water quality to affect fish habitat and habitat productivity is summarized in response to ESRD/CEAA Round 3 SIR 42. This response summarizes the effects pathways that were assessed between water quality and aquatic ecology, as well as the assessment conclusions, uncertainty and knowledge gaps. Water quality linkages were assessed for changes in DO and thermal regime. The surface water quality assessment also included potential effects on aquatic health resulting from changes in water or sediment chemistry and temperature. The confidence level of the water quality predictions are described in response to ESRD/CEAA Round 3 SIR 12a and are summarized in response to ESRD/CEAA Round 3 SIR 42b. Prediction confidence for changes in DO is high based on modelling results and the success of available mitigation. Prediction confidence for changes in temperature is moderate because, although the model was well calibrated and validated, it was calibrated from streams in the Muskeg River watershed. The assessment concluded that aquatic habitat that might be affected by changes in water quality included the portion of Big Creek downstream of the Project area resulting from changes in thermal regime at closure because of the presence of the pit lake. The predictions for changes in thermal regime were based on predicted temperatures in the pit lake outflow and were not corrected for possible attenuation as the water flows down the creek. As described in response to ESRD/CEAA Round 3 SIR 13, the predicted changes in thermal regime in Big Creek consist of delays in spring warming and fall cooling of water temperatures by approximately one month each. The temporal shift was evaluated for potential effects on fish habitat productivity, including benthic invertebrate communities, based on fitness and behavioural responses of the benthic invertebrate community and the fish species known to use lower Big Creek. Species sensitivity and timing of life history events (such as invertebrate October 2014 ESRD/CEAA Page 183

186 ESRD and CEAA Responses Water Frontier Oil Sands Mine Project hatch/emergence, fish spawning, incubation, growth and migration) were among the factors considered. It was concluded that the temperature shift was likely to: shift invertebrate emergence patterns and result in an associated shift in invertebrate abundance patterns shift the timing of the start of the spawning runs for the two spring-spawning sucker species that use lower Big Creek (i.e., longnose and white suckers) For forage fish, a similar delay in spawning might occur for the species that use Big Creek for spawning and that typically spawn in the spring period, but not for species that typically spawn in the summer at higher water temperatures. For all species, incubation and hatching success are assumed to be unaffected if the spawning period is delayed until appropriate temperatures occur. Based on the potential shift in benthic invertebrate abundance, it is expected that food availability, fish growth and productivity would be unaffected, although would be offset in time. The delay in cooling of water temperatures in the fall was considered likely to delay fall outmigration of burbot but not overall productivity of this species. Overall, it was concluded that the effects on habitat productivity in lower Big Creek would be negligible, partly because many species present in lower Big Creek tolerate a wide range of temperatures and exist in geographic areas where seasonal water temperatures are lower and higher than in the Big Creek, which suggests they may have low sensitivity to the predicted changes in temperature. However, there is a high level of uncertainty in the prediction that temperature shifts will not affect fish production in lower Big Creek because the extent of temperature attenuation is unknown and because knowledge gaps remain. For example, it is not known whether lower Big Creek is used for spawning by suckers from the Athabasca River or whether there is potential for ecological interactions to affect the productivity of the watercourse for fish (i.e., because of the predicted temperature shifts). Therefore, seasonal monitoring of benthic invertebrate communities and fish populations, including fish use and productivity, will be conducted for lower Big Creek to increase prediction confidence (see the conceptual monitoring plan provided in response to ESRD/CEAA Round 3 SIR 24). Updating the CFHCP based on potential habitat effects associated with changes in water quality is not necessary at this time. Changes in aquatic ecosystems will be assessed as part of the planned Project Update (see the response to AER Round 3 SIR 1), and the CFHCP and FHCL will be updated if required. If the monitoring program for lower Big Creek identifies adverse effects on habitat productivity, the CFHCP will be updated. REFERENCES Tsui, P., D. Tripp and W. Grant A Study of Biological Colonization of the West Interceptor Ditch and Lower Beaver Creek. Prepared by Aquatic Environments Ltd. ESRD/CEAA Page 184 October 2014

187 Frontier Oil Sands Mine Project ESRD and CEAA Responses Water Question 31 SIR1, Volume 1, Section 10, SIRs 72 and 73, Pages SIR1, Volume 1, Section 5.5, SIR 111a, Pages to SIR 112, Pages to SIR1, Volume 1, Section 10, SIR 71 b, Page 148 SIR2, Volume 1, Aquatics, SIR 30 Teck concludes, with respect to potential changes in the fish abundance in the Athabasca River, Changes in mean seasonal Athabasca River flows from cumulative withdrawals at PDC are within allowable limits of the WMF [Water Management Framework]. The WMF also ensures through water withdrawal restrictions that seasonal flows of the Athabasca River are maintained at an acceptable level. Therefore there will be no detectable effects on fish abundance in the revised RSA. This seems to assume that the only driver for fish abundance in the Athabasca River is flow volume. a. Support the assumption that flow is the only relevant factor in the assessment of effects on fish abundance in the Athabasca River. If the assumption cannot be supported, ensure the aquatic ecology assessment considers all factors that may influence fish abundance in the Athabasca River. b. Discuss ecological complexity and uncertainty associated with aquatic ecology and fish populations, their potential response to land use changes and the potential for abundance in the Athabasca River to be influenced. Include this discussion in the aquatic ecology assessment. c. Clarify what Teck means by overall abundance as used in the conclusion. Is Teck referring to overall numbers or biomass of fish? Provide peer-reviewed support or data to support the conclusion that the FHCL will result in an increase in overall abundance. Update the fish habitat compensation plan and the aquatic ecology assessment. Response 31 a. There is no assumption in the fish and fish habitat assessment that flow is the only relevant factor influencing potential effects of the Project on fish abundance in the Athabasca River. The assessment considers several potential effects pathways and associated linkages; one of these is the linkage to potential changes in habitat resulting from changes in flows. Linkages and associated changes that were considered in assessing potential effects of the Project on fish abundance in the Athabasca River included: changes in habitat area changes in habitat accessibility October 2014 ESRD/CEAA Page 185

188 ESRD and CEAA Responses Water Frontier Oil Sands Mine Project changes in flows, water levels, sedimentation or channel regime changes in water quality for key biological parameters changes in aquatic health fish entrainment or impingement at the proposed intake changes in fishing pressure and fish harvest For all valid linkages, predicted changes in fish habitat were carried forward to assess potential changes in fish abundance. For the Athabasca River, this included changes in flows and a possible (but currently undefined) small-scale change in habitat area associated with the construction and operation of the freshwater intake (see the response to ESRD/CEAA Round 3 SIR 42 for a full summary of assessment linkages and conclusions). These habitat changes were assessed along with potential direct effects on fish abundance associated with intake operations and changes in fishing pressure. The assessment concluded that compliance with the Water Management Framework (WMF) would appropriately mitigate potential changes in flows and the effects on fish habitat and fish abundance in the Athabasca River. Changes in habitat area at the intake could not be fully assessed because the detailed design is not yet available for the structure; this is typical at the current stage of engineering. To address this reality, Teck has committed to assess fish and fish habitat effects for the construction and operation of the intake, and implement appropriate compensation measures to mitigate the expected effects, if required (see Volume 5, Section , Page 5-30). The potential for loss of fish because of entrainment or impingement at the intake will be appropriately mitigated by designing the intake to comply with federal and provincial screening criteria (see Volume 5, Section , Page 5-41). The Project is not expected to result in increased access to the Athabasca River by anglers. Based on the assessment, and the provision of appropriate habitat compensation measures for the water intake (if necessary), Teck concluded that there would be no adverse effects on habitat and fish populations in the Athabasca River. Teck has provided additional information about potential changes in fish habitat or abundance in the Athabasca River in response to SIRs (Rounds 1 to 3). These responses have included further details about: potential changes in habitat productivity resulting from land use changes in watersheds in the aquatics LSA, and the potential effects of these changes on detrital inputs to the Athabasca River (see the responses to ESRD/CEAA Round 2 SIR 10 and SIR 34 and to ESRD/CEAA Round 3 SIRs 4, 8 and 25) ESRD/CEAA Page 186 October 2014

189 Frontier Oil Sands Mine Project ESRD and CEAA Responses Water benthic invertebrate drift and support for the lower-level productivity of the Athabasca River (see the responses to ESRD/CEAA Round 2 SIR 34 and SIR 176 and to ESRD/CEAA Round 3 SIR 26) the potential for direct effects on fish abundance because of increases in the regional human population and potential increases in fishing pressure (see the response to ESRD/CEAA Round 3 SIR 36) As described in response to ESRD/CEAA Round 2 SIR 176, the Frontier Project has negligible potential for changes in invertebrate drift as a food source for fish in the Athabasca River. Under existing conditions, invertebrate drift from the portions of Athabasca River tributary watercourses in and upstream of the PDA does not currently supplement downstream sections..., or the Athabasca River, because of the presence of large wetlands areas that lack any watercourse channel habitat. In one case (i.e., Redclay Creek), the diversion plan for the Project will provide connectivity between the upper watershed and the lower watercourse and allow the possibility for increased invertebrate drift to the lower portions of the watercourse and the Athabasca River. However: given the generally local origin of invertebrate drift and typically short drift distances, the potential for changes in invertebrate drift to the section of the Athabasca River adjacent to the Project area largely depends on changes to the lowermost parts of the three tributary drainages in the Project area, and on the other drainages that will form part of the closure landscape. Overall, changes to benthic invertebrate communities in tributary watercourses and changes in the volume of invertebrate drift are expected to be negligible, with invertebrate production being maintained in the watercourses that drain the aquatics LSA to the Athabasca River. Additional invertebrate production is also expected to occur in the pit lakes, waterbodies and channels that will form the other components of the closure drainage system. b. The potential for fish abundance in the Athabasca River to be affected by the Frontier Project and by regional oil sands development is possible through a number of pathways. These pathways might involve various ecological components and functions of the ecosystem, including physio-chemical characteristics, nutrient levels, algae, detrital inputs, primary production, secondary production by benthic invertebrates (i.e., because of drift from tributaries or internal production) and various trophic levels of fish production. Fish populations are supported by: the internal productivity of the river productivity exported to the Athabasca River from tributary watersheds direct use of the tributary watersheds for life history functions such as spawning, incubation, nursery, rearing and foraging habitat October 2014 ESRD/CEAA Page 187

190 ESRD and CEAA Responses Water Frontier Oil Sands Mine Project These tributary contributions and functions can be affected by the landscape changes that have occurred or are expected to occur in the tributary watersheds. The fish and fish habitat assessment for the Project and the information provided in response to SIRs considered the various effect pathways that were relevant to the Project and by which it could potentially affect fish and fish habitat, either alone or cumulatively with other regional developments. Potential cumulative effects were assessed based on available predictions of residual effects for other developments. As summarized in the response to ESRD/CEAA Round 3 SIR 42 (see Table 42b-1), the effects of the Frontier Project on the productivity of the Athabasca River are predicted to be negligible. In addition, none of the other operating oil sands mine developments have predicted residual effects on the productivity of the Athabasca River (see the response to ESRD/CEAA Round 3 SIR 9). Similarly, the results of long-term monitoring by RAMP for fish populations in the Athabasca River indicate no long-term trends or changes for fish abundance, with the exception of two sport fish (goldeye and lake whitefish) populations that have shown an increase in abundance over time. Although RAMP data on the abundance of large-bodied fish populations is limited, the results indicate there has been no adverse response to landscape changes in the lower Athabasca River basin. c. Overall abundance was generally used to refer to numbers of fish. However, assessments of potential changes in productivity also considered biomass as an important component of productivity. There is no available literature regarding the success of fish habitat compensation lakes in the oil sands region. As described in response to ESRD/CEAA Round 3 SIR 18, there is literature evaluating the effectiveness of compensation lakes in Canada (Quigley and Harper 2006), which demonstrated success for some, but not all, compensation habitats. However, none of the case studies presented are directly applicable to the FHCL as they involve enhancements of in-channel habitats in lotic systems, rather than development of new lentic habitats. As described in the response to ESRD/CEAA Round 1 SIR 120f and ESRD/CEAA Round 3 SIR 18 and SIR 21: Although similar habitat compensation lakes are in development in the oil sands region (i.e., planning, construction, filling or post-filling), their success... [in providing full compensation for predicted effects on habitat productivity or providing increased fish abundance] has not yet been demonstrated. The most advanced of the compensation works is the Horizon project s fish habitat compensation lake. Following filling, the biological development of this lake has been monitored from 2008 to 2011 [now 2012] (Golder 2013). Results to date indicate that... fish populations for some species (i.e., Arctic grayling, both white and longnose suckers, and several forage fish species) have naturally colonized the lake. Fish populations are expanding with successful spawning and recruitment documented. Although development of the Horizon Lake fish population is underway, it is too early in the development of the lake to demonstrate that expected levels of fish abundance have been achieved. ESRD/CEAA Page 188 October 2014

191 Frontier Oil Sands Mine Project ESRD and CEAA Responses Water The conclusion that the FHCL will result in an increase in fish abundance is associated with a high level of confidence, based on the processes and methodologies used to assess productivity effects and develop the CFHCP. As described in response to ESRD/CEAA Round 1 SIR 120a: The Project s FHCL is predicted to have a high probability of success based on the following factors: The FHCL will be designed and constructed to provide habitat features that: (i) are suitable for use by the fish species targeted for inclusion in the lake; and (ii) will support development of self- sustaining fish populations. For example, features such as lake bathymetry, substrate particle sizes, ratios of littoral and pelagic areas and shoreline development ratios will be built to suitable design specifications. The FHCL is designed to provide productive fish habitats greater than the affected habitats (based on habitat unit calculations). The FHCL is designed to provide habitat conditions that meet all life cycle requirements of the target fish species. Currently, the affected habitats have numerous habitat limitations relative to the needs of large-bodied species (i.e., sport fish and suckers) for spawning, rearing, feeding and overwintering, as well as some limitations for forage fish life cycle needs (e.g., overwintering). The timing to construct and develop the FHCL at the start of the Project will allow for monitoring and adaptive management of the FHCL during the early stages of Project development, including incorporating the results of monitoring programs and lessons learned by other operators engaged in similar habitat compensation works in the region. The process used to determine fish productivity losses (i.e., habitat unit calculations) is conservative so that productivity losses will not be underestimated because of possible limitations in fish distribution data or habitat suitability data (for details, see the response to ESRD/CEAA Round 3 SIR 18). In addition, the FHCL has been designed to compensate for conservatively estimated HU losses on a more-than-equivalent basis (i.e., using a compensation ratio greater than 1:1). Overall, the FHCL is designed to provide a higher level of fish productivity than that provided by the affected habitats. In turn, the FHCL is expected to support an increase in overall fish abundance. There is a high level of confidence that the FHCL will provide increased abundance of large-bodied fish species, including whichever sport fish and sucker species are selected for inclusion in the target fish community (see the response to ESRD/CEAA Round 3 SIR 20). The FHCL is designed to provide greater habitat diversity than the affected waterbody habitats and will include habitat types not present in the affected waterbodies (e.g., pelagic habitats, rocky substrates) as well as habitat types that are currently available (e.g., vegetated littoral habitat). Habitat diversity is important in terms of meeting the habitat requirements of all life stages of large-bodied fish that will be considered for inclusion in the FHCL species assemblage. With access to suitable habitat at all life stages, these species are fully expected to increase in distribution and abundance in the aquatics LSA. Comparing October 2014 ESRD/CEAA Page 189

192 ESRD and CEAA Responses Water Frontier Oil Sands Mine Project the FHCL to regional waterbodies and their fish communities shows that the FHCL can be expected to support the proposed fish community type (see the response to ESRD/CEAA Round 3 SIR 20). Although confidence is high that the FHCL will contribute to increased fish abundance in the aquatics LSA, particularly for large-bodied species, some uncertainty remains because of a lack of previously demonstrated success for similar compensation works. A study of ecological restoration projects identified the need for processes to address uncertainty in determining compensation effectiveness (Maron et al. 2012). The study highlighted the need to minimize time lags, provide appropriate monitoring and commit to adaptive management. Teck has incorporated these processes into its plans for the Frontier Project. For example: The time lag associated with the FHCL is minimized by providing compensation habitats as soon as feasible, and in advance of Project effects to productive fish habitats. The Project will include appropriate monitoring to confirm the effects of the Project on fish production and abundance, as well as the effectiveness of compensating for the observed effects (for details, see the conceptual monitoring plan provided in the response to ESRD/CEAA Round 3 SIR 24). Teck is also committed to the adaptive management of the FHCL and to any additional compensation measures that may be required, as determined by the monitoring program. Based on the information presented above, updating the CFHCP and the fish and fish habitat assessment is not necessary. REFERENCES Golder (Golder Associates Ltd.) Horizon Lake Monitoring Report. Prepared for Canadian Natural Resources Ltd. by Golder Associates Ltd., Calgary, Alberta. June Maron, M., R.J. Hobbs, A. Moilanen, J.W. Matthews, K. Christie, T.A. Gardner, D.A. Keith, D.B. Lindenmayer and C.A. McAlpine Faustian Bargains? Restoration Realities in the Context of Biodiversity Offset Policies. Biological Conservation 155: Quigley, J.T. and D.J. Harper Effectiveness of Fish Habitat Compensation in Canada in Achieving No Net Loss. Environmental Management 37: ESRD/CEAA Page 190 October 2014

193 Frontier Oil Sands Mine Project ESRD and CEAA Responses Water Question 32 SIR1, Volume 1, Section 10, SIRs 72 and 73, Pages SIR1, Volume 1, Section 5.5, SIR 111a, Pages to SIR 112, Pages to SIR1, Volume 1, Section 10, SIR 71 b, Page 148 SIR2, Volume 1, Aquatics, SIR 30 Teck concludes there will be no adverse environmental effect on fish abundance. This appears to be inconsistent with current and historical data for other watersheds in which mining is currently underway, and inconsistent with predictions associated with regional land use planning models and the Terrestrial Ecosystem Management Framework (TEMF) generated by CEMA. a. Clarify how Teck s fish abundance assessment conclusion considers and is consistent with current and historical data for other regional watersheds in which mining is currently underway. Where effects predictions are inconsistent provide an explanation. Specifically consider and compare mine EIA predictions, fish fence data and oil sands mine development in the Muskeg River watershed. Ensure uncertainty is considered and discussed. Response 32 a. The response to ESRD/CEAA Round 3 SIR 9 reviews: assessment predictions for other regional oil sands mine developments available monitoring data for operating oil sands mines and regional monitoring programs current and historical data for other regional watersheds in which mining is currently underway It also compares information available from these sources to predictions for the Frontier Project. COMPARISON TO OTHER WATERSHEDS AND EIA PREDICTIONS Assessment predictions for the Frontier Project are consistent with other oil sands mine EIA predictions, which predict negligible or no overall effects on fish habitat productivity, fish abundance and fish and fish habitat diversity. These conclusions result from the incorporation of appropriate mitigation and fish habitat compensation or enhancement measures. The prediction of increased fish abundance, particularly for large-bodied species, is also consistent with predictions as stated other oil sands mine EIAs, and result from compensation habitats that are expected to provide increased habitat productivity and habitat diversity for a range of species. There is a high level of confidence in the conclusion that the CFHCP will result in an increase in fish abundance, based on the methodologies used to assess productivity effects and develop the FHCL (see the response to ESRD/CEAA Round 3 SIR 31). October 2014 ESRD/CEAA Page 191

194 ESRD and CEAA Responses Water Frontier Oil Sands Mine Project COMPARISON TO CURRENT AND HISTORICAL DATA As described in response to ESRD/CEAA Round 3 SIR 9 and SIR 34, based on available monitoring reports, no conclusions can be reached concerning EIA predictions and associated effects. This is because of the current limited duration of monitoring efforts, the early stages of development for compensation habitats, and the early stages of oil sands development (i.e., when specific effects are not yet expected). As such, the available monitoring data do not indicate whether effects have been substantially under- or overpredicted and do not provide information to confirm or support the effects predictions or uncertainty assessment for the Frontier Project. The most comprehensive monitoring data available for the oil sands region to date is provided by RAMP, which has been monitoring aquatic resources in the oil sands region on an annual basis since The program monitors fish and fish habitat (including benthic invertebrate communities) with the goal of: defining the baseline range for the monitoring components and variables identifying long-term trends verifying EIA predictions Results of RAMP monitoring show that the benthic invertebrate communities at most monitoring sites are similar or improved for measurement endpoints relative to reference sites, regional variability or trends over time. This includes sites located near relatively intensive oil sands development (e.g., the Muskeg River, Jackpine Creek, Shipyard Lake). The remaining benthic invertebrate community monitoring sites are classified as having lower or declining conditions for one or more measurement endpoints. RAMP results for fish populations indicate that the number of monitoring sites classified as similar to baseline or reference conditions is approximately equal to the number classified as lower than baseline or reference conditions. Differences between current conditions and baseline or reference conditions were identified for the fish assemblage monitoring in the Muskeg, Steepbank, Ells and MacKay rivers and in Fort and Jackpine creeks. Some of the monitoring sites for benthic invertebrate communities and fish populations that were classified as being different than baseline or reference conditions were noted to have environmental conditions that might be a factor in the results (e.g., habitat differences between monitoring and reference sites or between survey periods). There are no conclusions from the RAMP results that the differences or changes for any of the monitoring sites are specific indications of habitat degradation or result from to oil sands development, nor are there any conclusions presented to date regarding the accuracy or confirmation of EIA predictions for operating oil sands mines. RAMP results for the Athabasca River fish inventory show that although there has been speciesspecific variability in assessment variables such as relative abundance, age-frequency distributions and condition factor among years, there are no long-term trends or changes identified in this data. The ESRD/CEAA Page 192 October 2014

195 Frontier Oil Sands Mine Project ESRD and CEAA Responses Water one exception is that goldeye and lake whitefish populations have shown an increase in abundance over time. The increase in goldeye is considered to potentially be the result of environmental conditions that could contribute to improved goldeye recruitment. To date, none of the monitoring results contradict the EIA predictions for the Frontier Project. Monitoring has not identified any cases where effects were substantially under- or overpredicted. The monitoring results also do not indicate any specific level of uncertainty for assessment predictions. The effects predictions for the Frontier Project are considered appropriate and were based on a Project-specific assessment of the mine development plan and the specific aquatic resources in the Project area that might be affected by the development activities. COMPARISON TO FISH FENCE DATA With respect to a comparison of current and historical data for the Muskeg River watershed, the fish fence data for the Muskeg River and for Jackpine Creek indicate a decline in the populations of largebodied fish that use the watershed on a seasonal basis (for details, see the response to ESRD/CEAA Round 3 SIR 43). There is some indication the decline began prior to oil sands development in the watershed. Although significant declines occurred for all species, white sucker use in the most recent survey was the highest ever recorded, indicating high variability in the fish fence data. The RAMP fish assemblage monitoring results for the Muskeg River indicate declines in various measurement endpoints that could stem from degrading conditions. However, all declining indicators are considered to have possible associated environmental factors that could be responsible, or at least contributing to, the observed declines. These environmental factors would be similar to those that might be contributing to observed increases in fish abundance for some fish species in the Athabasca River, as identified by RAMP. No conclusions have been derived about the cause of the observed trends, and no suggestion has been made that they are due to oil sands development. SUMMARY The Project-specific assessment conducted for the Frontier Project considered the specific Project development plan and characteristics of the local watercourses, waterbodies and fish populations. Although the assessment conclusions do not contradict existing monitoring data, the information is not particularly relevant for the reasons described above. As well, no data or conclusions indicate observed effects in these other watersheds. The conceptual monitoring plan for the Frontier Project includes monitoring of fish populations and abundance in downstream habitats to assess Project effects, confirm EIA predictions and determine whether additional compensation is required (see the response to ESRD/CEAA Round 3 SIR 24). October 2014 ESRD/CEAA Page 193

196 ESRD and CEAA Responses Water Frontier Oil Sands Mine Project Question 33 SIR1, Volume 1, Section 10, SIRs 72 and 73, Pages SIR1, Volume 1, Section 5.5, SIR 111a, Pages to SIR 112, Pages to SIR1, Volume 1, Section 10, SIR 71 b, Page 148 SIR2, Volume 1, Aquatics, SIR 30 Teck assessed fish diversity based on changes in surface area, quality, and types of habitat of each waterbody or watercourse involved. a. Provide peer-reviewed support for the underlying conclusion that a change in fish diversity is related solely to change in habitat. If the conclusion cannot be supported, update the assessment conclusion as appropriate to consider other potential influences on fish diversity. Ensure the aquatic ecology assessment includes this information. Response 33 a. The assessment does not conclude that a change in fish diversity is related solely to change in habitat. The assessment considers several potential effects pathways and associated linkages for fish diversity; one of these is the linkage to potential changes in habitat. The potential for changes in fish and fish habitat diversity is one of three key issues identified in the fish and fish habitat assessment (see Volume 5, Section 5.3.4, Table 5-2, Page 5-13). The other two are changes in fish habitat and changes in fish abundance. Linkages and associated changes that were considered in assessing potential changes in fish diversity included: changes in habitat area changes in habitat accessibility changes in flows, water levels, sedimentation or channel regime changes in water quality for key biological parameters changes in benthic invertebrate communities as a key food source for fish changes in aquatic health fish entrainment/impingement at the proposed intake changes in fishing pressure and fish harvest For all valid linkages, predicted changes in fish habitat and abundance were carried forward to assess potential changes in fish diversity. The assessment conducted for the Frontier Project determined there were valid linkages and potential effects resulting from changes in fish habitat (e.g., because of changes in habitat area associated with watercourse diversions and other landscape changes) and ESRD/CEAA Page 194 October 2014

197 Frontier Oil Sands Mine Project ESRD and CEAA Responses Water changes in watercourse flows. For a summary of assessment linkages and conclusions, see the response to ESRD/CEAA Round 3 SIR 42. No predicted changes in fish abundance were identified. Effects of the Project on fish diversity were assessed based on valid linkage pathways that considered all potential influences on fish diversity from Project-related activities. As a result, Teck considers the assessment complete and will follow similar methods when considering the planned Project Update (see the response to AER Round 3 SIR 1). Question 34 SIR1, Volume 1, Section 10, SIRs 72 and 73, Pages SIR1, Volume 1, Section 5.5, SIR 111a, Pages to SIR 112, Pages to SIR1, Volume 1, Section 10, SIR 71 b, Page 148 SIR2, Volume 1, Aquatics, SIR 30 In a discussion of other development in the RSA (primarily forestry), Teck concludes that None of the developments have the potential to affect fish habitats or populations in the revised LSA and therefore would not affect fish and fish habitat diversity. There is considerable peer-reviewed literature to support the opposite conclusion. Forestry (noted by Teck as the primary other land use) can result in changes to water quality, habitat fragmentation and increased access all of which have the potential to influence aquatic biota. a. Update aquatic ecology assessment to include potential effects associated with other land uses such as forestry. Teck concludes there is the potential for low level effects on fish and fish habitat diversity; but that the environmental consequence is negligible. This does not appear consistent with pre-development and current monitoring data for other watersheds in which oil sands mining is underway. b. Ensure the aquatic ecology assessment conclusions consider publicly available monitoring data collected in other watersheds in which oil sands mining is currently underway. Where effects predictions are inconsistent with the monitoring data, provide an explanation. Consider and compare mine EIA predictions, fish fence data and oil sands mine development in the Muskeg River watershed. Ensure uncertainty is considered and explicitly discussed. Response 34 a. Effects of forestry on aquatic systems occur through a variety of mechanisms. Logged systems tend to have higher flow rates (Heede 1991) and temperature (Garmin and Moring 1991), as well as altered nutrient levels (Carignan et al. 2000), sedimentation rates (Garmin and Moring 1991) and level of primary production (Murphy and Hall 1981). Land use changes such as logging have potential to affect October 2014 ESRD/CEAA Page 195

198 ESRD and CEAA Responses Water Frontier Oil Sands Mine Project fish communities; however, sensitivity to these disturbances varies among species. Fish species in the revised aquatics LSA are primarily forage fish, which are resilient to disturbance (Detenbeck et al. 1992) and not consistently affected by logging regimes (St-Onge and Mangan 2000; Steedman 2003). Although logging and other land uses can affect aquatic systems, these activities occur at low levels in the revised aquatics LSA, particularly in the lower portions of LSA watersheds where fish populations occur. The potential for forestry activity and other land uses to affect aquatic resources in the aquatics LSA was considered in the fish and fish habitat assessment in the description of reference conditions (see Volume 5, Section 5.5.3, Page 5-25). Existing conditions in the aquatics LSA were considered comparable to predevelopment because industrial activity in the LSA has largely consisted of limited oil and gas drilling and logging. Most logging has occurred south of the revised aquatics LSA (i.e., in the former SDA, which is no longer part of the Project). Roads created for logging have increased access to the upper reaches of watersheds in the aquatics LSA, but only to a limited extent since there are no bridges and all road use and road crossings occurs during winter. The fish and fish habitat assessment focused on potential effects of the Frontier Project, and changes resulting from forestry and other land uses in the aquatics LSA were not sufficiently extensive at baseline to warrant further assessment. b. Publicly available monitoring data for operating oil sands mines and regional monitoring initiatives is reviewed and discussed in response to ESRD/CEAA Round 3 SIR 9bc. The response also reviews historical and current fish and fish habitat data, including data from fish fence studies, the Muskeg River and the Steepbank River. Based on this review, Teck concluded that none of the monitoring results to date contradict the assessment predictions for the Frontier Project. Monitoring has not identified any cases where effects were substantially under- or overpredicted. The results also do not indicate any specific level of uncertainty that would be relevant to assessment predictions for the Frontier Project. In comparing historical and current surveys, some declining trends were identified; however, all declining indicators have possible associated environmental factors that might be responsible or be contributing to the observed declines. No conclusions have been derived as to the cause of the observed trends or suggestions made that they are due to oil sands development. The fish and fish habitat assessment for the Frontier Project is a project-specific assessment conducted based on the specific development plan and characteristics of local watercourses, waterbodies and fish populations. In the absence of any conclusions that monitoring data indicates observed effects to date, the assessment completed for the Frontier Project is considered appropriate, and the uncertainties associated with the assessment predictions for the Project remain unchanged. ESRD/CEAA Page 196 October 2014

199 Frontier Oil Sands Mine Project ESRD and CEAA Responses Water REFERENCES Carignan, R., P. D Arcy and S. Lamontagne Comparative impacts of fire and forest harvesting on water quality in Boreal Shield lakes. Canadian Journal of Fisheries and Aquatic Sciences 57: Detenbeck, N.E., P.W. DeVore, G.J. Niemi and A. Lima Recovery of temperate-stream fish communities from disturbance: a review of case studies and synthesis of theory. Environmental Management 16: Garmin, G.C. and J.R. Moring Initial effects of deforestation on physical characteristics of a boreal river. Hydrobiologia 209: Heede, B.H Response of a stream in disequilibrium to timber harvest. Environmental Management 15: Murphy, M.L. and J.D. Hall Varied effects of clear-cut logging on predators and their habitat in small streams of the Cascade Mountains, Oregon. Canadian Journal of Fisheries and Aquatic Sciences 38: Steedman, R.J Littoral fish response to experimental logging around small Boreal Shield lakes. North American Journal of Fisheries Management 23: St-Onge, I. and P. Magnan Impact of logging and natural fires on fish communities of Laurentian Shield lakes. Canadian Journal of Fisheries and Aquatic Sciences 57: Question 35 SIR1, Volume 1, Section 10, SIRs 72 and 73, Pages SIR1, Volume 1, Section 5.5, SIR 111a, Pages to SIR 112, Pages to SIR1, Volume 1, Section 10, SIR 71 b, Page 148 SIR2, Volume 1, Aquatics, SIR 30 Teck concludes that with the inclusion of deeper habitats in the FHCL, species diversity will increase. a. Support the conclusion using peer-reviewed literature on constructed aquatic habitat and regional data. Describe the uncertainty associated with this prediction. b. Discuss inter- and intra-specific interactions, predation, and competition. Discuss trophic levels below benthic invertebrates and potential changes that might have ramifications to broader aquatic ecology, fish and productivity. Update the fish habitat compensation plan and the aquatic ecology assessment. October 2014 ESRD/CEAA Page 197

200 ESRD and CEAA Responses Water Frontier Oil Sands Mine Project Response 35 a. As stated in response to ESRD/CEAA Round 3 SIR 20a, there are currently no examples of stable and successful compensation lakes (i.e., that have had sufficient time to demonstrate success) in the oil sands region that are comparable to the FHCL. The meta-analysis of compensation lakes in Canada conducted by Quigley and Harper (2006) (reviewed in response to ESRD/CEAA Round 3 SIR 18e) also does not include any comparable compensation works (i.e., constructed lakes). However, regional data on lake size, depth and species complement support the conclusion that the deeper habitats provided in the FHCL will support a greater level of fish species diversity than the affected habitats, particularly for large-bodied sport fish. Similar to the data analysis provided in the response to ESRD/CEAA Round 3 SIR 20a, Teck reviewed available data for natural lakes (i.e., named and unnamed waterbodies) in northern Alberta (i.e., Edmonton area and north). Data obtained from the Alberta Environment and Sustainable Resource Development (ESRD) Fisheries and Wildlife Management Information System (FWMIS) database were examined for lake size, depth and species complement. For this exercise, Kearl Lake was selected as an example of a fairly large, but shallow waterbody in the oil sands region and was compared to other regional lakes that were smaller or similar in size (i.e., up to 10% larger). The results show greater species diversity in the deeper waterbodies (see Table 35a-1), with the largest difference being the number of sport fish present. Although Kearl Lake supports a fish community of forage fish species and suckers, it includes only one large-bodied sport fish (northern pike). Even though northern pike have a known habitat preference for shallow habitats during certain life stages, Kearl Lake is known to be only occasionally used by this species. There is no permanent population of northern pike in the lake because of poor overwintering conditions associated with large amounts of decaying aquatic vegetation and shallow depths. In contrast, deeper lakes similar in size or smaller than Kearl Lake support three to six sport fish species (see Table 35a-1). Table 35a-1 Fish Species Diversity in Relation to Depth for Northern Alberta Waterbodies Waterbody Surface Area (ha) Depth (m) Number of Fish Species Maximum Mean Sport Sucker Forage Total Kearl Lake McClelland Lake 2, Borque Lake Ethel Lake Musreau Lake Garner Lake ESRD/CEAA Page 198 October 2014

201 Frontier Oil Sands Mine Project ESRD and CEAA Responses Water McClelland Lake was also compared to other regional lakes as an example of a large, shallow waterbody in the oil sands region. Although almost 3,000 ha in size, McClelland Lake has an average depth of less than 2 m and supports a very limited fish community comprising only three forage fish species. This lake has poor connectivity to other fish-bearing habitats, which in combination with the shallow depths and resulting poor overwintering conditions, prevents the establishment of largebodied fish species. As described in the response to ESRD/CEAA Round 2 SIR 42: The constructed FHCL for the Project will include fish habitat features (e.g., deep-water overwintering habitats) that might not be present in many northern Alberta natural waterbodies of similar size, but which are important aspects of fish productivity. Deep-water habitats are suitable for a variety of sport fish and sucker life stage activities, not just overwintering. Although shallow habitats have high suitability for forage fish and some life stages of sport fish and sucker species, other life stages of large-bodied species prefer lake depths up to 10 m or more (Golder 2008). The conclusion that lakes with deep-water habitats can support a higher level of species diversity is further supported by current monitoring data for the CNRL Horizon compensation lake. As described in the response to ESRD/CEAA Round 3 SIR 20a, the Horizon compensation lake, with a mean depth of 7.2 m, has so far achieved its goal of providing habitat for nine fish species. Based on this information, there is low uncertainty associated with the prediction that the deeper habitats provided in the FHCL will support greater fish species diversity. This will be achieved by providing habitats for large-bodied sport fish and suckers, which are currently limited in the habitats affected by the Frontier Project. b. The fish community in the FHCL will experience the same types of inter- and intra-specific interactions, competition and predation that occur in the affected habitats. As described in response to ESRD/CEAA Round 3 SIR 20c: The final proposed fish community for the FHCL will be based on a fish community that can feasibly be achieved, based on consultation with regulators, potentially affected Aboriginal communities and stakeholders, and considering factors such as regional management objectives, fish communities present in regional waterbodies and a sustainable mix of the various trophic levels represented by sport fish, suckers and forage fish species. As described in response to part b [ESRD/CEAA Round 3 SIR 20b], several natural lakes in northern Alberta have a fish species assemblage or species complement similar to the candidate list for the FHCL; these fish communities would be influenced by similar biological interactions, including inter- and intraspecific interaction, competition, and predation. October 2014 ESRD/CEAA Page 199

202 ESRD and CEAA Responses Water Frontier Oil Sands Mine Project These inter- and intra-specific interactions were accounted for by applying the same methodology (i.e., habitat unit calculations) for all fish species present in the affected habitats and expected in the compensation habitats. This approach enabled Teck to account for the same level of habitat partitioning and species interaction in both the affected and compensation habitats. The development of lower trophic levels in the FHCL is necessary for establishing productive habitat. Adequate establishment of lower trophic levels requires suitable water quality, nutrients and physical regime (e.g., temperature). Phosphorus, for example, is often the limiting nutrient for biological productivity in lakes (Wetzel 2001). Detailed water quality modelling will be conducted to confirm the FHCL is suitable for establishing lower trophic levels. This will occur as part of detailed compensation planning, as described in response to ESRD/CEAA Round 3 SIR 23b. Water quality predictions will be compared to chronic and acute guidelines from CCME s Canadian Water Quality Guidelines for Protection of Aquatic Life (CCME 1999), as well as to baseline conditions in the FHCL local watershed. Nutrient availability will be assessed as part of the water quality model, and all modelling predictions will be verified through monitoring of the FHCL. Although bottom-up effects such as nutrient availability are important in establishing lower trophic levels, top-down effects can also regulate lower trophic levels in lakes (Hillebrand 2002). The final structure of the fish community is another important factor influencing the lower trophic levels of the FHCL. Teck plans to examine sustainable fish community assemblages for natural regional lakes and use this information to determine a suitable target fish community. Based on the information provided above, an update of the CFHCP and fish and fish habitat assessment is not warranted. However, pending the results of the Project Update, the CFHCP might require revision. REFERENCES CCME (Canadian Council of Ministers of the Environment) (with updates to 2011). Canadian Environmental Quality Guidelines. Winnipeg, Manitoba. Golder (Golder Associates Ltd.) Fish Species Habitat Suitability Index Models for the Alberta Oil Sands Region. Version 2.0. October Hillebrand, H Top-down versus bottom-up control of autotrophic biomass a meta-analysis on experiments with periphyton. Journal of the North American Benthological Society 21: Quigley, J.T. and D.J. Harper Effectiveness of Fish Habitat Compensation in Canada in Achieving No Net Loss. Environmental Management 37: Wetzel, R.G Limnology. Academic Press, New York. ESRD/CEAA Page 200 October 2014

203 Frontier Oil Sands Mine Project ESRD and CEAA Responses Water Question 36 SIR1, Volume 1, Section 10, SIRs 72 and 73, Pages SIR1, Volume 1, Section 5.5, SIR 111a, Pages to SIR 112, Pages to SIR1, Volume 1, Section 10, SIR 71 b, Page 148 SIR2, Volume 1, Aquatics, SIR 30 Fish populations in northeast Alberta are vulnerable to over-fishing. Fishing pressure is expected to increase near Fort McMurray at angling locations at Gregoire Lake, and on the Hangingstone, Horse, Clearwater, Christina and Athabasca Rivers as the Regional Municipality of Wood Buffalo expands. Teck concludes that because little angling was observed during baseline sampling, few species of commercial, recreational, or traditional interest were captured upstream of the Pierre River Mine Project, no access changes to Ronald Lake are anticipated, and Project personnel will be prohibited from angling, that the linkage between fishing pressure and fish abundance was not valid. This does not consider the population at least doubling in the RMWB within the life of the Project nor that the community will include not only the workers directly employed by oil sands activity, but also indirectly related such as contractors, support services and families associated with oil sands Projects. The Status of Arctic Grayling in Alberta (ASRD 2005, page 19) states, Because of high catchability, even under catch and release management and low angler pressure, the potential effects of incidental mortalities (caused by hooking and handling distress and illegal harvest) can be significant management concerns for accessible populations. Although it is ESRD s role to manage fisheries, the cumulative population increase as a result of expanded industrial activity in the area may overwhelm the utility of the tools available to manage finite fisheries resources. In order for ESRD to assess this and plan for it, adequate information on the potential impact is needed. a. Update the aquatic ecology assessment to consider the potential influence of cumulative human population increases on fishing pressure and the associated implications to regional recreational, domestic, and commercial fisheries. October 2014 ESRD/CEAA Page 201

204 ESRD and CEAA Responses Water Frontier Oil Sands Mine Project Response 36 a. To assess the potential influence of cumulative human population increases (i.e., resulting from expanding industrial activity) on regional recreational, domestic and commercial fishing pressure, Teck examined available data for the Regional Municipality of Wood Buffalo (RMWB). This included population trends over the past 10 to 15 years and the number of recreational and commercial fishing licences sold. RECREATIONAL FISHING Alberta Sustainable Resource Development s summary of sport fishing in Alberta (ASRD 2012) includes data on recreational angling from 2010 and from seven previous angler surveys (conducted between 1975 and 2005). Data was analyzed for Fish Management Zone NB4 (which closely corresponds to the RMWB) to identify the number of active licensed anglers and estimate the number of unlicensed youth and senior anglers. Table 36a-1 lists the number of recreational fishing licences sold from 2002 to 2011 in major communities in the RMWB and the estimated total number of active anglers. This total includes licensed anglers as well as unlicensed youth and seniors who actively engage in recreational fishing. The total number of active anglers was calculated based on licence sales (using the information provided in ASRD [2012]) and the typical proportion of active licensed versus unlicensed anglers. Table 36a-1 also provides available population data for the RMWB and for Fort McMurray. Trends in regional cumulative population growth, fishing licence sales and estimated number of active anglers show that: licence sales in recent years (2002 to 2011) are not correlated with increased regional population recreational fishing pressure has not increased proportionally with population growth The trends demonstrate that, despite population growth, changes in fishing licence sales have been variable and relatively small (see Figure 36a-1). Although steady population growth has occurred over this period for Fort McMurray (59% increase) and the RMWB (144% increase, including temporary workers), fishing licence sales have varied. Compared to licence sales in 2002, changes in sales for the period 2003 to 2011 have ranged from decreases of 18% to increases of 10%, with an overall average of 0.8%. The data shows that, although fishing licence sales declined from 2003 to 2007 (compared to 2002), they increased in the period from 2008 to ESRD/CEAA Page 202 October 2014

205 Frontier Oil Sands Mine Project ESRD and CEAA Responses Water Table 36a-1 Recreational Fishing Licences Sold in Major Communities in the RMWB and Population Size, 2002 to 2011 Location Number of Fishing Licences Sold Fort McMurray 6,231 5,124 5,909 5,749 6,174 5,956 6,186 6,400 6,758 6,612 Anzac Conklin Regional Total 6,356 5,227 6,002 5,908 6,322 6,094 6,540 6,781 7,013 6,850 Estimated Total Active Anglers 1 8,572 7,050 8,095 7,968 8,526 8,219 8,820 9,146 9,458 9,239 Population Fort McMurray 47,757 56,111 60,983 61,366 65,400 72,363 76,797 RMWB 58,834 67,105 73,176 75,717 88, , ,338 NOTES: 1 Includes the estimated number of active licensed anglers and active unlicensed youth and senior anglers. 2 The number of recreation fishing licences sold by issuers (includes non-residents). Numbers of sales are approximate as there may be some licence cancelations. = data not available. SOURCES: Fishing licence sales information from Wolfram (2012, pers. comm.). Fort McMurray population information from Statistics Canada (2014). RWMB 2010 Municipal Census October 2014 ESRD/CEAA Page 203

206 ESRD and CEAA Responses Water Frontier Oil Sands Mine Project 120, ,000 Number 80,000 60,000 40,000 20,000 NB4 Fishing Licence Sales NB4 Estimated Active Anglers RMWB Population Fort McMurray Population Year Figure 36a-1 Recreational Fishing and Population of Fort McMurray and the RMWB, 2001 to 2011 Overall, the trend lines in Figure 36a-1 show a slight increase in fishing license sales and estimated numbers of active anglers. However, it is clear that the increase in recreational fishing pressure has not been proportional to the increase in the regional population. This is consistent with the regional ASRD Fish and Wildlife Branch reporting that fishing interest in the region has remained fairly constant (Shell 2007) despite the increase in the regional population. Two factors likely contribute to the small change in recreational fishing pressure relative to the large change in the regional population: recent declining trends in the proportion of the general population that engages in fishing activities the demographics of population growth in the region and limited fishing activity conducted by the large temporary workforce included in the cumulative population increase As described in the response to ESRD/CEAA Round 1 SIR 119, predicting current angling pressure or future angling pressure based on population size is complicated by recent trends in angling activity. For example: Recreational fishing surveys show that, despite population increases, the number of anglers in Canada has consistently declined over the past two decades by 40% to 54% (ASRD 2012; ESRD/CEAA Page 204 October 2014

207 Frontier Oil Sands Mine Project ESRD and CEAA Responses Water Econometric Research Ltd. 2008). The decline in Alberta was not as large as the national average and has been on the increase in recent years. In addition to a general decline in the proportion of the population that fishes recreationally, survey data indicates that temporary oil sands workers include a lower-than-typical proportion of people who engage in angling. Survey data of mobile workers in the RMWB (i.e., temporary oil sands workers) from Nichols Applied Management (2007) indicate that only 4.4% engage in angling and they average less than one fishing excursion per year. This may be partly because oil sands operators typically restrict workers from fishing in local watercourses or waterbodies while on site to mitigate potential increases in fishing pressure. Teck plans to include this mitigation for the Frontier Project. Therefore, although future population growth is expected in the RMWB, current trends indicate that fishing pressure is likely to increase at a much slower rate. Further, the potential for future increases in fishing pressure assumes the proportion of the population in the RMWB that fishes remains similar to 2008 to 2011 levels and does not follow the declining national trend, or the declining trend recorded for the RWMB for the period 2003 to It is anticipated that with a continued slow increase in the number of recreational anglers in the region, ESRD will continue to be able to manage regional fisheries resources and support sustainable fish populations. Ongoing monitoring of fishing pressure and fish populations in the RMWB will assist ESRD in evaluating whether regulatory measures to control sport fish harvest (e.g., regulating harvest limits, fishing season and size limits) are needed to manage fish populations in the RMWB. DOMESTIC FISHING Limited data is available about the proportion of Aboriginal peoples in the RMWB that fish and their level of fishing activity. As such, potential changes in domestic fishing pressure were assessed based on estimated changes in regional populations of Aboriginal communities. The RMWB municipal development plan (RMWB 2011) estimates the average population growth of small, mostly Aboriginal communities to be 2.2%. This is within the range of annual growth rates (1.1% to 2.2%) estimated by Statistics Canada for the Aboriginal identity population. Although this data indicates potential for a small increase in domestic fishing activity, the expected rate of growth is mostly related to community-level demographic pressures such as birth rates, rather than population increases resulting from industrial development. Prior to 1970, most of the fishing catch was used as food for sled dogs (MCFN 2010). Available (albeit limited) information about Aboriginal fishing activity indicates that fishing activity has dropped significantly since 1970 because of increased use of snowmobiles. More recently, the number of Aboriginal persons who fish is reported to be declining in some communities (MCFN 2010). October 2014 ESRD/CEAA Page 205

208 ESRD and CEAA Responses Water Frontier Oil Sands Mine Project COMMERCIAL FISHING Within Alberta, the sale of new commercial fishing licenses has been frozen since 1987 (Bodden 2007, pers. comm.). Current licence holders can sell their commercial licences to other fisherman, but no new licences are being issued. This restriction, combined with a government buy-out program for existing licences, is intended to encourage a more viable sport fishing industry. In addition, ESRD sets annual, waterbody-specific commercial fishery quotas and seasons. Given these restrictions, no change in commercial fishing pressure is expected as a result of regional population growth, and ESRD appears to have the appropriate tools in place to manage this aspect of Alberta s fishery resources. REFERENCES ASRD (Alberta Sustainable Resource Development) Sport Fishing in Alberta Summary Report from the Eight Survey of Recreational Fishing in Canada. Government of Alberta, Fisheries Management Branch, Alberta Sustainable Resource Development. March Bodden, K. (Alberta Sustainable Resource Development) Phone and communication with Bethany Beale (Golder) on October 23, Econometric Research Ltd Sportfishing in Alberta in 2005: Performance, Value and Economic Impact Volume 1. Submitted to Hunting for Tomorrow Foundation. November MCFN (Mikisew Cree First Nation) As Long as the River Flows: Athabasca River Use, Knowledge and Change. MCFN Community Report. August Nichols Applied Management Mobile Workers in the Wood Buffalo Region, November, Edmonton, Alberta. RMWB (Regional Municipality of Wood Buffalo) Municipal Census RMWB and University of Alberta, Population Research Lab. RMWB Municipal Development Plan (MDP). October Shell (Shell Canada Limited) Jackpine Mine Expansion and Pierre River Mine Application. Environmental Impact Assessment and Socio-Economic Assessment. Volumes 1 to 5. Prepared by Golder Associates Ltd., Calgary, Alberta. Submitted December Statistics Canada Census Profiles. Statistics Canada, Government of Canada, Ottawa, Ontario. Available at: Accessed May 11, Wolfram, V. (Alberta Environment and Sustainable Resource Development) communication with J. O Brien (Golder) on November 16, ESRD/CEAA Page 206 October 2014

209 Frontier Oil Sands Mine Project ESRD and CEAA Responses Water Question 37 SIR1, Volume 1, Section 10, SIRs 72 and 73, Pages SIR1, Volume 1, Section 5.5, SIR 111a, Pages to SIR 112, Pages to SIR1, Volume 1, Section 10, SIR 71 b, Page 148 SIR2, Volume 1, Aquatics, SIR 30 The EIA report (Volume 5, Section , Page 4-19) indicates that substances associated with polymer use were not modelled. Use of polymers in tailings management is relatively new. Tailings facilities will underlie a large portion of the reclamation landscape. a. Discuss the use of polymers in tailings management over the proposed spatial and temporal scales, and describe what is understood with respect to their degradation and ultimate ecological effect. Provide peer-reviewed support for the discussion. b. Discuss the uncertainty/unknowns associated with the potential ecological outcomes associated with polymer use. c. Present a conceptual monitoring program that specifically describes how Teck will assess the potential risks associated with polymer use, whether in cooperation with other operators or on its own. Outline what factors Teck will measure through time to assess whether terrestrial or aquatic effects are occurring associated with polymer use in tailings management. Teck states that based on current knowledge on polymer application in other oil sands operations, the polymer and by products are expected to have negligible aquatic or terrestrial ecological implications. d. Describe the current state of knowledge on the potential implications of polymer use on aquatic and terrestrial ecology to support the conclusion that polymer use will have negligible effects. e. Discuss knowledge gaps and uncertainty associated with the use of polymers in tailings management and the potential aquatic and terrestrial ecological effects. Describe how current oil sands operations are monitoring polymer use and potential effects and identify whether the monitoring will provide sufficient information to assess ecological risk to aquatic and terrestrial ecology prior to Teck initiating operations. Response 37 As discussed in the response to AER Round 3 SIR 1, Teck intends to update the for the Project to: recover additional resource from leases acquired from Shell during the Teck Shell asset exchange optimize the tailings management strategy in consideration of the current state of engineering practice and improved understanding of site-specific conditions October 2014 ESRD/CEAA Page 207

210 ESRD and CEAA Responses Water Frontier Oil Sands Mine Project reflect additional engineering studies and information obtained from Shell as part of the asset exchange consider input from regulators and potentially affected Aboriginal communities during the review process Changes to the tailings management strategy, and the potential effects of these changes, will be described in the Project Update. Optimization of the tailings management strategy includes increased beach capture of fines and the use of centrifuges instead of thin lift drying. This change is expected to result in decreased use of polymers and improved water management through capture of centrate instead of thin lift runoff. The following discussion provides context regarding the use of polymer in the oil sands region. a. Although use of polymers in oil sands tailings management is relatively new, polymers have long been used as a soil conditioner in agriculture where they have been safely and effectively applied to reduce soil erosion (Seybold 1994). Polymers have also been safely and effectively used in drinking water and wastewater treatment for removal of suspended solids (GOC 2009). Polyacrylamides are highmolecular-weight, synthetic organic polymers that primarily interact with the clay fraction of soils. Barvenik (1994) noted that although polyacrylamide is water soluble, it adsorbs to solids through several mechanisms (e.g., electrostatic attraction or charge neutralization), and can bridge between adjacent particles due to its extremely large molecular dimensions. The result is large aggregates or flocs. Based on this, the fate of polyacrylamide is sorption to soil solids (hence its use as a soil-binding agent for erosion control). It is expected that interactions between polymers and clay fractions of oil sands tailings would be consistent with the way in which polymers interact with the clay fraction of soils (i.e., that the polymer will bind to tailings solids in dedicated disposal areas [DDAs]). The proposed spatial and temporal extent for the polymer use in tailings management is therefore expected to result in limited distribution of the polymer beyond the tailings solids in the DDAs. Degradation of polyacrylamide occurs mainly through physical breakdown (i.e., physical shearing) and photodegradation (Barvenik 1994; Woodrow et al. 2008). This process results in the release of polyacrylates of varying lengths and small amounts of acrylamide. The breakdown of the polyacrylamide backbone is energetically unfavourable and is considered unlikely to occur through biological activity alone (EU JRC 2002). Bacteria can extract the nitrogen bound within the polyacrylamide molecule in the presence of an external carbon source. However, degradation of the carbon backbone and subsequent production of acrylamide has not been observed (Kay-Shoemake et al. 1998). The rate at which polyacrylamide is broken down by ultraviolet radiation and other mechanisms has been estimated at approximately 10% per year (Barvenik 1994; Entry et al. 2002), which equates to a degradation rate of day -1. In comparison, the degradation rate of acrylamide in aerobic environments has been estimated as day -1 (U.S. EPA 2001, as cited in WBK 2001). Therefore, as noted in Volume 5, Section , Page 4-19, the accumulation of acrylamide is not expected to occur because the rate of acrylamide degradation is faster than its generation rate. There ESRD/CEAA Page 208 October 2014

211 Frontier Oil Sands Mine Project ESRD and CEAA Responses Water are no known or suspected properties related to site-specific water chemistry or soil moisture conditions that would change this conclusion. Polyacrylamide has been shown to have low toxicity to aquatic life (de Rosemond and Liber 2004; Beim and Beim 1994; Liber et al. 2005) and terrestrial mammals (as summarized in Andersen 2005). Given the long history of polymer use in agriculture (i.e., to stabilize soils) and water treatment (i.e., to remove suspended solids), potential ecological effects on terrestrial and aquatic vegetation are unlikely with polymer use in tailings management. Recent studies have shown that the aquatic toxicity of anionic polymers is derived mainly from the change in the physical characteristics of the water by the application of the polymer, rather than from direct physiological effects of the polymer on aquatic organisms (de Rosemond and Liber 2004; Weston et al. 2009; Acharya et al. 2010; Harford et al. 2011). For example, Acharya et al. (2010) and Harford et al. (2011) hypothesize that increased water viscosity by the addition of polymer may result in increased energy demands for locomotion and food filtering, thereby reducing the energy available for reproduction and growth. The sublethal effect concentrations observed in these studies ranged from 14 mg/l to more than 200 mg/l for various aquatic species. Andersen (2005) summarized toxicology data available for a number of terrestrial mammals, concluding that polyacrylamide is not significantly toxic:... an acute oral toxicity study of polyacrylamide in rats reported that a single maximum oral dose of 4.0 g/kg body weight was tolerated. In subchronic oral toxicity studies, rats and dogs treated with polyacrylamide at doses up to 464 mg/kg body weight showed no signs of toxicity. Several 2-year chronic oral toxicity studies in rats and dogs fed diets containing up to 5% polyacrylamide had no significant adverse effects. Polyacrylamide was not an ocular irritant in animal tests. No compound-related lesions were noted in a three-generation reproductive study in which rats were fed 500 or 2000 ppm polyacrylamide in their diet. Polyacrylamide was not carcinogenic in several chronic animal studies. Human cutaneous tolerance tests performed to evaluate the irritation of 5% (w/w) polyacrylamide indicated that the compound was well tolerated. b. The main uncertainty associated with potential ecological outcomes of polymer use in oil sands tailings environments is that it is a different application relative to those described in part a. As such, the expected behaviour and fate of the polymer relative to existing applications is not known with certainty. To address this uncertainty, Teck will monitor tailings facilities where polymer is being used, or proposed to be used in the future (see the response to parts c and e). c. To assess and manage potential risks associated with polymer use, Teck will monitor polyacrylamide and acrylamide concentrations at specific locations including, but not necessarily limited to: release water from locations where polymer treatment is applied porewater from in-pit DDAs where polymer treated tailings are stored in groundwater wells downgradient from such locations October 2014 ESRD/CEAA Page 209

212 ESRD and CEAA Responses Water Frontier Oil Sands Mine Project Release waters would likely be monitored most frequently (e.g., weekly to monthly initially and quarterly thereafter) to confirm that the polymer dosing rate is appropriate. Porewater and groundwater sampling frequency would be less frequent (e.g., quarterly or semi-annually). Should groundwater monitoring indicate polymer mobility or the presence of acrylamide monomer, operational mitigation and additional monitoring of seepage interception wells would likely be initiated. Note that these locations are all within the closed-circuited Project area; none of these waters will be released to the receiving environment. Details of the monitoring program will be informed by monitoring programs applied at other oil sands operations, which will evolve before first oil from the Project, and by future stages of Project engineering. See the response to part e for a description of monitoring being conducted by an existing oil sands operation. d. See the response to part a. e. Uncertainties related to use of polymers in tailings management are discussed in part b of this response. As an example of how current oil sands operations are monitoring polymer use, Suncor has developed a monitoring and research program as part of its EPEA approval conditions for the company s tailings reduction operations (TRO). One of the objectives of the monitoring program is to determine residual concentrations of monomer (acrylamide) and polymer (polyacrylamide) in different phases of the TRO products in its DDAs. Samples are collected from DDA runoff collection sumps, suction lysimeters within dried or drying tailings products, and from upgradient and downgradient groundwater wells. Analytical results presented in the Tailings Reduction Operations (TRO) Research and Monitoring Plan Annual Report 2013 (Suncor 2014) show that polymer concentrations: ranged from below the detection limit (<10 mg/l) to 76 mg/l in suction lysimeters ranged from below the detection limit (<10 mg/l) to 125 mg/l in runoff sumps were below the detection limit in groundwater monitoring wells Acrylamide was not detected at any of the monitoring locations, with detection limits ranging from mg/l to 0.05 mg/l. Although polymer was detected in some of the runoff sump and porewater (suction lysimeter) samples, these waters remain in closed-circuit operations. Furthermore, the polymer has not been detected in groundwater monitoring wells immediately adjacent to the DDAs, indicating limited mobility of polymer within the porewater of drying tailings products. Continued monitoring is expected to build a more robust dataset that will be conducive to stronger conclusions being developed (Suncor 2014). REFERENCES Acharya, K., C. Schulman and M.H. Young Physiological response of Daphnia magna to linear anionic polyacrylamide: ecological implications for receiving waters. Water Air and Soil Pollution 212: ESRD/CEAA Page 210 October 2014

213 Frontier Oil Sands Mine Project ESRD and CEAA Responses Water Andersen, F.A Amended final report on the safety assessment of polyacrylamide and acrylamide residues in cosmetics. International Journal of Toxicology 24 (Suppl. 2): Barvenik, F.W Polyacrylamide characteristics related to soil applications. Soil Science. 158: Beim, A.A. and A.W. Beim Comparative ecological-toxicological data on determination of maximum permissible concentrations (MPC) for several flocculants. Environmental Toxicology 18: de Rosemond, S.J.C. and K. Liber Wastewater treatment polymers identified as the toxic component of a diamond mine effluent. Environmental Toxicology and Chemistry 23: Entry, J.A., R.E. Sojka, M. Watwood and C. Ross Polyacrylamide preparations for protection of water quality threatened by agricultural runoff contaminants. Environmental Pollution 120: EU JRC (European Commission Joint Research Centre) European Union Risk Assessment Report: Acrylamide, Volume 24. EUR EN. Luxemburg. GOC (Government of Canada) Proposed Risk Management Approach for 2-Propenamide (Acrylamide). Environment Canada and Health Canada. August Harford, A.J., A.C. Hogan, D.R. Jones and R.A. van Dam Ecotoxicological assessment of a polyelectrolyte flocculant. Water Research 45: Kay-Shoemake, J.L., M.E. Watwood, R.D. Lentz and R.E. Sojka Polyacrylamide as an organic nitrogen source for soil microorganisms with potential impact on inorganic soil nitrogen in agricultural soil. Soil Biology and Biochemistry 30: Liber, K., L. Weber and C. Lévesque Sublethal toxicity of two wastewater treatment polymers to lake trout fry (Salvelinus namaycush). Chemosphere 61: Seybold, C.A Polyacrylamide review: Soil conditioning and environmental fate. Communications in Soil Science and Plant Analysis. 25: Suncor (Suncor Energy Inc) Tailings Reduction Operations (TRO) Research and Monitoring Plan Annual Report Submitted to Alberta Environment and Sustainable Resource Development. March U.S. EPA (United States Environmental Protection Agency) Integrated Risk Information System (IRIS) Online. Office of Research and Development, National Center for Environmental Assessment. Cincinnati, Ohio. Available at: Accessed August 2001, as cited in WBK 2001). October 2014 ESRD/CEAA Page 211

214 ESRD and CEAA Responses Water Frontier Oil Sands Mine Project WBK (WBK & Associates Inc.) Screening Evaluation and Risk Assessment of Acrylamide Impacts from Polymer-Amended Thickened Tailings Deposits. Report for Albian Sands Energy Inc. December Weston, D.P., R.D. Lentz, M.D. Cahn, R. Scott Ogle, A.K. Rothert and M.J. Lydy Toxicity of anionic polyacrylamide formulations when used for erosion control in agriculture. Journal of Environmental Quality 38: Woodrow, J.E., J.N. Seiber and G.C. Miller Acrylamide release resulting from sunlight irradiation of aqueous polyacrylamide/iron mixtures. Journal of Agriculture and Food Chemistry 56: Question 38 SIR1, Volume 1, Section 10, SIRs 72 and 73, Pages SIR1, Volume 1, Section 5.5, SIR 111a, Pages to SIR 112, Pages to SIR1, Volume 1, Section 10, SIR 71 b, Page 148 SIR2, Volume 1, Aquatics, SIR 30 Teck has been asked how diversions directed through the plant site will be isolated from processaffected materials. The reviewer is directed to the ERCB SIR2 24 response. The response indicates open-circuit and closed-circuit flows will be contained in different channels. This does not describe how seepage and run-off will be kept away from natural source diversions. a. Update the aquatic ecology assessment to describe how natural source diversions will be kept isolated from all process-affected materials including seepage and run-off. Response 38 a. The closed-circuit drainage system will be designed to contain process-affected waters (including seepage and runoff) in the closed-circuit areas for floods up to the 100-year return period. This design standard is commonly used in the oil sands region. Such measures will isolate natural release waters (i.e., from natural sources such as muskeg drainage, overburden dewatering, and diversions of head-watershed) from process-affected waters (i.e., seepage and runoff). The same flood protection and containment standards will be applied in designing the system that accommodates natural release waters. Natural release waters will be contained by having sufficient drainage channel capacity and additional containment berms where required. During extreme flood events (i.e., those with greater than 100-year return periods), potential exists for some overflow from the closed-circuit system to the natural water system. However, such overflow is expected to have a limited effect on receiving water quality because of the large dilution effect of ESRD/CEAA Page 212 October 2014

215 Frontier Oil Sands Mine Project ESRD and CEAA Responses Water flood volumes. As such, there is no change to the effects analysis provided in the alternate aquatic ecology assessment (see the response to ESRD/CEAA Round 2 SIR 308a, Appendix 308a.4, Section 308a.4.3). Question 39 SIR1, Volume 1, Section 10, SIRs 72 and 73, Pages SIR1, Volume 1, Section 5.5, SIR 111a, Pages to SIR 112, Pages to SIR1, Volume 1, Section 10, SIR 71 b, Page 148 SIR2, Volume 1, Aquatics, SIR 30 Teck indicates six road crossings will be required. Teck has identified either culverts or bridges will be used. a. Provide the criteria to be used to determine whether crossing structure will be a bridge or culvert. b. Describe how Teck will ensure these crossings will not contribute to aquatic fragmentation. c. Confirm Teck will monitor crossings at minimum annually and use the Roadway Watercourse Crossing Inspection Manual (September 2012). d. Provide the timeframe under which crossing deficiencies and issues will be remediated. Response 39 a. Teck will follow the criteria presented in the Alberta Water Act Code of Practice for Watercourse Crossings (Government of Alberta 2013) to determine whether a watercourse crossing structure can be a bridge or a culvert. The Alberta Codes of Practice regulate activities under the Water Act and set out standards and conditions that must be met to ensure that watercourse crossing activities minimize disturbance and impact on the environment. The Code of Practice for Watercourse Crossings classifies watercourses based on the sensitivity of fish habitats and known fish distributions (AENV 2001), and provides criteria regarding the preferred and alternate types of watercourse crossing structures that are suitable for use (based on the classification of the watercourse being crossed). To determine which type of crossing structure(s) will be used for the Project, Teck will: identify the specific watercourse crossing locations determine the classification of each of these watercourses under the Code of Practice for Watercourse Crossings apply the protocols specified in the Code of Practice for new watercourse crossings to determine: (i) the preferred type of crossing structure for each class of watercourse and (ii) the alternate October 2014 ESRD/CEAA Page 213

216 ESRD and CEAA Responses Water Frontier Oil Sands Mine Project type(s) of crossing structures considered suitable for use for the specific location (based on the conditions specified in the Code of Practice that determine whether an alternate structure is suitable for the specified application). For example, the preferred type of crossing for any watercourse is a clear-span bridge (Type 1 crossing), although other types of crossing structures such as multi-span bridges and open-bottom culverts (Type 2 crossing) or box culvert (Type 3 crossing) might also be suitable, providing that mitigation (e.g., isolation) is used and a qualified aquatic environment specialist (QAES) determines that the quantity and productive capacity of the aquatic environment, including fish habitat, at completion is equivalent or greater than that which existed prior to starting the works. Bridge crossings will be used where required by Code of Practice protocols, and at other locations Teck selects because of engineering requirements or other needs. Culvert crossings, if any, would be used at sites where they are considered appropriate based on the protocols in the Code of Practice. All crossings, regardless of type of structure, will be installed following the standards and conditions specified in the Code of Practice. b. Teck will follow the guidelines presented in the Code of Practice for Watercourse Crossings to protect upstream and downstream fish passage and avoid aquatic habitat fragmentation at each crossing location. Installation of watercourse crossings will include measures to avoid serious harm to fish (DFO 2013a, 2013b) and minimize the risk of adversely affecting fish and fish habitat. The Code of Practice specifies that the capacity of any bridge or culvert in a watercourse crossing must be sufficient to maintain fish migration through the crossing by ensuring that, at a minimum: water velocities through the crossing do not create a barrier to migrating fish for more than three consecutive days at a 1 in 10 year occurrence interval upstream and downstream fish migrations must not be impeded over the life span of the crossing The Code of Practice also defines other protocols to maintain fish passage at any crossing site. This includes, for example, maintaining or approximating the existing slope of the watercourse, and accommodating fish migration during crossing construction by maintaining flow at the crossing site or limiting isolation of the flow to a specified number of days (unless upstream and downstream migration is accommodated). Teck will conduct the appropriate site-specific hydrological assessments and water velocity assessments for each crossing site to ensure these protocols for fish passage will be met. In addition, Teck will complete regular inspections of each watercourse crossing to evaluate fish passage conditions (see the response to part c). For watercourse crossings that might involve culvert installation, Teck intends to submit a Request for Review to Fisheries and Oceans Canada (DFO 2013a). Teck intends to design watercourse crossings that are best suited to the individual site characteristics, and to construct each crossing in a manner that meets federal regulatory requirements such that a Fisheries Act authorization is not required. ESRD/CEAA Page 214 October 2014

217 Frontier Oil Sands Mine Project ESRD and CEAA Responses Water c. Teck will follow the guidelines presented in the Code of Practice with respect to monitoring completed watercourse crossings. For example, Teck will prepare a monitoring plan that outlines the parameters to be monitored and how monitoring will be conducted during the anticipated life of the watercourse crossing to ensure the crossing meets the requirements of the Code of Practice. The inspection frequency and process will, at a minimum, include an annual inspection and will follow the inspection methodology provided in the Roadway Watercourse Crossing Inspection Manual (Government of Alberta 2012). Inspections will assess erosion and sedimentation, culvert status (if relevant), outlet gap and pool depth, and fish passage. Teck might conduct inspections more frequently, and might use additional inspection protocols, where appropriate, given site conditions or sensitivities. d. Watercourse crossing inspections (described in the response to part c) will be used to identify deficiencies and issues such as erosion, sedimentation, culvert condition and blockages, and conditions limiting fish passage. Deficiencies and issues identified during inspections will be addressed and corrected as soon as possible, in consideration of the following: the type of corrective action needed and its complexity site-specific conditions such as flow volume and rainfall, as applicable to being able to safely and effectively complete the corrective actions availability of materials needed to complete the corrective actions regulatory consultation and permitting, as required At a minimum, corrective actions will be taken within six months of the inspection that identified the deficiency or issue. REFERENCES AENV (Alberta Environment) Guide to the Code of Practice for Watercourse Crossings, Including Guidelines for Complying with the Code of Practice. Revised April DFO (Fisheries and Oceans Canada). 2013a. Projects near Water Self-Assessment. Available at: Accessed February 10, DFO. 2013b. Measures to Avoid Causing Harm to Fish and Fish Habitat. Available at: Accessed February 10, Government of Alberta Roadway Watercourse Crossing Inspection Manual. ESRD/Roadway Watercourse Crossing Inspection Protocol (May 10, 2012 Version). September Government of Alberta Code of Practice for Watercourse Crossings. Made under the Water Act and Water (Ministerial) Regulation. Office Consolidation Consolidated to Include Amendments in Force as of June 24, Alberta Queen s Printer. October 2014 ESRD/CEAA Page 215

218 ESRD and CEAA Responses Water Frontier Oil Sands Mine Project Question 40 SIR1, Volume 1, Section 10, SIRs 72 and 73, Pages SIR1, Volume 1, Section 5.5, SIR 111a, Pages to SIR 112, Pages to SIR1, Volume 1, Section 10, SIR 71 b, Page 148 SIR2, Volume 1, Aquatics, SIR 30 a. List measureable targets, goals and objectives for aquatic systems on the reclamation landscape that Teck will steward toward. Teck identifies in several places in the fish and fish habitat assessment that the closure landscape is expected to develop into viable fish habitat. b. In the aquatic ecology assessment, present a map, colour-coded by species or species group, which identifies where Teck anticipates fish habitat will develop. c. Discuss the uncertainty associated with the closure landscape functioning as fish and aquatic habitat to better describe the potential Project outcomes. Response 40 a. Aquatic systems on the reclamation landscape will consist of the FHCL, the pit lakes and the small lakes, shallow wetlands and watercourse channels that comprise the remainder of the closure drainage system. As described in the response to ESRD/CEAA Round 1 SIR 96a: The FHCL is designed to provide productive fish habitat to offset potential losses in fish habitat that are predicted as a result the Project. The FHCL has been designed to replace the productive capacity of the affected habitats with new habitats of equivalent or higher productive capacity, based on the preliminary assessment of Habitat Units in the affected habitats and in the FHCL. Following closure, viable aquatic ecosystems, including additional productive fish habitats, are expected to develop naturally in the permanent lakes, wetlands and watercourse channels that will comprise the closure drainage system. The FHCL is currently in the conceptual design phase. The final design of the FHCL will be completed as part of the detailed compensation planning phase, in consultation with regulators and stakeholders. The detailed compensation planning phase will include development of the measurable targets, goals and objectives of the FHCL, and development of a detailed monitoring plan to assess the effectiveness of the FHCL in meeting the overall objective of compensating fish habitat losses associated with the Frontier Project. A key component of the regulatory consultation process will be continued discussions with DFO and potentially affected Aboriginal communities regarding measurable targets, goals and objectives for the FHCL. These targets, goals and objectives would then ESRD/CEAA Page 216 October 2014

219 Frontier Oil Sands Mine Project ESRD and CEAA Responses Water be expected to form part of the conditions of the anticipated Fisheries Act authorization for the Project. Objectives previously specified by DFO as authorization conditions for similar regional compensation works have included: verification and validation of HSI models and habitat unit calculations achieving self-sustaining fish populations achieving self-sustaining fish habitat (e.g., littoral and pelagic, water and sediment quality, water flow and level, aquatic vegetation) achieving specific community and productivity objectives (e.g., fish diversity, density, productivity) Although details of the measurable targets, goals and objectives and associated monitoring plans for the FHCL are not yet available, monitoring plans for other constructed habitat compensation lakes in the oil sands region include the following items, which might also be applied to the FHCL for the Project: water level monitoring to assess hydrologic sustainability water quality and sediment quality monitoring relative to guidelines for aquatic life and to baseline conditions for the local watersheds physical features of the waterbody such as surface area, bathymetry, proportions of littoral and pelagic zones water temperature regime lower-level productivity, including composition, density and biomass of phytoplankton and zooplankton composition, distribution, density and vigour of aquatic vegetation composition and density of benthic invertebrate communities fish productivity, including species composition, relative abundance, population size, density and biomass density validation of the HSI models used to predict the productivity gains for the FHCL The overall performance measure of the FHCL is expected to be its effectiveness in compensating effects on fish productivity. Success of the FHCL would be defined as achieving the overall compensation goal of the Project, which is to provide productive fish habitats equivalent or greater than baseline conditions. For the remaining aquatic systems on the reclamation landscape, the objective is to establish viable, self-sustaining aquatic ecosystems that will be able to support fish populations and lower trophic levels. These expectations are based on predictions that the constructed systems will have suitable water quality and sediment quality to support aquatic life, either because they will convey water from upstream, unaffected areas or will provide suitable bioremediation of reclamation water. The responses to ESRD/CEAA Round 1 SIR 97d and SIR 99b describe pit lake design features that are October 2014 ESRD/CEAA Page 217

220 ESRD and CEAA Responses Water Frontier Oil Sands Mine Project expected to support the development of viable aquatic ecosystems in the pit lakes, and provide the natural and biological components expected to develop in the pit lakes. The response to ESRD/CEAA Round 1 SIR 97c identifies aspects of the geomorphic design of the closure drainage system that are expected to provide for the development of viable, self-sustaining aquatic ecosystems. Although the pit lakes, small lakes, shallow wetlands and watercourse channels of the closure drainage system are expected to develop viable aquatic ecosystems, there are no specific targets for production, or species assemblages defined for fish or other trophic levels for these systems. As stated in the response to ESRD/CEAA Round 1 SIR 101: Unlike the FHCL, the components of the closure drainage system are not designed with the goal of providing a specific level of habitat productivity or fish production, but are designed to provide viable [, self-sustaining] aquatic ecosystems that will be able to support local natural aquatic species and communities. Success will be determined by monitoring the development of the closure system for stability, sustainability and the physical features they are designed to provide. Water quality, sediment quality and the physical features of the closure drainage system will be monitored and the results will be used to measure success relative to the goal of providing lentic and lotic aquatic habitats capable of supporting local aquatic life. Measurable targets will be developed as part of the detailed monitoring plan once the final design of the drainage features is completed. Teck will strive to create viable, self-sustaining aquatic ecosystems and monitor these systems to confirm that the end pit lakes are providing sufficient bioremediation. As stated in the response to ESRD/CEAA Round 1 SIR 97d: A monitoring plan... will be used to evaluate the success of the pit lakes as providing suitable bioremediation. An adaptive management plan will be developed to employ available mitigation and active treatment options should monitoring indicate that natural bioremediation is less successful than expected. Monitoring the development of physical characteristics of the early components of the closure drainage system will help inform and adjust the design of subsequent features, where appropriate. Because closure of the Frontier Project will occur later in the overall development schedule for the oil sands region, Teck will be in a position to learn from the closure activities and monitoring results for other oil sands mines that are currently approved or operating. Teck s ability in this regard will be enhanced by it being a member of Canada s Oil Sands Innovation Alliance (COSIA) and the FiSH Committee. Teck will use all relevant information in its adaptive management plan for the Project to improve the design, operation and monitoring of the closure landscape. Teck is committed to developing and implementing adaptive management frameworks for its operations. This commitment by Teck is demonstrated for another of its projects by the key management plans for the Line Creek Operations Phase II Project (Teck 2013) that outline a Cumulative Effects Management Framework (CEMF) that is applicable to all of Teck Coal s ESRD/CEAA Page 218 October 2014

221 Frontier Oil Sands Mine Project ESRD and CEAA Responses Water operations in the Elk River Valley, British Columbia. The goal of the CEMF is to produce a practical, workable framework that supports decision-making and cumulative effects management in the Elk Valley using a collaborative, consensus-based process. The components for which the CEMF will be implemented are terrestrial environment, water quality and aquatic health, and fish habitat. Although the CEMF focuses on the contributions of Teck s operations to cumulative effects, it also considers the cumulative effects of previous, existing and future developments from different land users that interact with the effects of Teck s operations. Teck is committed to the development of a formal adaptive management plan for the Project prior to its construction, for use during its operation and closure. Teck will draw on its experience with mining and reclamation activities elsewhere and integrate this approach with frameworks that are under development in the oil sands region. In addition, Teck intends to participate in regional collaborative initiatives and studies on reclamation and closure planning, data collection and continual improvement of design and construction methodologies. Teck is committed to achieving the reclamation and closure goals as defined in the conceptual closure drainage plan. b. Fish habitats and populations will be developed in the FHCL for a fish community consisting of sport, sucker and forage fish species. However, as described in response to ESRD/CEAA Round 3 SIR 20a, the target species assemblage has not yet been determined and will be finalized as part of detailed compensation planning, in consultation with regulators, potentially affected Aboriginal communities and stakeholders. Although habitats will be developed in the FHCL for each of these species groups, the specific fish species to be included will be determined as planning progresses. At the current stage of planning, Teck is unable to provide a map of the remaining closure drainage features showing where fish habitat is expected to develop. Some features (e.g., closure drainage channels) are currently at the conceptual stage and many will likely be redesigned as part of the Project Update (for details, see the response to AER Round 3 SIR 1). More detailed planning and design needs to be completed to enable specific identification of these drainage features. However, Teck expects that the pit lakes and the small lakes, shallow wetlands and watercourse channels that comprise the remainder of the closure drainage system will support the establishment of viable aquatic ecosystems and will be able to support fish populations with appropriate design. Natural colonization pathways exist for fish to move into the closure drainage system and establish populations. This will occur via the lower portions of Redclay Creek and Big Creek, which will receive flows from the closure landscape, connecting it to the Athabasca River. Although Unnamed Creeks 17 and 18 will also drain a small portion of the closure landscape, these watercourses do not currently support fish populations in the Project area given their lack of connectivity to downstream fish-bearing habitats. These characteristics will not change at closure. Colonization routes will also be available to the sport, sucker and forage fish species in Redclay Creek and Big Creek downstream of the Project area. Fish will be able to access the permanent October 2014 ESRD/CEAA Page 219

222 ESRD and CEAA Responses Water Frontier Oil Sands Mine Project diversion channels that connect the closure landscape to these two natural watercourses and use them to access the various pit lakes, small lakes, wetlands and remaining diversions channels of the closure drainage system. It is not known which species will colonize the drainage system, but the fish communities most likely to develop are expected to be similar to those present in the affected watercourses since closure channels will have similar physical characteristics and expected flow volumes and gradients will be somewhat similar to existing watercourses. Given these colonization routes, forage fish species may become the most widely distributed and abundant fish in the drainage system, along with smaller populations of longnose and white sucker. Sport fish distribution does not currently include the natural watercourses and waterbodies in the Project area. This distribution is not likely to increase at closure for the Big Creek drainage, so sport fish might not colonize parts of the closure drainage system connected to Big Creek, or the time required may be longer than for other drainages (e.g., Redclay Creek). The presence of the FHCL in the Redclay Creek drainage will provide for the development of sport fish populations higher in the Redclay Creek drainage than currently exists, and will allow colonization by sport fish to the portion of the drainage system connected to Redclay Creek, which will be via the FHCL. As described in response to ESRD/CEAA Round 1 SIR 97d: At present, the development of a fish community management plan is focused on the FHCL. In the far future, when the pit lakes are filled with water, and monitoring indicates that aquatic habitat conditions are suitable for use by fish, the adaptive management plan might be revised to include the management of fish communities in the pit lakes (rather than natural development), as determined by the management objectives of the time, regional management initiatives and consultation with regulators, potentially affected Aboriginal communities and stakeholders. As such, stocking of sport fish and other species into the pit lakes, and thereby into the closure drainage system, may be considered in the future. c. Uncertainty that the closure drainage system will function as fish and aquatic habitat is low. This low uncertainty rating is because of confidence in predictions related to water quality, sediment quality and aquatic health, and the fact that fish habitat design considerations were included in the closure drainage features. The expectation that aquatic resources in the closure landscape will support the development of viable aquatic ecosystems is based on the prediction that the constructed systems will have suitable water quality and sediment quality to support aquatic life, either because they will convey water from upstream unaffected areas or because they will provide suitable bioremediation of reclamation water. The water quality and aquatic health assessments both indicate high confidence in the prediction that water and sediment quality in the pit lakes and closure drainage system will be able to support aquatic life. Confidence is also high that habitat features of the closure drainage system will provide for the development of aquatic ecosystems. The responses to ESRD/CEAA Round 1 SIR 97d and SIR 99b describe pit lake design features that are expected to support the development of viable ESRD/CEAA Page 220 October 2014

223 Frontier Oil Sands Mine Project ESRD and CEAA Responses Water aquatic ecosystems in the pit lakes, and provide the natural and biological components expected to develop in the pit lakes. Similarly, the response to ESRD/CEAA Round 1 SIR 97c identifies aspects of the geomorphic design of the closure drainage system that are expected to support the development of viable aquatic ecosystems. Regional studies provide a high level of confidence that aquatic ecosystems and fish habitat can be successfully developed in watercourses of the closure drainage system. For example, studies conducted on the Syncrude West Interceptor Ditch (WID) showed the development of various components of the aquatic ecosystem, including fish habitat. These studies focused on documenting the natural colonization of the ditch, which was constructed to divert a section of Beaver River, a tributary of the Athabasca River. Studies conducted in the years following WID construction (e.g., Tsui et al. 1977; Syncrude 1985) measured the development of zooplankton, phytoplankton, macroinvertebrates and fish populations. Results showed that in the first year following construction, all of these biological components were present, although the density and diversity of biological organisms was low (Tsui et al. 1977). Later, the development of lower-trophic levels (e.g., macroinvertebrates) achieved typical levels for the region, including density, biomass and diversity. Fish use was documented to include longnose sucker, white sucker and three forage fish species. Among other life stages, use by these species included use of the ditch for spawning in local gravels areas installed for streambed protection. The WID was designed as an operational flow conveyance channel with no sinuosity and no inclusion of fish habitat features. In contrast, because the closure drainage system for the Frontier Project was designed to include natural geomorphic features, there is a high degree of confidence that aquatic ecosystems can be developed beyond that observed in the WID. For example, fish use in the WID was suspected to be seasonal because of poor overwintering conditions and a lack of habitat diversity (i.e., complete lack of pool habitats). The geomorphic design of the Project closure system will provide a much higher level of habitat diversity (e.g., potential overwintering habitats and other habitats required by local natural aquatic species and communities). Outside the WID, other constructed habitats in the oil sands region have been successfully colonized by aquatic biota (Leonhardt 2003; Whelly 1999). Although there is a low level of uncertainty regarding the development of fish and aquatic habitats in the closure drainage system, uncertainty remains about the level of productivity that will develop. This uncertainty does not apply to the FHCL, where there is a requirement to provide productive fish habitat to compensate potential losses and to replace the productive capacity of affected habitats with new habitats of equivalent or higher productive capacity. Additional productivity in the closure drainage system is not needed to meet the compensation objective, but will be important in providing functional aquatic habitats in the watercourses and waterbodies on the closure landscape. October 2014 ESRD/CEAA Page 221

224 ESRD and CEAA Responses Water Frontier Oil Sands Mine Project REFERENCES Leonhardt, C.L Zoobenthic Succession of Constructed Wetlands in the Fort McMurray Oil Sands Region. Developing a Measure of Zoobenthic Recovery. M.Sc. Thesis, University of Windsor. Windsor, Ontario. Syncrude (Syncrude Canada Ltd.) A Study of Aquatic Environments in the Syncrude Development Area, Prepared by R.L.&L. Environmental Services Ltd. and A.A. Aquatic Research Ltd. Environmental Research Monograph Teck (Teck Coal Limited) Key Management Plans for the Line Creek Operations Phase II Project. Submitted to the British Columbia Environmental Assessment Office. Teck Coal Limited Line Creek Operations. February Tsui, P, D. Tripp and W. Grant A Study of Biological Colonization of the West Interceptor Ditch and Lower Beaver Creek. Prepared by Aquatic Environments Ltd. Whelly, M.P Aquatic Invertebrates in Wetlands of the Oil Sands Region of Northeast Alberta, Canada, with Emphasis on Chironomidae (Diptera). M.Sc. Thesis, University of Windsor, Windsor, Ontario. Question 41 SIR1, Volume 1, Section 10, SIRs 72 and 73, Pages SIR1, Volume 1, Section 5.5, SIR 111a, Pages to SIR 112, Pages to SIR1, Volume 1, Section 10, SIR 71 b, Page 148 SIR2, Volume 1, Aquatics, SIR 30 All aquatic ecology monitoring sections refer to the monitoring plan outlined in the fish compensation plan. The scope of the list of items to be monitored suggests that the monitoring will be limited to the constructed compensation habitat. a. Describe how Teck will confirm impact assessment conclusions, support adaptive management approaches, and address knowledge gaps and uncertain ecological connections. Response 41 a. The conceptual monitoring plan provided in response to ESRD/CEAA Round 3 SIR 24a-i describes Project-specific monitoring in various habitats in the Project area. These habitats include the constructed compensation habitat in the FHCL, but also the affected habitats and the closure drainage system. The plan specifically identifies: ESRD/CEAA Page 222 October 2014

225 Frontier Oil Sands Mine Project ESRD and CEAA Responses Water habitats in which fish habitat productivity is expected to be affected by the Project (by one or more of the effects pathways described in response to ESRD/CEAA Round 3 SIR 42b, Table 42b-1) habitats where predictions of negligible effects on fish habitat productivity were associated with uncertainty or knowledge gaps The conceptual monitoring plan describes how Teck will confirm assessment predictions, address key uncertainties and knowledge gaps, and demonstrate the effectiveness of the FHCL in compensating for the expected losses in fish habitat and habitat productivity. As described in ESRD/CEAA Round 3 SIR 24a-i, the conceptual monitoring plan will progress from its current conceptual state to a final monitoring plan based on consultation with DFO and potentially affected Aboriginal communities. Monitoring conditions and requirements will be specified in the anticipated Fisheries Act authorization for the Project. The monitoring plan will support an adaptive management approach by providing the information Teck needs to implement an adaptive management program for the Project. The program would focus on eliminating or minimizing potential effects on fish and fish habitat. Monitoring will provide data that would assist in determining: Project effects on fish habitat productivity, both predicted and unexpected the level of fish habitat productivity provided by the FHCL the effectiveness of the compensation measures (including whether additional measures are needed) In addition, the monitoring program will provide information about the development of the FHCL and the closure drainage system that will enable Teck to achieve management objectives. This might include, for example, the need to enhance or support the development of the FHCL (e.g., vegetation planting, benthic invertebrate seeding, fish stocking) or closure drainage system (e.g., pit lake development). Question 42 SIR1, Volume 1, Section 10, SIRs 72 and 73, Pages SIR1, Volume 1, Section 5.5, SIR 111a, Pages to SIR 112, Pages to SIR1, Volume 1, Section 10, SIR 71 b, Page 148 SIR2, Volume 1, Aquatics, SIR 30 In its entirety, Teck s conclusion for aquatic ecological effects is Consistent with the original assessment, the construction of the FHCL and mitigation applied during the Project life, a negligible environmental consequence is expected. October 2014 ESRD/CEAA Page 223

226 ESRD and CEAA Responses Water Frontier Oil Sands Mine Project a. Given the number of places where it is difficult to discern the aquatic ecological support for conclusions or statements, or where there are gaps in how the foundational water quality and quantity conclusions were placed in an aquatic ecological context and carried forward to the fish and fish habitat assessment, develop and present a diagram that highlights each ecological pathway considered in the aquatic environmental effects assessment for the Frontier Project. b. Provide a table that lists and describes the assessment conclusions associated with each pathway, identifies whether proposed mitigation is sufficient to eliminate potential effects or whether effects are partially mitigated, describes uncertainties or gaps in understanding, and points to peer-reviewed supporting information or data to support the conclusions. c. In the aquatic ecology assessment, identify how effects may interact with each other and provide an overall conclusion associated with the potential effects of the proposed Frontier Project on aquatic systems in the local and regional context. Describe how this conclusion is or is not consistent with the predictions in regional land use planning models and the TEMF. If it is not consistent, discuss why. Summarize major areas of uncertainty and knowledge gaps that may influence the overall assessment conclusion. Response 42 a. A diagram presenting the effects pathways that were included in the fish and fish habitat assessment is provided in Figure 42a-1. b. Table 42b-1 provides a summary of the fish and fish habitat assessment and relevant information provided in response to SIRs, including pathways, conclusions, mitigation, uncertainty, knowledge gaps and location of supporting information. ESRD/CEAA Page 224 October 2014

227 FRONTIER PROJECT AQUATIC ECOLOGY LINKAGE DIAGRAM PROJECT DESIGN NOT TO SCALE REV. 0 WP CHECK REVIEW FIGURE 42a-1

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229 Frontier Oil Sands Mine Project ESRD and CEAA Responses Water Table 42b-1 Fish and Fish Habitat Assessment Conclusions Pathway or Linkage Validity Conclusions and Mitigation Knowledge Gaps Supporting Information Change in flow and water level Valid linkage exists because of planned watercourse diversions, changes to watershed areas and water withdrawal. The potential for effects on fish habitat in the Athabasca River because of water withdrawal is negligible based on mitigation that will include compliance with the Water Management Framework and associated withdrawal restrictions. Changes in streamflow will result in potential flow-related effects on habitat productivity in Big Creek and Redclay Creek downstream of the Project area. The predicted effect of reduced habitat area associated with reduced flows was mitigated through the provision of compensation habitats in the FHCL. Consequently, the habitat change was classified as a low magnitude effect. The productivity of the affected habitat area was estimated by calculating affected habitat units (HUs) for the fish species present and compensating with more than an equivalent number of HUs in the FHCL. There is a high level of confidence in the mitigation associated with the Athabasca River Water Management Framework and the protection of aquatic habitat. There is a high level of confidence that the FHCL will provide habitat productivity that is at least equivalent to the affected habitats. The quantified measure of HUs is based on the amount of habitat and habitat suitability, which describe the ability of key habitat components to supply the life requisites of each fish species. The habitat suitability index (HSI) models for the oil sands were developed based on published models and the opinions of subject matter experts. In addition, the FHCL was designed to provide more HUs than the affected habitats. There is uncertainty associated with the prediction of fish habitat productivity levels in the FHCL because the fish HSI models used in the assessment have not been fully validated for the oil sands region. Model validation studies are underway, but have not been completed. Uncertainty is reduced by: employing the HSI models to quantify productivity levels in affected and compensation habitats including conservative assumptions when applying the models See the revised fish and fish habitat assessment provided in response to ESRD/CEAA Round 2 SIR 30a, Appendix 30a.1. See the response to ESRD/CEAA Round 3 SIR 18 for a discussion of the HU calculation process, regional HSI models and, along with the response to ESRD/CEAA Round 3 SIR 21a, discussions of similar regional compensation lakes. See the responses to ESRD/CEAA Round 3 SIR 20 and SIR 35 for information about the expected success in establishing the FHCL fish community and suitable habitat productivity. See the response to ESRD/CEAA Round 3 SIR 24 for the conceptual monitoring plan for the Project. providing a more-than-equivalent level of HUs in the compensation habitats The knowledge gap around the FHCL providing sufficient compensation is that success has not been demonstrated for similar regional compensation lakes. These lakes have only been operating for a short time. Monitoring results are preliminary, but encouraging in relation to development of a diverse fish community. The conceptual monitoring plan includes components designed to determine the effectiveness of the FHCL. October 2014 ESRD/CEAA Page 227

230 ESRD and CEAA Responses Water Frontier Oil Sands Mine Project Table 42b-1 Fish and Fish Habitat Assessment Conclusions (cont d) Pathway or Linkage Validity Conclusions and Mitigation Knowledge Gaps Supporting Information Change in channel regime or morphology Change in suspended sediment level or sedimentation because of a change in sediment loading Invalid linkage because there are no predicted increases in peak flows that could result in channel erosion or destabilization. Valid linkage for Unnamed Lake 1 because of predicted increases in suspended sediment levels. Invalid linkage for other watercourses and waterbodies because mitigation is expected to maintain downstream suspended sediment levels and sedimentation similar to baseline conditions. Predicted reductions in peak flows at closure in lower Big Creek and lower Redclay Creek were evaluated in response to ESRD/CEAA Round 3 SIR 16. Predicted reductions in peak flows, in combination with trapping suspended sediments in pit lakes, is expected to have a negligible effect on sediment deposition and in-channel aggradation. The predicted negligible changes in sediment loading will have no effect on fish and fish habitat. The increase in suspended sediment in Unnamed Lake 1 was considered to have altered the productivity of the lake to the extent that all habitats in the lake were lost. Therefore, compensation habitat was included in the Project design to permanently compensate potential losses in habitat productivity. The CFHCP includes the development of a FHCL to provide new habitat, based on habitat evaluation procedures (HEP) employed as standard practice for large compensation works in the oil sands region. Based on this mitigation, the habitat change was classified as a low magnitude effect. There is uncertainty associated with the prediction because of a knowledge gap around the determination of stream-specific effective flows that influence geomorphic processes in the two watercourses. There is also uncertainty regarding the interaction of reduced sediment load and reduced peak flows in channel regime effects. Monitoring of flow regimes and in-channel habitats in lower Big and Redclay creeks are included in the conceptual monitoring plan for the Project. The level of confidence in the prediction that the FHCL will provide sufficient compensation for the productivity of Unnamed Lake 1 is high. The quantified measure of HUs is based on the amount of habitat and habitat suitability, which describe the ability of key habitat components to supply the life requisites of each fish species. The HSI models for the oil sands were developed based on published models and the opinions of subject matter experts. There is uncertainty associated with the prediction of fish habitat productivity levels in the FHCL because the fish HSI models used in the assessment have not been fully validated for the oil sands region. Model validation studies are underway, but they have not been completed. Uncertainty is reduced by employing the HSI models to quantify productivity levels in affected and compensation habitats, by the conservative assumptions used when applying the models, and in providing a more than equivalent level of HUs in the compensation habitats. The knowledge gap around the FHCL providing sufficient compensation is that success has not been demonstrated for similar regional compensation lakes. These lakes have only been operating for a short time. Monitoring results are preliminary, but encouraging in relation to development of a diverse fish community. The conceptual monitoring plan includes components designed to determine the effectiveness of the FHCL. See the response to ESRD/CEAA Round 3 SIR 16 for a discussion of the potential effects of reduced peak flows on channel regime. See the response to ESRD/CEAA Round 3 SIR 24 provides the conceptual monitoring plan for the Project. See the fish and fish habitat assessment (Volume 5, Section , Pages 5-29 to 5-34). See the revised CFHCP provided in response to ESRD/CEAA Round 2 SIR 30j, Appendix 30j.1. See the response to ESRD/CEAA Round 3 SIR 18 for a discussion of the HU calculation process, regional HSI models and, along with the response to ESRD/CEAA Round 3 SIR 21a, discussions of similar regional compensation lakes. See the responses to ESRD/CEAA Round 3 SIR 20 and SIR 35 for information about the expected success in establishing the FHCL fish community and suitable habitat productivity. See the response to ESRD/CEAA Round 3 SIR 24 for the conceptual monitoring plan for the Project. ESRD/CEAA Page 228 October 2014

231 Frontier Oil Sands Mine Project ESRD and CEAA Responses Water Table 42b-1 Fish and Fish Habitat Assessment Conclusions (cont d) Pathway or Linkage Validity Conclusions and Mitigation Knowledge Gaps Supporting Information Change in dissolved oxygen level Change in thermal regime Change in aquatic health because of a change in water sediment chemistry or thermal regime Invalid linkage because DO levels are predicted to be the same or greater than existing conditions given planned mitigation (e.g., properly designing polishing ponds) and the mitigation success achieved by operating oil sands mines. Valid linkage because of the predicted shift in the temperature regime of Big Creek following closure (i.e., due to effects of the pit lake on downstream water temperatures). Invalid linkage because potential changes to aquatic health from changes in water and sediment chemistry were predicted to be negligible to low. As well, changes in the thermal regime of Big Creek were predicted to have negligible effects on aquatic health. No effects predicted for fish and fish habitat because of a lack of changes in DO levels. A temperature shift is predicted for lower Big Creek downstream of the pit lake at closure. This will delay spring warming and fall cooling by one month each. The shift is expected to delay spawning for spring suckers and outmigration for burbot in the fall. The shift is not expected to affect the overall productivity of the watercourse based on a corresponding shift in benthic invertebrate abundance and limited potential for effects on primary production since light intensity will not be affected. The aquatic health assessment concluded that the potential for the Project to affect aquatic health because of changes in water and sediment chemistry was negligible to low with low risk to fish health. Predicted thermal changes in Big Creek reflect a shifting time scale and not a change in temperatures beyond the normal range, and are expected to have negligible effects on aquatic health. The assessment of changes in dissolved oxygen was provided by the water quality assessment. Prediction confidence is high for changes in DO levels and the success of available mitigation. There are no knowledge gaps associated with this prediction. The level of confidence in this prediction is low because of the uncertainty in predicting ecological interactions and because of knowledge gaps around watercourse use and spawning suckers. Monitoring benthic invertebrate communities, fish use and fish abundance in lower Big Creek is included in the conceptual monitoring plan for the Project. The assessment of changes in aquatic health was provided by the water quality assessment. The prediction confidence for the aquatic health assessment was rated as high because of conservative modelling and the multiple lines of evidence examined, and the underlying predictions for water and sediment chemistry. The prediction confidence was rated as high for the changes in water and sediment chemistry because modelling methods and conservatism would not underestimate substance concentrations. The level of confidence in the thermal regime predictions is moderate; although the level of confidence in the robustness of the model is high, the model is based on Muskeg River temperature data because there is a lack of data for the aquatics LSA. As a result, monitoring water temperatures in lower Big Creek is included in the conceptual monitoring plan. See the water quality assessment for DO (Volume 5, Section 4.7, Pages to 4-108). See the response to ESRD/CEAA Round 3 SIR 13 for a discussion of potential effects of changes in thermal regime and the potential effects on Big Creek. See the response to ESRD/CEAA Round 3 SIR 24 for the conceptual monitoring plan. See the aquatic health assessment (Volume 5, Section 4.12, Pages to 4-212) and revised assessment provided in response to ESRD/CEAA, Round 1 SIR 45a, Appendix 45a.7. See the response to ESRD/CEAA Round 3 SIR 24 for the conceptual monitoring plan. October 2014 ESRD/CEAA Page 229

232 ESRD and CEAA Responses Water Frontier Oil Sands Mine Project Table 42b-1 Fish and Fish Habitat Assessment Conclusions (cont d) Pathway or Linkage Validity Conclusions and Mitigation Knowledge Gaps Supporting Information Change in watercourse or waterbody habitat area Change in habitat accessibility to fish Valid linkage because of planned watercourse diversions, landscape changes and development of new habitat area as part of the CFHCP. Invalid linkage because no loss of access is expected to habitats except for losses included in the assessment of changes in habitat area. Loss of aquatic habitats in Unnamed Waterbody 22, Unnamed Creek 2 and a portion of Big Creek is predicted because of the diversions and landscape changes associated with mining. Compensation habitat was included in the Project design to manage potential losses in habitat productivity. The CFHCP includes the development of a FHCL to provide new habitats to compensate the loss of habitat productivity in Waterbody 22, Creek 2 and the affected portion of Big Creek, based on the HEP methods employed as standard practice for large compensation works in the oil sands region. Based on the mitigation, the habitat change was classified as a low magnitude effect. Loss of aquatic habitats will occur because of watercourse diversions and landscape changes, and is accounted for in the assessment of changes in habitat area. Because of mitigation to prevent interference with fish passage and prevent habitat fragmentation in the watercourse crossings, there will be no loss of access to other habitats. There is a high level of confidence that the FHCL will provide habitat productivity that is at least equivalent to the affected habitats. The quantified measure of HUs is based on the amount of habitat and habitat suitability, which describe the ability of key habitat components to supply the life requisites of each fish species. The HSI models for the oil sands were developed based on published models and the opinions of subject matter experts. In addition, the FHCL was designed to provide more HUs than the affected habitats. There is uncertainty associated with the prediction of fish habitat productivity levels in the FHCL because the fish HSI models used in the assessment have not been fully validated for the oil sands region. While model validation studies are underway, they have not been completed. Uncertainty is reduced by employing the HSI models to quantify productivity levels in affected and compensation habitats, and in providing a more than equivalent level of HUs in the compensation habitats. The knowledge gap around the FHCL providing sufficient compensation is that success has not been demonstrated for similar regional compensation lakes. These lakes have only been operating for a short time. Monitoring results are preliminary, but encouraging in relation to development of a diverse fish community. The conceptual monitoring plan includes components designed to determine the effectiveness of the FHCL. Confidence is high that the mitigation specified by the Alberta Water Act code of Practice for Watercourse Crossings will be successful in reducing and managing potential effects on fish migration and habitat fragmentation. See the revised CFHCP provided in response to ESRD/CEAA Round 2 SIR 30j, Appendix 30j.1. See the response to ESRD/CEAA Round 3 SIR 18 for a discussion of the HU calculation process, regional HSI models and, along with the response to ESRD/CEAA Round 3 SIR 21a, discussions of similar regional compensation lakes. See the responses to ESRD/CEAA Round 3 SIR 20 and SIR 35 for information about the expected success in establishing the FHCL fish community and suitable habitat productivity. See the response to ESRD/CEAA Round 3 SIR 24 for the conceptual monitoring plan for the Project. See the response to ESRD/CEAA Round 3 SIR 39 for mitigation, monitoring and correction measures for watercourse crossings. ESRD/CEAA Page 230 October 2014

233 Frontier Oil Sands Mine Project ESRD and CEAA Responses Water Table 42b-1 Fish and Fish Habitat Assessment Conclusions (cont d) Pathway or Linkage Validity Conclusions and Mitigation Knowledge Gaps Supporting Information Change in habitat conditions or productivity Change in benthic invertebrate communities Valid linkage for lowerlevel productivity of the Athabasca River because of potential changes in detrital inputs and benthic invertebrate drift associated with watercourse diversions and landscape changes. Valid linkage because of predicted changes in flow, water level, thermal regime and watercourse or waterbody habitat area. The potential for changes in detrital inputs were predicted to be negligible because of the expectation that allochthonous inputs in diversion channels will eventually be similar to the natural watercourse channel once riparian vegetation matures, flow related movement of detritus and because of the characteristics of the affected drainages, which filter large organic particles from large swamp areas with no defined watercourse channels. For Big Creek, channel conditions downstream of the wetland complex will not be affected; in Redclay Creek, the diversion will provide connectivity between the upper and lower watershed. Changes in benthic invertebrate drift to the Athabasca River were predicted to be negligible because of the factors mentioned and because most drift originates from benthic invertebrate communities a short distance upstream. There are no predicted effects on benthic inveterate communities in lower Big Creek or lower Redclay Creek. It was concluded that the potential for changes in benthic invertebrate communities is negligible. Although habitat changes associated with diversions and landscape changes will alter or eliminate habitats, the FHCL will mitigate effects by providing suitable benthic invertebrate habitat, and the food supply for fish is expected to be suitable in the compensation habitats as well in the watercourse habitats downstream of the Project area. Based on mitigation, the habitat change was classified as a low magnitude effect. There is a high level of confidence in the prediction based on the available literature concerning the nature of detrital inputs to watercourses and the physical characteristics of Big Creek and Redclay Creek relative to detrital inputs to the Athabasca River. There is a high level of confidence in the prediction based on the habitats that will be provided in the FHCL. See the responses to ESRD/CEAA Round 2 SIR 34 and Round 3 SIRs 4, 8 and 25 for discussion of potential effects on detrital inputs. See the response to ESRD/CEAA Round 3 SIR 31 for a discussion of potential effects on the productivity of the Athabasca River. See the response to ESRD/CEAA Round 3 SIR 27 for a discussion of benthic invertebrate drift sources. See the revised fish and fish habitat assessment provided in response to ESRD/CEAA Round 2 SIR 30a, Appendix 30a.1. October 2014 ESRD/CEAA Page 231

234 ESRD and CEAA Responses Water Frontier Oil Sands Mine Project Table 42b-1 Fish and Fish Habitat Assessment Conclusions (cont d) Pathway or Linkage Validity Conclusions and Mitigation Knowledge Gaps Supporting Information Change in fishing pressure Fish entrainment or impingement at intake Change in fish abundance Valid linkage because of increased access provided by the Project and increases in the region s human population, which has a cumulative contribution to changes in fishing pressure. Invalid linkage because of screening of the intake to comply with provincial and federal criteria. Valid linkage because of predicted changes in flow, water level, thermal regime and watercourse or waterbody habitat area. The assessment concluded that there would be no effects due to increased access associated with the Project because of the lack of sport fish populations in the development area. Despite the large increase in regional human population, there has been no increase in the number of regional anglers, and it is expected that the increase in angling pressure will be negligible. The assessment concluded that the freshwater intake at the Athabasca River would not result in fish entrainment or impingement based on the mitigation of proper intake screening. The intake will be screened to meet provincial and federal requirements for screen size and water velocity characteristics to mitigate entrainment or impingement for the fish species known to occur in the Athabasca River. The assessment concluded that the potential for the Project to result in reduced fish abundance because of changes in fish habitat productivity was negligible, based on the mitigation provided in the CFHCP to compensate potential changes in productivity. It was also concluded that the CFHCP provided the potential for an increase in fish abundance through design of the FHCL to provide more than equivalent productivity (based on HU calculations) than provided by the affected habitats. The FHCL is expected to provide improved habitat suitability in the aquatics LSA for large-bodied sport fish and sucker species. There is a high level of confidence in the prediction based on the documented distribution of fish species in the Project development area and the documented lack of pattern or increasing trends in fishing license sales in the region, despite population increases. The confidence level is high that the mitigation specified by the regulatory guidance documents for intake screening will successfully mitigate the potential for fish entrainment and impingement at the water intake. Further assessment will be completed as part of the development of the detailed intake design and construction plan, and knowledge gaps regarding baseline conditions for fish and fish at the intake site identified by Fisheries and Oceans Canada will be addressed. There is a high level of confidence that the FHCL will compensate potential changes in fish abundance by providing habitat productivity that is at least equivalent to the affected habitats. The quantified measure of HUs is based on the amount of habitat and habitat suitability, which describe the ability of key habitat components to supply the life requisites of each fish species. The HSI models for the oil sands were developed based on published models and the opinions of subject matter experts. In addition, the FHCL was designed to provide more HUs than the affected habitats. The provision of habitat types in the FHCL that are suitable for use by suckers and sport fish that are not present in the affected habitats is expected to increase the distribution and abundance of these species in the aquatics LSA. See the fish and fish habitat assessment (Volume 5, Section , Page 5-41). See the response to ESRD/CEAA Round 1 SIR 119 and Round 3 SIR 36 for a discussion of regional fishing pressure. See the fish and fish habitat assessment (Volume 5, Section , Page 5-41). See the response to ESRD/CEAA Round 3 SIR 22d for information on the planned intake assessment. See the fish and fish habitat assessment (Volume 5, Section 5.6, Pages 5-37 to 5-44). See the revised fish and fish habitat assessment provided in response to ESRD/CEAA Round 2 SIR 30a, Appendix 30a.1. See the response to ESRD/CEAA Round 2 SIR 51a for a discussion of the rationale for how the FHCL is expected to support fish abundance through provision of increased productive capacity. ESRD/CEAA Page 232 October 2014

235 Frontier Oil Sands Mine Project ESRD and CEAA Responses Water Table 42b-1 Fish and Fish Habitat Assessment Conclusions (cont d) Pathway or Linkage Validity Conclusions and Mitigation Knowledge Gaps Supporting Information Change in fish abundance (cont d) Change in fish habitat diversity Valid linkage because of predicted changes in watercourse or waterbody habitat area and development of new habitat area as part of the CFHCP. The assessment concluded that the potential for reduction in fish habitat diversity in the aquatics LSA was negligible, based on the mitigation provided by the FHCL and the aquatic habitats to be provided in the watercourses that will be developed as part of the closure landscape. The FHCL will provide lentic habitats with a greater level of diversity than the affected lentic habitats. A small amount of lotic habitat will be replaced with lentic habitat as part of the CFHCP, but the lentic habitats will provide high habitat suitability, particularly for large-bodied sport fish and suckers. New lentic habitats will be available in the numerous watercourses that will form part of the closure drainage system. There is uncertainty associated with the prediction of fish habitat productivity levels and fish abundance in the FHCL because the fish HSI models used in the assessment have not been fully validated for the oil sands region. While model validation studies are underway, they have not been completed. Uncertainty is reduced by employing the HSI models to quantify productivity levels in affected and compensation habitats, by the conservative assumptions used when applying the models, and in providing a more than equivalent level of HUs in the compensation habitats. The knowledge gap around the FHCL providing sufficient compensation is that success has not been demonstrated for similar regional compensation lakes. These lakes have only been operating for a short time. Monitoring results are preliminary, but encouraging in relation to development of a diverse fish community. The conceptual monitoring plan includes components designed to determine the effectiveness of the FHCL in providing sufficient habitat productivity and fish abundance compensation. There is a high level of confidence that the FHCL will provide increased lentic habitat diversity. The design will include the habitat requisites of the candidate fish community, which consists of sport fish, sucker and forage fish species. Examples of habitat types to be provided that are not present in the affected lentic habitats include deep-water habitats, improved overwintering habitat and rocky substrates. See the response to ESRD/CEAA Round 3 SIR 10f for information about fish abundance predictions, uncertainty and knowledge gaps. See the response to ESRD/CEAA Round 3 SIR 20 for information about the confidence in establishing a suitable fish community in the FHCL. See the responses to ESRD/CEAA Round 3 SIRs 18e, 21a and 31c for a summary of knowledge gaps regarding functioning examples of similar compensation lake works. See the response to ESRD/CEAA Round 3 SIR 24 for the conceptual monitoring plan for the Project. See the revised fish and fish habitat assessment provided in response to ESRD/CEAA Round 2 SIR 30a, Appendix 30a.1. October 2014 ESRD/CEAA Page 233

236 ESRD and CEAA Responses Water Frontier Oil Sands Mine Project Table 42b-1 Fish and Fish Habitat Assessment Conclusions (cont d) Pathway or Linkage Validity Conclusions and Mitigation Knowledge Gaps Supporting Information Change in fish species diversity Change in fish trophic levels Valid linkage because of predicted changes in watercourse or waterbody habitat area and development of new habitat area as part of the CFHCP. Valid linkage because of predicted changes in watercourse or waterbody habitat area and development of new habitat area as part of the CFHCP. The assessment concluded that the potential for reduction in fish species diversity in the aquatics LSA was negligible, based on the mitigation provided by the FHCL. The FHCL will provide habitats with high habitat suitability, particularly for large-bodied sport fish and suckers. The FHCL will provide habitats for affected species as well as species not present in the affected habitats. The FHCL has the potential to increase fish species diversity as it is expected to increase the distribution and abundance of large-bodied sport fish and suckers in the aquatics LSA. The assessment concluded that the potential for reduction in fish species trophic level diversity in the aquatics LSA was negligible, based on the mitigation provided by the FHCL. The FHCL will provide habitats with high habitat suitability for forage fish, suckers and sport fish, including predatory species. The FHCL has the potential to increase trophic level diversity as it is expected to increase the distribution and abundance of large-bodied sport fish in the aquatics LSA. There is a high level of confidence that the FHCL will maintain or improve fish species diversity in the aquatics LSA by providing increased lentic habitat diversity and habitats suitable for all life stage requisites of the candidate sport, sucker and forage fish species for the FHCL community. There is a high level of confidence that the FHCL will maintain or improve trophic level diversity in the aquatics LSA by providing habitats suitable for fish species of all trophic levels and increasing available habitat for predatory species, which are not present in the affected habitats. See the revised fish and fish habitat assessment provided in response to ESRD/CEAA Round 2 SIR 30a, Appendix 30a.1. See the responses to ESRD/CEAA Round 3 SIR 20 and SIR 35 for information about the expected fish community of the FHCL. See the revised fish and fish habitat assessment provided in response to ESRD/CEAA Round 2 SIR 30a, Appendix 30a.1. See the responses to ESRD/CEAA Round 3 SIR 20 and SIR 35 for information about the expected fish community of the FHCL. ESRD/CEAA Page 234 October 2014

237 Frontier Oil Sands Mine Project ESRD and CEAA Responses Water Table 42b-1 Fish and Fish Habitat Assessment Conclusions (cont d) Pathway or Linkage Validity Conclusions and Mitigation Knowledge Gaps Supporting Information Change in benthic invertebrate diversity Valid link because of predicted changes in watercourse or waterbody habitat area and development of new habitat area as part of the CFHCP. The assessment concluded that the potential for reduction in benthic invertebrate diversity was negligible, based on the mitigation provided by the FHCL and the aquatic habitats to be provided in the watercourses that will be developed as part of the closure landscape. The FHCL will provide lentic habitats with a greater level of diversity than the affected lentic habitats that are expected to support a higher level of benthic invertebrate diversity than the affected lentic habitats. A small amount of lotic habitat will be replaced with lentic habitat as part of the CFHCP, but the lentic habitats will provide increased habitat diversity in the LSA. New lentic habitats will be available in the numerous watercourses that will form part of the closure drainage system. There is a high level of confidence in the prediction that the FHCL will provide increased lentic habitat diversity. Examples of specific habitat types to be provided that are not present in the affected lentic habitats include deep-water habitats, improved overwintering habitat and rocky substrates. Monitoring data from a similar compensation lake that is in the early stages of development show a level of benthic invertebrate diversity that is above that documented in the largest of the affected waterbodies. See the revised fish and fish habitat assessment provided in response to ESRD/CEAA Round 2 SIR 30a, Appendix 30a.1. See the response to ESRD/CEAA Round 3 SIR 28 for information about the expected increase in benthic invertebrate diversity in the FHCL in relation to affected waterbodies. October 2014 ESRD/CEAA Page 235

238 ESRD and CEAA Responses Water Frontier Oil Sands Mine Project c. Linkage pathways indicate that there is potential for effects interactions in watercourses downstream of the Project area, including lower Big Creek, lower Redclay Creek and the Athabasca River. Each area was assessed for multiple pathways. Big Creek was assessed for change in flows, channel regime, thermal regime and benthic invertebrate communities. Redclay Creek was assessed for changes in flows, channel regime and benthic invertebrate communities. The pathways were assessed as having negligible effects or low magnitude effects based on mitigation associated with the CFHCP. Uncertainty and knowledge gaps were identified around changes in channel regime in the two watercourses and the predicted temperature shift in Big Creek. As a result of uncertainty and possible effects interactions, the conceptual monitoring plan includes monitoring habitat, fish populations and benthic invertebrate communities in these two watercourses. The Athabasca River was assessed for changes in flows and lower-level productivity related to detrital inputs and benthic invertebrate drift. Since all effects were predicted to be negligible with a low level of uncertainty, the potential for effects interactions is considered negligible. Long-term regional fish population monitoring in the Athabasca River is ongoing. Results to date show no adverse changes in fish populations (see the response to ESRD/CEAA Round 3 SIR 9b). Overall conclusions for the potential effects of the Project on fish and fish habitat are described in Table 42b-1. Low magnitude effects are predicted for changes in fish habitat associated with changes in flows, suspended sediments, habitat area and benthic invertebrate communities. These effects are managed through mitigation outlined in the CFHCP. The FHCL is also expected to mitigate effects on fish habitat productivity in the aquatics LSA. Because the FHCL is expected to increase habitat diversity for lentic habitats in the aquatics LSA and to provide suitable habitats for large-bodied species that are not present in the affected habitats, there are no predicted adverse effects on fish abundance or fish and fish habitat diversity. The assessment conclusion is not consistent with the Terrestrial Ecosystem Management Framework (TEMF). This inconsistency arises from a lack of suitability of the TEMF modelling methods to predict Project effects that compare with the multi-pathway, Project-specific assessment done. As described in response to ESRD/CEAA Round 3 SIR 10a, model predictions in the TEMF state that the Index of Native Fish Integrity (INFI) is in the red condition, meaning that the index is 20% below the natural range of variation (NRV) or the model predicts it will drop to this level within 15 years. The prediction is based on simple, assumed relationships between linear development density (as representative of degree of habitat fragmentation), human density and the INFI. The TEMF is a modelling exercise to determine the implications of various management scenarios, but is not conducted at detailed enough level to be of use in the Project assessment. The IFNI used is not relevant to the aquatics LSA because of a lack of sport fish population, which is the key driver behind INFI levels. INFI also does not consider mitigation included in the Project to prevent aquatic habitat fragmentation. ESRD/CEAA Page 236 October 2014

239 Frontier Oil Sands Mine Project ESRD and CEAA Responses Terrestrial 5 TERRESTRIAL 5.1 Land Use and Land Management Question 43 SIR2 Response 57 b, Page Teck was asked how land use effects associated with the fish habitat compensation lake will be mitigated or to provide specific references to where the information is provided. Teck s response directs the reviewer to mitigation summary tables provided in the Volume 1 EIA Summary (Section 18). Many of the mitigation measures listed are not specific to the terrestrial effects associated with the proposed fish compensation lake. a. Provide a table that lists the potential effects associated specifically with the fish habitat compensation lake. Identify the mitigation proposed for each listed effect. Describe whether the mitigation will eliminate the effect or partially address the effect. For effects for which the mitigation does not eliminate the effect, highlight the residual effect. Response 43 a. Several fish habitat compensation options were considered for the Project, with Option 2 being selected for the FHCL (see Volume 1, Section , Pages 2-21 to 2-22). Option 2 incorporates the FHCL into Redclay Creek using the natural topography associated with the creek s entry to the Athabasca River valley. The response to ESRD/CEAA Round 1 SIR 468a identifies the vegetation cover classes and wildlife habitat for key indicator species present in this location and their extent (as a percentage of the Project footprint). For convenience, this information is included in Table 43a-1. The purpose of the FHCL is to mitigate the loss of fish and fish habitat resulting from the Project. However, as part of that mitigation, terrestrial lands and associated resources will be permanently lost. That loss is offset by other gains for the environment (i.e., viable aquatic habitat). October 2014 ESRD/CEAA Page 237

240 ESRD and CEAA Responses Terrestrial Frontier Oil Sands Mine Project Table 43a-1 Vegetation Cover Classes in Option 2 FHCL Vegetation Cover Class Option 2 FHCL Area % Net Gain or Loss at Closure Environmental Consequence 1 Relative to Predevelopment Coniferous jack pine Gain Low Low Low Coniferous white spruce Gain Low Low Low Mixedwood white spruce Loss Low Low Low Deciduous/Mixedwood deciduous Gain Low Low Low Upland shrubland Loss Moderate Moderate Moderate Upland grassland Loss Moderate Moderate Moderate Subtotal Upland Gain Low Low Low Wooded bog Loss Low Low Moderate Shrubby fen Loss High High High Open fen Loss High High High Wooded swamp Loss Low Low Moderate Shrubby swamp Gain Low Low Low Subtotal Wetland Loss Low Moderate Moderate Total N/A N/A N/A N/A Old-growth forest Loss Moderate Moderate Moderate NOTES: 1 Environmental consequence reflects regional residual cumulative effects after consideration of regional reclamation (see the response to ESRD/CEAA Round 2 SIR 136, Appendix 136a.1). The revised Project incrementally contributes to regional residual cumulative effects. N/A = not applicable. There is an overall net Project gain for several vegetation cover classes occurring in the FHCL (see Table 43a-1). For cover classes with a net Project gain, it is Teck s opinion that common boreal species associated with these cover classes will be reestablished through reclamation efforts, and effects are therefore mitigated. Where a net loss of vegetation cover classes is expected, there is a residual effect that was assessed as part of the EIA process (see Volume 6, Section 3.6, Pages 3-45 to 3-81, and the revised vegetation assessment provided in response to ESRD/CEAA Round 2 SIR 136a, Appendix 136a.1). The FHCL is incrementally contributing to that effect (see Table 43a-1). Specific FHCL cover classes that will have a net Project loss are: mixedwood-white spruce forest upland shrubland and grassland wooded bog shrubby fen open fen wooded swamp ESRD/CEAA Page 238 October 2014

241 Frontier Oil Sands Mine Project ESRD and CEAA Responses Terrestrial Two of the vegetation cover classes within the FHCL that experience a net Project loss, shrubby fen and open fen, are rated as having a high environmental consequence. This reflects regional cumulative effects and the irreversibility of replacing peatland ecosystems to the same extent as at predevelopment. Wildlife key indicator species for which shrubby and open fen vegetation cover classes are moderately to highly suitable are Canada lynx, common nighthawk, rusty blackbird, short-eared owl, western toad, wood bison and yellow rail. Of these, regional cumulative effects to habitat were rated as having high environmental consequence for rusty blackbird, short-eared owl, yellow rail and western toad (see Volume 6, Section 4.5, Pages 4-30 to 4-256, and the revised wildlife assessment provided in response to ESRD/CEAA Round 2 SIR 136a, Appendix 136a.4). The Project and the FHCL are expected to incrementally contribute to these losses. Reclamation will provide some habitat for these species, and Teck has committed to relocate western toads (see the response to ESRD/CEAA Round 1 SIR 454). However, it is anticipated that residual effects to moderate- to highsuitability habitat will remain without additional mitigation. Wetlands and the species that depend on them for some or all of their life cycle are present throughout the boreal forest and are particularly common in low-lying areas where it is preferable to construct fish habitat compensation lakes. Therefore, shifting the FHCL to an alternate location will not likely result in a different outcome (i.e., wetlands, and particularly peatlands, will be present in the required FHCL disturbance area) unless Teck is able to negotiate an agreement with Shell and integrate Project compensation with the compensation lake planned for the PRM (i.e., realize preferred Option 1B). For a comparison of the amount of wetlands present for different FHCL options, see the response to ESRD/CEAA Round 1 SIR 468a, Table 468a-1. Other options for compensation (e.g., enhancement of watercourses or habitat offsets) would be required to potentially eliminate effects to wetlands. As indicated in the response to ERCB Round 2 SIR 29b: It is Teck s view that habitat offsets and conservation initiatives as well as other mitigation will be used, where necessary, to address residual impacts after avoidance, mitigation and reclamation/rehabilitation have been taken into account, including effects to wetlands and biodiversity. This aligns with recent Joint Review Panel decision reports for oil sands mines, including the Joslyn North Mine and Jackpine Mine Expansion, and with Environment Canada s (2012) Operational Framework for the Use of Conservation Allowances. This also fully aligns with Teck s own publicly disclosed Biodiversity Plan. October 2014 ESRD/CEAA Page 239

242 ESRD and CEAA Responses Terrestrial Frontier Oil Sands Mine Project REFERENCES Environment Canada Operational Framework for the Use of Conservation Allowances. Available at: Accessed March Question 44 SIR2 Response 63, Page , SIR2 72, Page 203, and SIR2 Response 73, Page 204. Teck indicates its preferred access option is Shell s proposed Athabasca River Bridge 28 km upgrade of the existing winter access road. Shell has requested a delay in their review and approval process, which has subsequently been granted by the federal-provincial panel convened to review and assess their proposed Project. a. Discuss how this delay will affect Teck s planning and which alternate options it will pursue. Update the conclusions to include the revised access approach and environmental effects. Response 44 a. The delay of the PRM does not affect Teck s planning because the Frontier Project has also been delayed (see the response to AER Round 3 SIR 1). Alternate options are not being pursued and conclusions regarding the access approach and environmental effects do not need updating beyond what is necessary to consider temporal effects of the revised development schedule. Teck will continue to work with Shell under the Projects Agreement to align schedules and share infrastructure during future stages of engineering (see the response to ESRD/CEAA Round 2 SIR 1). ESRD/CEAA Page 240 October 2014

243 Frontier Oil Sands Mine Project ESRD and CEAA Responses Terrestrial 5.2 Conservation and Reclamation Question 45 Volume 1, ESRD/CEAA SIR 74, Figure 74b-1, Pages 205 and 206 Teck illustrates in Figure 74b-1 the available topsoil salvage depths for each map unit in the revised Terrestrial LSA and the details are provided in Appendix 74a.1. Teck did not provide stripping depths for disturbed land (as illustrated in Figure 74b-1). a. Provide stripping depths for disturbed soils and update Appendix 74a.1. b. Provide conformation that Teck will salvage all topsoil present on disturbed lands. Response 45 a. Existing disturbed lands account for 190 ha of the 24,139 ha PDA and occur in three separate soil map units. If topsoil is present on disturbed land, Teck expects that it would either be similar in depth to that of the surrounding classified polygons (which range from 20 cm to 50 cm), or less because of previous disturbance. A revised appendix is provided (see Appendix 45a.1) that reflects the potential for topsoil to be present on disturbed land. b. Teck will salvage upper and lower lift materials as described in Volume 1, Section 13.5, Table , Page and reproduced below (see Table 45b-1). Upper lift reclamation materials will be salvaged from all areas where surface soil disturbance is proposed. If topsoil is present on existing disturbances, it will be salvaged. Table 45b-1 Reclamation Material Salvage Depth Upper Lift Salvage Layer Coarse-textured upland surface soil Medium- and fine-textured upland surface soil Fine-textured fluvial fan material Lower Lift Coarse-textured suitable subsoil material Medium- and fine-textured suitable subsoil material Organic soil Salvage Depth Overlying LFH, O and upper 20 cm of mineral material Overlying LFH, O and upper 35 cm of mineral material Overlying LFH, O and upper 50 cm of mineral material 20 cm to bottom of suitable subsoil material 35 cm to bottom of suitable subsoil material NOTES: LFH = Surface leaf litter horizon on well drained upland soils. O = Surface organic accumulation, usually peat, on lowland or poorly drained soils. To depth plus over-stripping into underlying mineral October 2014 ESRD/CEAA Page 241

244 ESRD and CEAA Responses Terrestrial Frontier Oil Sands Mine Project ESRD/CEAA Page 242 October 2014

245 Frontier Oil Sands Mine Project ESRD and CEAA Responses Terrestrial 5.3 Terrain and Soils Question 46 Volume 1, ESRD/CEAA SIR, Pages 212 and 213 Volume 2, Appendix 78a.1 Pages i to vi, 2-1 to 2-26 Volume 2, Appendix 78b.1 Pages i to ii, 78b.1-1 to 78b.1-32 Teck removed the proposed PRM soil and terrestrial disturbance information for the Project from all the base case assessment for the EIA. Teck also updated all figures, tables, discussions to reflect this correction. Teck provided two appendices with their response to SIR 78. They included a revised assessment (Appendix 78a.1) and an alternative assessment which included the removal of progressive reclamation for regional development (Appendix 78b.1) for terrain and soils. In Appendix 78a.1, Table 2 12 (page 2-19 to 2-20) Teck provided changes to soil series diversity (revised). The values provided for Change from pre-development to application case, Project maximum build-out (ha and %) are not consistent with proposed development. For example, Brunisolic soils have a positive increase in ha and %. All other soils have a negative or neutral increase. a. Review the table and revise if necessary. Response 46 a. Table 46a-1 provides revisions to the columns outlining change from predevelopment to Application Case for brunisolic soil map units. No other changes were made to the table. The revised assessment conclusions remain unchanged from those discussed in the response to ESRD/CEAA Round 2 SIR 78a, Appendix 78a.1. October 2014 ESRD/CEAA Page 243

246 ESRD and CEAA Responses Terrestrial Frontier Oil Sands Mine Project Table 46a-1 Changes in Soil Series Diversity (Revised Table 2-12) Condition or Assessment Case Reference Condition Base Case Snapshot or Soil Map Unit Brunisolic Soils Predevelopment Existing Maximum Build-out (ha) (ha) (ha) (ha) Change from Predevelopment to Base Case Maximum Build-out Application Case Project Maximum Build-out Project Closure Percent of Revised Terrestrial LSA (ha) (ha) (ha) Change from Predevelopment to Application Case Project Maximum Build-out Percent of Revised Terrestrial LSA Project Closure Eymundson 1, , , < Marguerite 3, , , , , , , Mildred 3, , , , , , , Ruth Lake Subtotal 8, , , , , , , Luvisolic Soils Horse River 1, , , < , , Kilome < Surmont 1, , , < Winefred < < <-0.1 Subtotal 3, , , , , Regosolic Soils McMurray Namur 6, , , , , , , Subtotal 6, , , , , , , Gleysolic Soils Asphalt 14, , , , , , , Bitumont 1,14.6 1, , Els River < Mamawi < Subtotal 16, , , , , , , (ha) Percent of Revised Terrestrial LSA ESRD/CEAA Page 244 October 2014

247 Frontier Oil Sands Mine Project ESRD and CEAA Responses Terrestrial Table 46a-1 Changes in Soil Series Diversity (Revised Table 2-12) (cont d) Condition or Assessment Case Reference Condition Base Case Snapshot or Soil Map Unit Organic Soils Predevelopment Existing Maximum Build-out (ha) (ha) (ha) (ha) Change from Predevelopment to Base Case Application Case Change from Predevelopment to Application Case Maximum Build-out Project Maximum Build-out Project Closure Percent of Revised Terrestrial LSA (ha) (ha) (ha) Project Maximum Build-out Percent of Revised Terrestrial LSA Project Closure Albian Hartley Mariana < McLelland 1, , , Muskeg Subtotal 2, , , , , , , Cryosolic Soils Mikkwa Subtotal Other Land Units Disturbed Land Reclaimed Land (ha) Percent of Revised Terrestrial LSA , , , , Water , , Total 1,2 38,150 38,150 38, ,150 38, NOTES: Revised cells are marked with gray shading. 1 Areas and proportions might not add up to totals because of rounding 2 The revised PDA is 24,139 ha. This number cannot be directly calculated from the difference between Base Case and Application Case because of waterbodies in the closure landscape. The change in water from maximum build-out to closure is 2,251.3 ha. When this is added to the area of reclaimed land at closure (21,887.7 ha), the total area in the closure landscape is 24,139 ha. October 2014 ESRD/CEAA Page 245

248 ESRD and CEAA Responses Terrestrial Frontier Oil Sands Mine Project Question 47 Volume 1, ESRD/CEAA SIR 78, Pages 212 and 213 Volume 2, Appendix 78a.1, Section 2.7, Table 2-16, Pages 2-23 and 2-24 In Table 2-16 Teck provides an area-weighted average class for Forest Land Capability. a. Provide the scientific rationale for using an area-weighted average class for LCC (i.e., classes are real numbers, not integers). b. Revise and update the table after removal of the weighted-average class. Response 47 a. An area-weighted average class was used in the terrain and soils assessment for the Project to quantify proportional changes in land capability classification (LCC) class in the terrestrial LSA. Because the proportion of the terrestrial LSA not rated with an LCC value (i.e., water and disturbed land) changes between reference conditions and assessment cases, use of a modal value is more appropriate and is provided in the response to part b. b. A revised table is provided (see Table 47b-1) that lists modal LCC values for the revised terrestrial LSA. As described in the, changes in soil capability will be confined to the PDA and are expected to persist until reclamation is complete at closure. Because LCCs at closure reflect an overall improvement in forest capability, effects are considered reversible and have low environmental consequence. It should be noted that the overall improvement in LCCs reflects changes in the closure landscape, including a reduction in the amount of wetlands present. As part of the updated closure, conservation and reclamation (CC&R) plan for the Project, Teck plans to increase the relative proportion of wetlands where feasible (see the response to AER Round 3 SIR 1). These changes will be considered as part of the Project Update. ESRD/CEAA Page 246 October 2014

249 Frontier Oil Sands Mine Project ESRD and CEAA Responses Terrestrial Table 47b-1 Changes in Forest Land Capability Extent (Revised Table 2-16) Condition or Assessment Case Reference Condition Base Case Snapshot or Capability Class Predevelopment Existing Maximum Build-out (ha) (ha) (ha) (ha) Change from Predevelopment to Base Case Application Case Project Maximum Build-out Project Closure Percent of Revised Terrestrial LSA (ha) (ha) (ha) Change from Predevelopment to Application Case Project Maximum Build-out Percent of Revised Terrestrial LSA Project Closure 1 6, , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , N/A (water and disturbed land) (ha) Percent of Revised Terrestrial LSA , , , , , Modal class N/A N/A NOTE: N/A Not applicable October 2014 ESRD/CEAA Page 247

250 ESRD and CEAA Responses Terrestrial Frontier Oil Sands Mine Project Question 48 Volume 1, ESRD/CEAA SIR 79, Figure 79a-1, Pages 214 and 215 a. Provide updated PAI isopleths on 1:20,000 black and white photos with labels for: the development footprint, soil map unit polygon boundaries, site inspection points, and isopleths for the PAI loading levels of the 0.17 keq H+/ha/a where anticipated as depicted by the fixed cased soil critical load exceedances. Response 48 a. Updated figures are provided on CD (see Appendix 48a.1) that show potential acid input (PAI) isopleths for the Base Case, Application Case and Planned Development Case (PDC) at a 1:20,000 scale for the revised terrestrial LSA. These figures also show the development footprints, soil map unit polygons and site inspection points. The PAI isopleths represent those determined as part of the alternate terrain and soils assessment (see the response to ESRD/CEAA Round 2 SIR 78a, Appendix 78b.1). The alternate assessment: removes the PRM from the Base Case and Application Case in the revised terrestrial LSA uses ESRD MM5 as input data for air modelling Several of the soil series mapped in the revised terrestrial LSA were not modelled for critical loads following the ARC model (Abboud et al. 2002), as was used in the regional assessment for PAI. Critical loads used in this response are listed in Table 48a-1. Results based on revised terrestrial LSA soils information are consistent with those provided as part of the alternate assessment (i.e., no soil is expected to be exposed to a value above critical loads for the Base Case and Application Case). For the PDC, 0.1 ha (less than 0.1% of the revised terrestrial LSA) is predicted to have be above critical loads. This area was not accounted for in the regionalscale alternate assessment (see the response to ESRD/CEAA Round 2 SIR 78a, Appendix 78b.1). REFERENCES Abboud, S.A., L.W. Turchenek and L.A. Halsey Critical Loads of Acid Deposition on Soils in the Athabasca Oil Sands Region, Alberta. Alberta Environment. Edmonton, Alberta. Holowaycuk, N. and R.J. Fessenden Soil Sensitivity to Acid Deposition and the Potential of Soils and Geology to Reduce the Acidity of Acidic Inputs. Alberta Research Council, Edmonton, Alberta. ESRD/CEAA Page 248 October 2014

251 Frontier Oil Sands Mine Project ESRD and CEAA Responses Terrestrial Table 48a-1 Derivation of Critical Loads for Soil Series in the Revised Terrestrial LSA Revised Terrestrial LSA Soil Series Name and Code Alternate Assessment Soil Series Critical Load 3 Comments Albian ALB Gregoire There is no modelled critical load of the Albian soil series. The modelled critical load of Terric Albian over clay ALBxc Gregoire the Gregoire soil has been used to represent the expected critical load of these phases of the Albian soil series. These phases of Albian and the related Gregoire soil series Terric Albian over loam ALBxm Gregoire are Fibrisols so should have similar cation exchange capacity. Gregoire is a bog soil Terric Albian over sand ALBxs Gregoire and Albian is a fen soil, so Albian should have a higher ph and be better buffered than Gregoire. The use of 0.5 is considered conservative. Asphalt AST Critical load 0.7 There is no modelled critical load for the Asphalt soil series. Although Asphalt soil Asphalt coarse ASTco load, Project chemical data show that Asphalt profiles tend to be more acidic than estimated forms on the same material as Namur, for which there is an accepted modelled critical Asphalt coarse and peaty ASTcopt 0.7 Namur. In terms of the Holowaychuk and Fessenden (1987) approach to estimating Asphalt peaty ASTpt 0.7 sensitivity towards acidification, the Asphalt soils in the moderately sensitive group. The moderately sensitive group correlates with modelled critical loads of about Asphalt over sand ASTxs Keq+/ha/a. Asphalt over till ASTxt 0.7 Peaty Bitumount over till BMTxtpt Bitumount The modelled critical load of Bitumount has been used for all the phases of the Rego Bitumount BMTzr Bitumount Bitumount soil series found in the revised terrestrial LSA. Rego and cobbly Bitumount BMTzrcb Bitumount Peaty and Rego Bitumount BMTzrpt Bitumount Disturbed Land DL Disturbed Land N/A Critical loads are not estimated for disturbed land. Peaty Els River ELSpt Steepbank There is no modelled critical load of the Els River series. The modelled critical load of Steepbank has been used as a surrogate for the Els River soil series. This is justified because Els River soil forms on the same material as Steepbank, belongs to the same Great Group of the Gleysolic order, and should have similar or more buffering against acidification than Steepbank due to its more juvenile weathering stage greater water table interaction. Els River soil experiences groundwater influence similar to an Organic fen soil, with addition of base cations through groundwater discharge. Eymundson EYM Namur There is no modelled critical load of the Eymundson soil series. The Eymundson soil series is formed on the same materials as Namur. In terms of taxonomic development, it represents a more developed Brunisolic soil whereas Namur represented an earlier period of soil development (Regosolic). In terms of critical load Eymundson should have a similar critical load as Namur. October 2014 ESRD/CEAA Page 249

252 ESRD and CEAA Responses Terrestrial Frontier Oil Sands Mine Project Table 48a-1 Derivation of Critical Loads for Soil Series in the Revised Terrestrial LSA (cont d) Revised Terrestrial LSA Soil Series Name and Code Alternate Assessment Soil Series Critical Load 3 Comments Fort FRT Fort Used modelled critical load of the Fort soil series. Hartley HLY Hartley Used modelled critical load of the Hartley soil series. Horse River HRR Horse River Used modelled critical load of the Horse River soil series. Gleyed Horse River HRRgl Horse River The modelled critical load of Horse River has been used for all the phases of the Horse River soil series found in the revised terrestrial LSA. Kilome KME Dover There is no modelled critical load for the Kilome soils series. However, the Kilome and Dover soils series are very similar, differing only in terms of drainage and subgroup classification. The modelled critical load of Dover has been used for the Kilome soil series found in the revised terrestrial LSA. Marguerite MAR Marguerite Used modelled critical load of the Marguerite soil series. Marguerite gleyed MARgl Marguerite z 0.8 The modelled critical load of Marguerite has been used for all the phases of the Marguerite soil series found in the revised terrestrial LSA. Mildred MIL Mildred 1 1 Used modelled critical load of the Mildred soil series. Gleyed Mildred MILgl Mildred 1 1 The modelled critical load of Mildred has been used for all the phases of the Mildred soil Mildred over till MILxt Mildred 1 1 series found in the revised terrestrial LSA. Mikkwa MKWaa Mikkwa Used modelled critical load of the Mikkwa soil series. McLelland MLD McLelland Used modelled critical load of the McLelland soil series. McLelland over clay MLDxc McLelland The modelled critical load of McClelland has been used for all the phases of the McLelland over loam MLDxm McLelland McClelland soil series found in the revised terrestrial LSA. McLelland over sand MLDxs McLelland McLelland over till MLDxt McLelland Mamawi MMW Mamawi Used modelled critical load of the Mamawi soil series. Gleyed McMurray MMYgl McMurray The modelled critical load of McMurray has been used for all the phases of the McMurray soil series found in the revised terrestrial LSA. ESRD/CEAA Page 250 October 2014

253 Frontier Oil Sands Mine Project ESRD and CEAA Responses Terrestrial Table 48a-1 Derivation of Critical Loads for Soil Series in the Revised Terrestrial LSA (cont d) Revised Terrestrial LSA Soil Series Name and Code Alternate Assessment Soil Series Critical Load 3 Comments Mariana MRN Mariana Used modelled critical load of the Mariana soil series. Muskeg MUS Muskeg Used modelled critical load of the Muskeg soil series. Muskeg over loam MUSxm Muskeg The modelled critical load of Muskeg has been used for all these phases of the Muskeg soil series found in the revised terrestrial LSA. Namur gleyed NAMgl Namur The modelled critical load of Namur has been used for all these phases of the Namur Namur gleyed and coarse NAMglco Namur soil series found in the revised terrestrial LSA. Ruth, atypical RUTzz Ruth Lake Used modelled critical load of the Ruth Lake soil series to represent areas of the atypical Ruth Lake soil series in the revised terrestrial LSA. Atypical Ruth differs from the Ruth Lake soil series in terms of taxonomic development. Particle size and chemical buffering are expected to be similar between the different varieties of this series. Surmont, fine textured SRTaafi Surmont The modelled critical load of Surmont has been used for all these phases of the Surmont Surmont, fine and gleyed SRTaafigl Surmont soil series found in the revised terrestrial LSA. Winefred WNF Critical load 0.7 There is no modelled critical load for the Winefred soil series. Chemical data obtained for Gleyed Winefred WNFgl for all phases of the Winefred soil series. estimated profiles of this series from the Frontier field program was used to estimate a critical load Water ZZZ N/A N/A PAI analysis of water is conducted separately from that of PAI analysis of soil. NOTES: 1 The 50-year fixed-case critical loads for soil series were obtained from Abboud et al. (2002) 2 The 50-year fixed-case critical loads for soil series were estimated from a qualitative rating scheme (Holowaychuk and Fessenden 1987) and then fitted into the distribution of critical loads of Abboud et al. (2002) based on relationships among soil series chemical and physical properties year fixed case. N/A = not applicable. October 2014 ESRD/CEAA Page 251

254 ESRD and CEAA Responses Terrestrial Frontier Oil Sands Mine Project Question 49 Volume 1, ESRD/CEAA SIR 82, Page 217 Teck provided a commitment that additional soil data would be collected prior to construction to supplement the uncontrolled soil legend at the ESRD meeting on March 19, EIA: Teck states that An uncontrolled legend was used for mapping the LSA, meaning that all soils and non-soils (e.g., water) significant in extent are listed, either singly or in groups. (Page 7-21). Teck also states that Poor access over the LSA resulted in the use of transect inspection designs, which were carried out to ensure that potential delineations had inspection sites. Some polygons do not have an inspection site, whereas other delineations have several. The procedure is designed to allow interpretation of topographic-soil relationships and extrapolation of map unit concepts over areas where field verification was lacking. (Page 7-30) a. Provide a soil survey intensity for the additional soils investigations committed by Teck. Response 49 a. As noted in the response to ESRD/CEAA Round 2 SIR 82a: Teck confirms its commitment to collect additional soils information prior to construction to supplement the uncontrolled legend and provide more detailed information to support future stages of conservation and reclamation planning for the Project. Teck anticipates that additional soils information collected for the Project will be at soil Survey Intensity Level 2 (SIL 2). Question 50 Volume 1, ESRD/CEAA SIR 84, Page 219 to 220 Volume 2, Appendix 78b.1, Section 78b.1.7, Tables 78b-9 and 78b 10, Pages 78b.1-27 to 78b.1-30 Teck states that The 50-year mid-case critical loads were established to allow for a tiered approach to airshed management when combined with monitoring data (CEMA 2004). It represents a hypothetical effect that has the potential to occur (i.e., the value is at the midpoint of a potential realized effect). The effect is defined by the fixed case. Since an assessment evaluates effects, the fixed-case values are appropriate. Teck provided a brief PAI analysis based on mid-case critical loads in Appendix 78b.1. The analysis shows that for the base case and application case, there are two 4x4 township blocks above the 10,000-ha limit and for the PDA there are twelve 4x4 township blocks above the 10,000-ha limit, thereby exceeding a management trigger. ESRD/CEAA Page 252 October 2014

255 Frontier Oil Sands Mine Project ESRD and CEAA Responses Terrestrial The ADMF uses mid-case critical loads as management criteria. a. Determine the environmental consequence of the Project based on 50-year mid-case critical goals. b. Provide a management plan based on these results. Response 50 a. As noted in the preamble to this SIR, it is Teck s opinion that since an assessment evaluates effects, use of fixed-case values is most appropriate for the reasons discussed in the response to ESRD/CEAA Round 2 SIR 84. In addition, Teck notes that the method of assessing PAI inputs (i.e., using fixed-case values) aligns with the assessment methods used in two recent oil sands mine applications: Jackpine Mine Expansion Project (Shell 2007, Volume 3, Section ) Joslyn North Mine Project, Additional Information Project Update (TEPCA 2010, Section 14.10) Both of these applications have been deemed complete and approved. In addition to following similar methods and assessing the effects of cumulative air emissions on soils using the fixed-case, Teck has provided information on the mid-case to supplement the fixed-case assessment (see Volume 6, Appendix 2A and as revised in the response to ESRD/CEAA Round 2 SIR 78b, Appendix 78b.1). b. The Alberta Acid Deposition Management Framework (ADMF) (Alberta Environment 2008) recommends that management actions be structured to rely on monitoring and receptor measurements and minimize reliance on model predictions. Further, Alberta Environment (2008) suggests that management plans be developed by all relevant stakeholders and not individual operators. Under the Cumulative Environmental Management Association (CEMA 2004) Acid Deposition Management Framework for the oil sands region, monitoring must support the findings of acidification modelling to confirm a management trigger. Teck will participate in the development of regional management plans. REFERENCES Alberta Environment Alberta Acid Deposition Management Framework. Edmonton, Alberta. CEMA (Cumulative Effects Management Association) Recommendations for the Acid Deposition Management Framework for the Oil Sands Region of North-Eastern Alberta. Shell (Shell Canada Limited) Jackpine Mine Expansion and Pierre River Mine Application. Environmental Impact Assessment and Socio-Economic Assessment. Volume 3 Air Quality, Noise and Environmental Health. Prepared by Golder Associates Ltd., Calgary, Alberta. Submitted December TEPCA (Total E&P Canada) Joslyn North Mine Additional Information Project Update, Section Soils and Terrain. Prepared by Golder Associates Ltd., Calgary, Alberta. Submitted February October 2014 ESRD/CEAA Page 253

256 ESRD and CEAA Responses Terrestrial Frontier Oil Sands Mine Project Question 51 Volume 1, ESRD/CEAA SIR 77, Table 77a-1, Figure 77a-1, Pages 209 to 211 Teck provided the updated Soil map unit extents within Areas of Above the NO 2 AAAQO. The table is incomplete. Teck provided 77a-1: Soil Classification and NO 2 Concentration Application Case, however, the legend is incorrect and the PRM is not correctly identified. a. Complete the table. b. Correct the figure and associate label. Response 51 a. A revised table that includes all map unit names is provided (see Table 51a-1). b. A revised figure with a corrected legend is provided (see Figure 51b-1). Table 51a-1 Soil Map Unit Extents within Areas above the NO 2 AAAQO (Revised Table 77a-1) Soil Map Unit Map Unit Name Area (ha) Luvisolic Soils HRR Horse River 5.9 HRRgl Gleyed Horse River 2.0 SRTaafi Surmont, fine textured 9.9 WNF Winefred 0.3 Subtotal 18.1 Regosolic Soils NAMgl Namur gleyed 4.5 NAMglco Namur gleyed and coarse 0.1 Subtotal 4.7 Gleysolic Soils AST Asphalt 2.3 ASTpt Asphalt peaty 0.2 ASTxt Asphalt over till 2.0 MMW Mamawi 0.1 Subtotal 4.5 Organic Soils MLDxc McLelland over clay 0.2 MRN Mariana 6.4 MUS Muskeg 1.6 MUSxm Muskeg over loam 0.8 Subtotal 8.9 Disturbed Land 2,142.1 Total 2,178 NOTE: Areas might not add up to totals because of rounding. AAAQO = Alberta Ambient Air Quality Objective ESRD/CEAA Page 254 October 2014

257 Big Creek T102 R12W4 R11 Unnamed Creek 18 Unnamed Creek 17 Unnamed Creek 16 R10 R9 Unnamed Cree k 19 ³ T101 Unnamed Waterbody 29 Unnamed Waterbody 12 Redclay Creek Athabasca River T100 Unnamed Lake 1 Unnamed Lake 2 Eymundson Creek T99 Asphalt Creek First Creek Unnamed Waterbody 15 Predom inantsoilorder Brunisolic T98 Pierre River U n named Creek 1 Unnamed Waterbody 7 Unnamed Waterbody 10 Unnamed Waterbody 8 Cryosolic Gleysolic Luvisolic Organic Regosolic DisturbedLand PRM 45ug/m 3 NO2Isop leth TerrestrialLocalStudyArea Tow nship DefinedWatercourse UndefinedWatercourse Waterbody Acknowledgements: Base data: AltaLIS, Hydrology ground truthed by Golder (2009), Soil Data: Stantec. KILOMETRES 1:200,000UTM Z one12nad83 Date: Author: LF Checked: CS File ID: (Original page size: 8.5X11) Figure51b-1:SoilClassificationandNO 2 Concentration ApplicationCase(Rev ised) Frontier Project Resp onsetosup p lem entalinform ationrequest:round3 ESRD/CEAA

258 ESRD and CEAA Responses Terrestrial Frontier Oil Sands Mine Project ESRD/CEAA Page 256 October 2014

259 Frontier Oil Sands Mine Project ESRD and CEAA Responses Terrestrial 5.4 Vegetation Question 52 SIR2 Response 85, Page Teck was asked in SIR1 and SIR2 to identify alternative locations that do not require the removal of old growth forest for EDA1 and ETA1. Using the list provided and the definition of viable as locations that would not further advance the losses of old growth habitat, the following interpretations have been made: Options to the north may be viable (will not remove additional old growth), however Teck has agreed in discussions with aboriginal communities in Fort Chipewyan not to place tailings facilities in the Ronald Lake / Buckton Creek drainages. Options to the south may be viable (will not remove additional old growth); but, Teck does not currently have sufficient data to determine whether there is economic resource on oil sands leases acquired by Teck. Assuming that sufficient data could be acquired to assess whether the south oil sands leases have economic resource, and further discussions could be undertaken with Aboriginal communities in Fort Chipewyan regarding the options to the north: a. Considering potential alternate placement to the north and south, provide at least two alternatives to the current location of these facilities. b. Assess the effects of each these alternatives on terrestrial and aquatic resources, incorporating all available information. c. Compare and contrast the environmental effects associated with the current locations and the alternative locations. d. If options exist to the south that could minimize old growth loss, discuss Teck s willingness to undertake delineation work to determine whether economic resource would be sterilized. e. If options exist to the north, discuss Teck s willingness to present the alternatives to the Aboriginal communities in Fort Chipewyan to see whether the current location is still preferred. Response 52 a. As discussed in the response to AER Round 3 SIR 1, Teck intends to optimize the Frontier Project to realize the full potential of the asset exchange with Shell. This will include expanding the Main pit to the south, which will eliminate the option of shifting other Project components to this location. In its quarterly update to the Canadian Environmental Assessment Agency (CEAA) (May 13, 2014), Shell indicated that it intends to update its PRM application to include an additional area of oil sands lease October 2014 ESRD/CEAA Page 257

260 ESRD and CEAA Responses Terrestrial Frontier Oil Sands Mine Project (OSL 352). These changes are physical constraints that preclude placement of Project components to the south. With respect to locations to the north, it is desirable to limit disturbance north of the Project to the extent practical for the following reasons: Teck made a commitment to potentially affected Aboriginal communities not to place tailings in the Ronald Lake catchment because it drains north to Lake Claire in Wood Buffalo National Park (WBNP) instead of to the Athabasca River like other oil sands mine developments. Most of the Ronald Lake bison herd range is north of the Project assessment area (PAA). Woodland caribou (a threatened SARA-listed species) are known to transit the area north of the PAA (for details, see the response to ESRD/CEAA Round 3 SIR 87). Environmentally Significant Area 692 begins near the PAA and extends to the north. Locations to the north are operationally sub-optimal (i.e., they would require longer hauls and pumping of tailings). Given these constraints, Teck expects that Project components such as the external tailings area (ETA) will require clearing of some old growth forest. The amount of old growth forest impacted is minimized by the commitments and limitations described above. b. See the response to part a. c. See the response to part a. d. See the response to part a. e. See the response to part a. Question 53 SIR2 Response 86, Page 222. The original question identifies that Teck states that they did not rank each ecosite phase and vegetation cover class for biodiversity potential because the number of vegetation species located within a given vegetation type was directly related to the number of times the vegetation type was sampled (see Volume 2, Section 8.3.5, Table 8-13, Page 8-54). The fact that species lists increased with each additional sample is an indication that insufficient sampling occurred to approach the limit, or actual species diversity within each ecosite, To address this, Teck was asked to Provide Teck s plan to augment the data set with additional field data to ensure species diversity estimates by ecosite phase are reliable. ESRD/CEAA Page 258 October 2014

261 Frontier Oil Sands Mine Project ESRD and CEAA Responses Terrestrial Teck responds that Teck believes that the existing dataset is adequate to inform the Integrated Application. Field data will continue to be collected to improve the understanding of biodiversity in the revised terrestrial LSA. Teck does not provide support for this opinion or describe why it believes that the existing dataset is sufficient to inform the integrated application, particularly as the data themselves indicate that sampling was insufficient to inform the limit, or actual species diversity within each ecosite. a. Provide science-based support for Teck s belief that the existing dataset is sufficient to inform the despite clear science-based evidence that the sampling undertaken is insufficient to approach the limit or actual species diversity within each ecosite. Teck further states that Teck supports the following organizations that seek to gain a better understanding of regional biodiversity: The Alberta Biodiversity Monitoring Institute The Joint Canada-Alberta Implementation Plan for Oil Sands Monitoring The Canadian Oil Sands Innovation Alliance (COSIA) It is expected that additional guidance regarding biodiversity monitoring, evaluation and action levels will be provided in the Biodiversity Framework for the Lower Athabasca Regional Plan, which is expected to be released in Teck s baseline data with respect to this are intended to inform Teck and the application process at the LSA scale. The above-noted initiatives while positive, do not currently operate, and are unlikely to operate in the future, at the Project scale. b. Provide Teck s plan to augment the data set with additional field data to ensure species diversity estimates by ecosite phase are reliable and available to inform Teck s assessment conclusions, monitoring, adaptive management process, and closure targets and goals associated with biodiversity. Describe a schedule, sampling intensity, and how Teck will determine sufficient sampling has been undertaken to describe species diversity in support of the above. Response 53 a. There are 29 vegetation types identified in the revised terrestrial LSA. Vegetation types present in the revised LSA were sampled to support the ; the number of sites and number of species found are listed in Table 53a-1. On average, 20 sites were visited in each vegetation type, and the number of sites sampled ranged from 1 to 51 (see Table 53a-1). This information was presented previously as part of the (see Volume 2, Section 8.3.5, Table 8-13, Page 8-54) and it was noted that as would be expected, the total number of species and species identified to genus found in each ecosite phase or wetland class increases as the number of sites examined increases. This statement does not suggest that sampling was inadequate, but simply that additional species will likely be found as more sites are visited in a given vegetation type. October 2014 ESRD/CEAA Page 259

262 ESRD and CEAA Responses Terrestrial Frontier Oil Sands Mine Project An effective way to determine whether vegetation types have been adequately sampled in a local area is to examine site-species curves. Site-species curves document the pattern of new species found as additional sites are examined. Site-species curves for the vegetation types present in the revised terrestrial LSA are provided in Figures 53a-1 to 53a-29. Note that the axes for Figure 53a-1 to 53a-29 differ among vegetation types. Site-species curves for all vegetation types in the revised terrestrial LSA tend to plateau when 5 to 7 sites have been sampled. Those that did not plateau are ecosite phase b3, upland grassland and upland shrubland (see Figures 53a-4, 53a-18 and 53a-19). Each of these vegetation types represents less than 1% of the revised terrestrial LSA. Based on the site-species curves presented, it is Teck s belief that the vegetation data collected in support of the is sufficient to characterize species that typically are found in association together (i.e., ecosite phases and wetland classes) in the revised terrestrial LSA. b. Based on the sampling completed to support the (see the response to part a), Teck has adequately defined baseline conditions. However, as discussed in the response to AER Round 3 SIR 1, Teck plans to undertake a Project Update to incorporate opportunities associated with the Teck Shell asset exchange. Changes in the PDA may require the collection of additional vegetation samples that will be identified and incorporated into an updated baseline study for the Project. In addition, it is anticipated that additional vegetation data will be collected in the future to support follow-up and monitoring programs that will be required as part of the anticipated EPEA approval for the Project. Teck will be in a position to provide details about the timing and extent of these programs once the anticipated EPEA approval requirements are available. ESRD/CEAA Page 260 October 2014

263 Frontier Oil Sands Mine Project ESRD and CEAA Responses Terrestrial Table 53a-1 Ecosite Phase and Wetland Class Species Distribution Ecosite Phase or Wetland Class Upland Ecosite Phases Number of Sites Sampled Total Vascular Species Richness a1: Jack pine/lichen b1: Jack pine aspen/blueberry b2: aspen white birch /blueberry b3: aspen white spruce/blueberry 3 55 b4: white spruce Jack pine/blueberry c1: mesic Jack pine black spruce/labrador tea 7 49 d1: aspen/low-bush cranberry d2: aspen-white spruce/low-bush cranberry d3: white spruce-aspen/low bush cranberry e1: balsam poplar aspen/dogwood e2: balsam poplar white spruce/dogwood e3: white spruce/dogwood f1: balsam poplar-aspen/horsetail f2: balsam poplar-white spruce/horsetail f3: white spruce/horsetail g1:subhygric black spruce Jack pine/labrador tea 8 47 h1: white spruce-black spruce/labrador tea Upland grassland 1 26 Upland shrubland 1 39 Wetland Classes Forested and wooded bogs without internal lawns (BFNN) Nonpatterned, open, graminoid-dominated fens (FONG) Nonpatterned, open, shrub-dominated fens (FONS) Nonpatterned, wooded fens with no internal lawns (FTNN) Marshes (MONG) Shrubby swamps (SONS) Forested and wooded coniferous swamp (SFNNcs/STNNcs) Forested and wooded hardwood swamp (SFNNhs/STNNhs) Forested and wooded mixedwood swamp (SFNNms/STNNms) 7 78 Shallow open water (WONN) 7 92 October 2014 ESRD/CEAA Page 261

264 ESRD and CEAA Responses Terrestrial Frontier Oil Sands Mine Project Cumulative Number of Species Ecosite Phase a Number of Sites Total Number of Sites = 20 Total Number of Species = 46 Figure 53a-1 Site-Species Curve for Ecosite Phase a1 Cumulative Number of Species Ecosite Phase b Number of Sites Total Number of Sites = 37 Total Number of Species = 115 Figure 53a-2 Site-Species Curve for Ecosite Phase b1 Cumulative Number of Species Ecosite Phase b Number of Sites Total Number of Sites = 11 Total Number of Species = 54 Figure 53a-3 Site-Species Curve for Ecosite Phase b2 ESRD/CEAA Page 262 October 2014

265 Frontier Oil Sands Mine Project ESRD and CEAA Responses Terrestrial Cumulative Number of Species Ecosite Phase b Number of Sites Total Number of Sites = 3 Total Number of Species = 55 Figure 53a-4 Site-Species Curve for Ecosite Phase b3 Cumulative Number of Species Ecosite Phase b4 Total Number of Sites = 10 Total Number of Species = Number of Sites Figure 53a-5 Site-Species Curve for Ecosite Phase b4 Cumulative Number of Species Ecosite Phase c1 Total Number of Sites = 7 Total Number of Species = Number of Sites Figure 53a-6 Site-Species Curve for Ecosite Phase c1 October 2014 ESRD/CEAA Page 263

266 ESRD and CEAA Responses Terrestrial Frontier Oil Sands Mine Project Cumulative Number of Species Ecosite Phase d1 Total Number of Sites = 43 Total Number of Species = Number of Sites Figure 53a-7 Site-Species Curve for Ecosite Phase d1 Cumulative Number of Species Ecosite Phase d2 Total Number of Sites = 46 Total Number of Species = Number of Sites Figure 53a-8 Site-Species Curve for Ecosite Phase d2 Cumulative Number of Species Ecosite Phase d3 Total Number of Sites = 13 Total Number of Species = Number of Sites Figure 53a-9 Site-Species Curve for Ecosite Phase d3 ESRD/CEAA Page 264 October 2014

267 Frontier Oil Sands Mine Project ESRD and CEAA Responses Terrestrial Cumulative Number of Species Ecosite Phase e1 Total Number of Sites = 36 Total Number of Species = Number of Sites Figure 53a-10 Site-Species Curve for Ecosite Phase e1 Cumulative Number of Species Ecosite Phase e2 Total Number of Sites = 17 Total Number of Species = Number of Sites Figure 53a-11 Site-Species Curve for Ecosite Phase e2 Cumulative Number of Species Ecosite Phase e3 Total Number of Sites = 15 Total Number of Species = Number of Sites Figure 53a-12 Site-Species Curve for Ecosite Phase e3 October 2014 ESRD/CEAA Page 265

268 ESRD and CEAA Responses Terrestrial Frontier Oil Sands Mine Project Cumulative Number of Species Ecosite Phase f1 Total Number of Sites = 11 Total Number of Species = Number of Sites Figure 53a-13 Site-Species Curve for Ecosite Phase f1 Cumulative Number of Species Ecosite Phase f Number of Sites Total Number of Sites = 16 Total Number of Species = 124 Figure 53a-14 Site-Species Curve for Ecosite Phase f2 Cumulative Number of Species Ecosite Phase f3 Total Number of Sites = 7 Total Number of Species = Number of Sites Figure 53a-15 Site-Species Curve for Ecosite Phase f3 ESRD/CEAA Page 266 October 2014

269 Frontier Oil Sands Mine Project ESRD and CEAA Responses Terrestrial Cumulative Number of Species Ecosite Phase g1 Total Number of Sites = 8 Total Number of Species = Number of Sites Figure 53a-16 Site-Species Curve for Ecosite Phase g1 Cumulative Number of Species Ecosite Phase h1 Total Number of Sites = 18 Total Number of Species = Number of Sites Figure 53a-17 Site-Species Curve for Ecosite Phase h1 Cumulative Number of Species Ecosite Phase Upland Grassland Total Number of Sites = 1 Total Number of Species = Number of Sites Figure 53a-18 Site-Species Curve for Ecosite Phase Upland Grassland October 2014 ESRD/CEAA Page 267

270 ESRD and CEAA Responses Terrestrial Frontier Oil Sands Mine Project Cumulative Number of Species Ecosite Phase Upland Shrubland Number of Sites Total Number of Sites = 1 Total Number of Species = 39 Figure 53a-19 Site-Species Curve for Ecosite Phase Upland Shrubland Cumulative Number of Species Wetland Class BFNN/BTNN Total Number of Sites = 24 Total Number of Species = Number of Sites Figure 53a-20 Site-Species Curve for Wetland Class BFNN/BTNN Cumulative Number of Species Wetland Class FONG Total Number of Sites = 14 Total Number of Species = Number of Sites Figure 53a-21 Site-Species Curve for Wetland Class FONG ESRD/CEAA Page 268 October 2014

271 Frontier Oil Sands Mine Project ESRD and CEAA Responses Terrestrial Cumulative Number of Species Wetland Class FONS Total Number of Sites = 24 Total Number of Species = Number of Sites Figure 53a-22 Site-Species Curve for Wetland Class FONS Cumulative Number of Species Wetland Class FTNN Total Number of Sites = 35 Total Number of Species = Number of Sites Figure 53a-23 Site-Species Curve for Wetland Class FTNN Cumulative Number of Species Wetland Class MONG Total Number of Sites = 31 Total Number of Species = Number of Sites Figure 53a-24 Site-Species Curve for Wetland Class MONG October 2014 ESRD/CEAA Page 269

272 ESRD and CEAA Responses Terrestrial Frontier Oil Sands Mine Project Cumulative Number of Species Wetland Class SONS Total Number of Sites = 47 Total Number of Species = Number of Sites Figure 53a-25 Site-Species Curve for Wetland Class SONS Cumulative Number of Species Wetland Class SFNNcs and STNNcs Total Number of Sites = 51 Total Number of Species = Number of Sites Figure 53a-26 Site-Species Curve for Wetland Class SFNNcs/STNNcs Cumulative Number of Species Wetland Class SFNNhs and STNNhs Total Number of Sites = 32 Total Number of Species = Number of Sites Figure 53a-27 Site-Species Curve for Wetland Class SFNNhs/STNNhs ESRD/CEAA Page 270 October 2014

273 Frontier Oil Sands Mine Project ESRD and CEAA Responses Terrestrial Cumulative Number of Species Wetland Class SFNNms and STNNms Total Number of Sites = 7 Total Number of Species = Number of Sites Figure 53a-28 Site-Species Curve for Wetland Class SFNNms/STNNms Cumulative Number of Species Wetland Class WONN Total Number of Sites = 7 Total Number of Species = Number of Sites Figure 53a-29 Site-Species Curve for Wetland Class WONN October 2014 ESRD/CEAA Page 271

274 ESRD and CEAA Responses Terrestrial Frontier Oil Sands Mine Project ESRD/CEAA Page 272 October 2014

275 Frontier Oil Sands Mine Project ESRD and CEAA Responses Terrestrial 5.5 Wildlife Question 54 SIR2 Response 87, Page Teck states that It is expected that wildlife will move to other habitats adjacent to the PAA (see Figure 87a-1), and those areas will be used for maintaining ungulate energy reserves, body condition and reproductive potential. Teck is also states that Thermal and hiding cover and habitat wildlife use for foraging and calving will be maintained in areas of the KWBZ surrounding the PAA during Project operations. This suggests that the habitat adjacent to the PAA will be sufficient to maintain wildlife populations at the present levels despite the proposed KWBZ habitat disturbance through time associated with the proposed Project. Further, Figure 87a-1 does not include other development proposed within the KWBZ, which will also influence the utility of the KWBZ and its effectiveness in maintaining current populations. Teck also states that As part of reclamation planning for the Frontier Project, Teck will strive to achieve the desired outcomes of the KWBZ. a. The habitat identified outside the PAA is currently supporting wildlife. Teck s references to it seem to suggest wildlife in the Project area will move into these adjacent habitats and be supported at an increased density despite the proposed KWBZ habitat deletion through time associated with the proposed Project. If so, provide literature and/or data that would support this conclusion. b. Because the temporal scale of the Project spans multiple generations of wildlife, identify how this increased density will be supported through time. Discuss inter-specific and intra-specific interactions and the ongoing capacity of the smaller habitat area to support these populations. c. Discuss the uncertainty associated with the assessment predictions and the resilience of the ecological systems that will be affected by the Project. What is the likelihood that an alternate stable-state will result which will influence whether populations will re-establish in the reclaimed habitat? d. Because development in the MOSA will overlap both spatially and temporally with respect to habitat use by local wildlife, provide a discussion of the uncertainty associated with the cumulative effects on wildlife associated with the Project. Include a robust discussion of resilience referencing the primary literature to support the discussion. e. Discuss how these predictions are consistent with current monitoring data and lessons learned by other mines in the MOSA. Where predictions are not supported by current monitoring data, adjust the predictions appropriately. October 2014 ESRD/CEAA Page 273

276 ESRD and CEAA Responses Terrestrial Frontier Oil Sands Mine Project f. Discuss how these predictions are consistent with modelling used to inform land use planning under LARP, and the Terrestrial Ecosystem Management Framework. Specifically discuss the dose-response curves and whether Teck s assessment conclusions are consistent with the associated predictions. If Teck s assessment conclusions are not consistent, adjust the conclusions or provide a robust explanation for the inconsistency referencing established ecological principles and peer-reviewed literature. Response 54 a. In its response to ESRD/CEAA Round 2 SIR 87, Teck did not make the assumption that the habitat adjacent to the PAA was sufficient to maintain wildlife populations. As stated in ESRD/CEAA Round 2 SIR 87b: It is expected that wildlife will move to other habitats adjacent to the PAA (see Figure 87a-1), and those areas will be used for maintaining ungulate energy reserves, body condition and reproductive potential. In addition to these habitats, there are also other suitable habitats within the RSA and beyond that may be used by far-ranging species. Results from the Wildlife Habitat Effectiveness and Connectivity (WHEC) program (Bohm et al. 2012) indicated that moose are using habitat adjacent to mine sites (particularly near river valleys). Moose are one of the species targeted by the Key Wildlife and Biodiversity Zones (KWBZ), and these results suggest that moose will likely use habitat east of the PAA, between the PAA and the Athabasca River. As part of the Project s wildlife mitigation and monitoring plan, Teck anticipates that residual habitats within Teck s leases and outside the PAA will be monitored for wildlife use (including habitat between the PAA and the Athabasca River). Because of a lack of information about the carrying capacity of the wildlife populations near the Project, it is challenging to make conclusions about potential density effects on species (i.e., either through inter- or intra-specific competition). Teck acknowledges (and has identified in the assessment) that there is the potential for effects, particularly during Project operation. Therefore, Teck intends to monitor changes in the relative abundance of target species over the life of the Project in both residual habitat and reclaimed landscapes. Teck understands that habitat usage and species displacement is of strong interest to Aboriginal communities. Teck wishes to work collaboratively with Aboriginal communities to better understand and integrate traditional knowledge related to wildlife habitat. Teck had previously committed to initiate development of the wildlife mitigation and monitoring plan for the Project in 2014 in conjunction with regulators and potentially affected Aboriginal communities. As Teck is currently preparing a Project Update (see the response to AER Round 3 SIR 1), development of the wildlife mitigation and monitoring plan will be delayed. Teck is delaying development of the wildlife mitigation and monitoring plan to allow for a design that will better reflect the updated Project. ESRD/CEAA Page 274 October 2014

277 Frontier Oil Sands Mine Project ESRD and CEAA Responses Terrestrial b. Teck acknowledges that the Project will span multiple generations of wildlife; however, it will also span multiple stages of reclamation on adjacent mines, linear disturbances, recovery from natural disturbances and logging. In addition, there will be changes in seral stages in undisturbed habitats in the region. Reclamation is expected to provide functional habitat for wildlife populations over time, keeping in mind that different species prefer different seral stages. As such, species habitat use and distribution is also expected to change over time. As discussed in part c, the boreal forest is constantly changing due to natural disturbances, which in turn influence wildlife abundance and distribution. Because habitat is not confined by the study area boundaries or the boundaries of the KWBZ, it is difficult to assume that densities will change in a particular area. In addition, there is no information available that would indicate that existing regional populations are at or near carrying capacity, where changes in density may have a greater effect on the populations. As discussed in part a, Teck will monitor wildlife abundance and distribution over the life of the Project in habitat adjacent to the PAA and within Teck s leases. c. See the responses to ESRD/CEAA Round 3 SIRs 62, 63 and 67 for a discussion of uncertainty and resilience with respect to reclamation and use of reclaimed habitats by wildlife. As part of the wildlife mitigation and monitoring plan discussed in part a, Teck has committed to implementing a follow-up program that will test assessment predictions. As part of this commitment, Teck will: identify specific targets or performance benchmarks for wildlife habitat use and the successful recolonization of disturbed landscapes by wildlife incorporate actual end land use and wildlife recolonization measures in the wildlife mitigation and monitoring plan, including a direct comparison of results with baseline conditions consult with potentially affected Aboriginal communities and incorporate input from these discussions into monitoring programs address the need for specific details and information about wildlife health, which is important for continued traditional land use by Aboriginal communities discuss and consider of the effects of ecosystem shifts on reclamation success, prediction confidence and wildlife recolonization in the terrestrial LSA and vegetation and wildlife regional study area (RSA) d. Teck has included a Planned Development Case (PDC) that complies with the terms of reference for the Project and that contemplated all reasonably foreseeable developments in assessing cumulative effects in the vegetation and wildlife RSA, which fully includes the mineable oil sands area (MOSA). Existing disturbances, along with all developments and activities identified in Volume 3, Section 1, Appendix 1C, were included as disturbed land in each of the assessment cases (i.e., Base Case, Application Case and PDC). In addition, as part of the wildlife assessment and overall cumulative effects assessment, Teck included future forest fire modelling following methods used by CEMA (see October 2014 ESRD/CEAA Page 275

278 ESRD and CEAA Responses Terrestrial Frontier Oil Sands Mine Project Volume 6, Section , Pages 3-29 to 3-32) as well as the best available information on future forest harvesting activities (see Volume 6, Section , Pages 3-46 to 3-47). All of these disturbances can have a variety of direct and indirect effects on wildlife habitat use, abundance and distribution. Teck considered all of these inputs in assessing potential cumulative effects on wildlife (spatially and temporally). In addition, Teck estimated prediction confidence as part of the assessment conclusions to discuss any uncertainty associated with predicted effects at maximum build-out. In determining prediction confidence, Teck also addressed uncertainty with respect to climate change and its potential effects on wildlife. Teck acknowledges that some degree of uncertainty exists with its effects predictions; however, models are commonly used in EIAs and are considered necessary to guide reclamation planning in the oil sands region, particularly as it relates to wildlife habitat (Welham et al. 2012). For existing and proposed developments in the vegetation and wildlife RSA, Teck was restricted to using available information. Teck acknowledges that cumulative disturbance and cumulative reclamation in the oil sands region will change during the life of the Project, beyond what is predicted for the PDC. However, Teck assumes that predicted effects are likely to remain consistent (see the response to ESRD/CEAA Round 1 SIR 462). Combining the existing and proposed developments, with the predicted habitat changes expected from forestry and forest fires, provided a clearer understanding of potential effects on wildlife in the region. Teck acknowledges that any landscape affected by natural or anthropogenic disturbance will exhibit changes (spatial and temporal) in wildlife habitat use, distribution and abundance. This is typical of the boreal forest, which is a dynamic landscape, mainly because of the effects of fire on forest structure and age. Studies that compare natural ecosystems to those affected by disturbance (e.g., reclaimed sites), particularly in terms of their resilience to disturbance, are currently underway by multiple groups in the oil sands region (e.g., Pyper et al. 2013; Welham 2013). Results of these studies will add to the understanding of the resilience of the landscape, including wildlife populations, and the uncertainty around future use. For further discussion about resilience, see the responses to ESRD/CEAA Round 3 SIR 63 and SIR 67. e. Teck is unable to obtain existing monitoring data from other oil sands developments; this information is typically included in annual reports submitted by oil sands operators to Alberta Environment (now the Alberta Energy Regulator) and is not widely available. However, as discussed in Volume 6, Section , Pages 3-55 to 3-57, data from CEMA s long-term monitoring plots indicate that, for the most part, reclaimed oil sands sites appear to be moving toward natural ecosystems. As stated in Volume 6, Section : From a site-productivity perspective, preliminary measures from older monitoring plots indicate that early tree growth on reconstructed soils is comparable to growth rates of trees on natural soils, although the long-term sustainability of this growth is still in question (Timberline Natural ESRD/CEAA Page 276 October 2014

279 Frontier Oil Sands Mine Project ESRD and CEAA Responses Terrestrial Resource Group 2008). Long-term monitoring plots document that, for the most part, reclaimed oil sands sites appear to be developing into ecosystems with similar plant community composition and nutrient availability to those which occur naturally (see Rowland et al for an evaluation of long-term reclamation monitoring data). However, from a community-succession perspective, the diversity of plants on sites with reconstructed peat/mineral mix soils still remains well below natural site levels when these young reclaimed stands are compared to more mature natural sites (Stantec 2009). For additional discussion regarding novel ecosystems, see the response to ESRD/CEAA Round 1 SIR 473. Empirical data are available that demonstrate successful vegetation establishment and growth in the oil sands region, based on research and long-term reclamation monitoring completed by CEMA (see Volume 6, Section , Pages 3-55 to 3-57 and the response to ESRD/CEAA Round 1 SIR 216). Teck acknowledges that empirical data specifically documenting the successful reclamation of wildlife habitat in the oil sands region, including use of habitat, are more limited. As described in Hawkes and Tuttle (2011), CEMA initiated a pilot program to monitor wildlife in early successional habitats on reclaimed landscapes. The program focused on setting standards upon which to base longer term monitoring, and identifying wildlife groups that would indicate whether reclaimed ecosystems satisfy land use objectives (Hawkes and Tuttle 2011). For the pilot program, work was done to determine the appropriate methods for the following surveys for use on reclaimed sites: small mammal trapping, winter track surveys and songbird surveys. A variety of species were observed during the pilot program, including moose, snowshoe hare, deer mouse, red squirrel, red fox, and 48 bird species. Because initial work focused on determining appropriate survey methods for assessing wildlife use, comparisons are not yet available between plots in natural habitats, although they are recommended for future programs. AENV (2010) summarizes wildlife monitoring of reclaimed landscapes in Suncor s Lease 86/17 that has occurred since Wildlife use was examined using methods such as winter track counts, browse-pellet surveys, small mammal surveys, remote camera programs, breeding bird surveys and amphibian surveys among others. Winter tracking results have shown that a variety of wildlife species use reclaimed landscapes, including moose, fisher/marten, Canada lynx, and deer. However, the abundance of typical boreal species (i.e., moose, lynx, fisher) is much higher in natural forests. Generally, species that prefer young seral habitats (i.e., deer, coyote, deer mice, song sparrow, claycolored sparrow) are found more commonly in recently reclaimed landscapes. Teck has provided further information related to wildlife use of reclaimed sites in the response to ESRD/CEAA Round 3 SIR 63. f. See the discussion on the Lower Athabasca Regional Plan (LARP) and the Terrestrial Ecosystem Management Framework (TEMF) modelling process and predictions provided in response to ESRD/CEAA Round 3 SIR 67. October 2014 ESRD/CEAA Page 277

280 ESRD and CEAA Responses Terrestrial Frontier Oil Sands Mine Project REFERENCES AENV (Alberta Environment) Guidelines for Reclamation to Forest Vegetation in the Athabasca Oil Sands Region, 2nd Edition. Prepared by the Terrestrial Subgroup of the Reclamation Working Group of the Cumulative Environmental Management Association, Fort McMurray, Alberta. Bohm, H., E. Neilson, B. Thomas, S. Boutin and C. De La Mare Wildlife Habitat Effectiveness and Connectivity Program Annual Report University of Alberta, Edmonton, Alberta. Hawkes, V.C. and K.N. Tuttle Early Successional Wildlife Monitoring on Reclaimed Plots in the Oil Sand Region. Year Annual Report. LGL Report EA3248. Unpublished report by LGL Limited environmental research associates, Sidney, B.C. for CEMA The Reclamation Working Group (RWG), Fort McMurray, Alberta. Pyper, M.P., C.B. Powter and T. Vinge Summary of Resiliency of Boreal Forest. Landscapes Seminar, Oil Sands Research and Information Network. University of Alberta. School of Energy and Environment, Edmonton Alberta. OSRIN Report TR- 30. Available: Rowland, S.M., C.E. Prescott, S.J. Grayston, S.A. Quideau and G.E. Bradfield Recreating a functional forest soil in reclamation oil sands in northern Alberta: an approach for measuring success in ecological restoration. Journal of Environmental Quality 38: Stantec (Stantec Consulting Ltd.) Results from Long Term Soil and Vegetation Plots Established in the Oil Sands Region (2009). Prepared for Cumulative Environmental Management Association, Fort McMurray, Alberta and other annual reports (2001 through 2008). Timberline Natural Resource Group Ltd Analyzing and Relationship between LCCS Ratings and Site Productivity. Cumulative Environmental Management Association, Fort McMurray, Alberta. Welham, C Factors Affecting Ecological Resilience of Reclaimed Oil Sands Uplands. Oil Sands Research and Information Network, University of Alberta, School of Energy and the Environment, Edmonton, Alberta. OSRIN Report No. TR-34. Welham, C., J. Blanco, B. Seely and C. Bampflyde Oil sands reclamation and the projected development of wildlife habitat attributes. In D. Vitt and J. Bhatti [eds.]. Restoration and Reclamation of Boreal Ecosystems: Attaining Sustainable Development. Cambridge University Press, pp ESRD/CEAA Page 278 October 2014

281 Frontier Oil Sands Mine Project ESRD and CEAA Responses Terrestrial Question 55 SIR2 Response 89, Page 234 Teck was asked to update the LSA and Application Case Assessment to include all planned Project disturbances, including all viable options presented for Project components including option 3 for the Raw Water Intake, if option 3 is still part of this application. a. Update the LSA and Application Case assessment to include option 3 for the Raw Water Intake as requested. Response 55 a. As discussed in the response to AER Round 3 SIR 1, Teck intends to update the for the Project to: recover additional resource from leases acquired from Shell during the Teck Shell asset exchange optimize the tailings management strategy in consideration of the current state of engineering practice and improved understanding of site-specific conditions reflect additional engineering studies and information obtained from Shell as part of the asset exchange consider input received from regulators and potentially affected Aboriginal communities during the review process Items identified in this SIR will be considered in the Project Update because Option 3 is now the selected option for the river water intake. Question 56 SIR2 Response 90, Page Teck undertook bird surveys late in the survey season. Teck was asked to comment on the appropriateness of the timing for target species and special status songbirds if they do occur. Teck states that Due to the number of avian species of management concern surveyed during a breeding bird survey, the use of the window described in the response to part c is appropriate for baseline surveys that support assessments. a. Provide further discussion to support the statement that the number of species of management concern identified is suggestive of sufficient survey effort and appropriate timing. October 2014 ESRD/CEAA Page 279

282 ESRD and CEAA Responses Terrestrial Frontier Oil Sands Mine Project b. It is generally recommended that surveys be done twice, early and later, during the timing window to note early species as well as late species. Provide a plan to undertake additional baseline surveys earlier in the optimal window to confirm the conclusion that the late surveys appropriately characterize the presence of species of management concern. Response 56 a. As described in ESRD/CEAA Round 2 SIR 90c and SIR 90d, the 2012 breeding bird survey conducted for the Project was completed within the survey window for breeding songbirds and woodpeckers in the boreal region of Alberta as recommended by ESRD (2013; June 1 to July 7) and the Canadian Wildlife Service (2007; May 28 to July 7). The level of effort for the breeding bird surveys, conducted prior to the release of ESRD (2013), aligned with standard practices for EIAs in the oil sands region as well (i.e., one breeding bird survey per season). Although the survey was completed towards the end of the recommended window (i.e., June 29 to July 7), the breeding bird survey overlapped with the breeding window of songbird species of management concern (see ESRD/CEAA Round 2 SIR 90 Table 90c-1). In addition, the number of species of management concern observed during the 2012 survey is similar to that observed during previous surveys in the Project area that were completed earlier in the survey window (see Table 56a-1). Table 56a-1 Species of Management Concern Observed during Breeding Bird Surveys Year Survey Dates Number of Species of Management Concern 1 Observed 2012 June 29 to July June 10 to June June 18 to June 22 9 NOTE: 1 As defined by ESRD (2010) and Government of Canada (2012). Although these breeding bird surveys were conducted at different times within the recommended surveys window, the results are similar in terms of the number of species of management concern observed and the species. For instance, seven of the nine species observed in 2012 were previously observed in either 2008 or 2010 (i.e., pileated woodpecker, western wood-pewee, least flycatcher, black-throated green warbler, Canada warbler, common yellowthroat, western tanager). As ESRD/CEAA Round 2 SIR 90e requested comment on the appropriateness of the breeding bird survey as it related to detecting target species and species of management concern, it is Teck s opinion that the timing of the 2012 survey was acceptable. ESRD/CEAA Page 280 October 2014

283 Frontier Oil Sands Mine Project ESRD and CEAA Responses Terrestrial b. Teck plans to conduct preconstruction surveys before starting early works to support the wildlife mitigation and monitoring plan that will be developed for the Project. Preconstruction surveys will focus on breeding songbirds and woodpeckers and will consist of two visits one early and one late within the survey window recommended by ESRD (2013; June 1 to July 7). REFERENCES Canadian Wildlife Service Instructions for Conducting the Breeding Bird Survey (BBS). Available at: Accessed April ESRD (Alberta Environment and Sustainable Resource Development) The General Status of Alberta Wild Species Alberta Fish and Wildlife Management Division. Edmonton, Alberta. Available at: GeneralStatusofAlbertaWildSpecies2010/Search.aspx. ESRD Sensitive Species Inventory Guidelines. Alberta Environment and Sustainable Resource Development, Government of Alberta. Available at: WildlifeManagement/SensitiveSpeciesInventoryGuidelines.aspx. Accessed April Government of Canada Species at Risk Public Registry. Last updated April 10, Available at: Accessed August Question 57 SIR2 Response 92, Page Teck was asked to provide evidence to support its statement that It is unlikely that wolves, moose and white-tailed deer would move into the Red Earth range to the west as the habitat is unsuitable for both moose and deer (i.e., primarily peatlands). Teck s response is based on habitat suitability modelling and the proportion of suitable habitat present for caribou, moose and deer. This would seem an oversimplification and does not draw on data available for ranges such as the CLAWR and ESAR. a. Undertake a similar assessment for the CLAWR and ESAR ranges and compare the results to Teck s Red Earth rationale. b. Identify whether Teck s habitat-based conclusion holds. c. If Teck s conclusion holds, explain how it is consistent with the declines exhibited by woodland caribou in the CLAWR and ESAR. If Teck s conclusion does not hold, adjust it as appropriate. October 2014 ESRD/CEAA Page 281

284 ESRD and CEAA Responses Terrestrial Frontier Oil Sands Mine Project Response 57 a. In boreal regions, caribou and other ungulate species (e.g., moose, deer) typically occupy opposing habitats (i.e., peatlands versus uplands and disturbed sites) year round (James et al. 2004). These patterns of habitat selection are fundamental to the widely supported theory of spatial separation, which explains coexistence among these species and their predators (Bergerud et al. 1984; Seip 1992). Teck s position that peatlands are low quality or unsuitable habitat for alternate prey species of wolves (e.g., moose, deer) is founded on prevailing research from caribou ranges throughout northeastern Alberta (e.g., James et al. 2004) and eastern boreal systems (Dussault et al. 2006; Poley et al. 2014). Recent literature supports this observation for the East Side Athabasca River (ESAR) (Latham 2009; Wasser et al. 2011; Latham et al. 2013) and areas adjacent to the Cold Lake Air Weapons Range (CLAWR) (Fisher et al. 2013), particularly for white-tailed deer. In northeastern Alberta, evidence suggests that spatial separation of wolves and caribou occurs even though the primary prey of wolves may have switched from moose (James et al. 2004) to white-tailed deer, especially during winter (Latham et al. 2011, 2013). Data from the ESAR and West Side Athabasca River (WSAR) ranges indicate that more than 70% of white-tailed deer sightings occurred in upland habitat in both summer and winter, while around 80% of caribou observations were in peatlands (Latham et al. 2013). This observation was shared by Wasser et al. (2011), who describe a strong negative correlation between caribou and deer habitat selection in the ESAR range. Similarly, Fisher et al. (2013) states that deer occurrence near the CLAWR was best explained by the percentage of upland deciduous habitat and the percent of human footprint. The study concludes that white-tailed deer selected early seral habitat associated with anthropogenic disturbance over all other habitat. Latham et al. (2013) suggests that increased spatiotemporal overlap between wolves and caribou during summer was explained not by movement of white-tailed deer or moose into peatlands, but by a shift in wolf prey selection towards beaver. b. Based on the information provided in the response to part a, Teck s conclusion holds. Habitat in the Red Earth boreal caribou range (located directly west of the Project) is primarily unfragmented peatland bogs. Therefore, moose and deer are not expected to use that area as much as regions north of the PAA and along the Athabasca River where habitat is predominantly upland. The limited number of linear features connecting the PAA to the northern portion of the Red Earth range provides little incentive for direct movement between the two areas. As a result, the likelihood of increased spatiotemporal overlap between boreal caribou, predators and other ungulates because of Project activities is assumed to be minimal in the eastern portion of the Red Earth herd range. c. Caribou decline in ESAR and CLAWR is linked to numerous stressors that lead to increased mortality and reduced fitness. As with boreal caribou herds throughout Alberta, the main reason for the decline of woodland caribou is increased predation resulting from increases in prey densities (e.g., deer) and corresponding wolf predation rates, including incidental predation on caribou (Latham et al. 2011). The driver for increased risk of predation is not predator and prey selection of peatland habitat; rather, ESRD/CEAA Page 282 October 2014

285 Frontier Oil Sands Mine Project ESRD and CEAA Responses Terrestrial it is the loss and alteration of peatland habitat within caribou ranges coupled with natural and anthropogenic disturbances (Environment Canada 2012). The level of undisturbed habitat within the ESAR and CLAWR ranges is 19% and 15% of their total area when natural and anthropogenic disturbance are considered (Environment Canada 2012). These levels do not meet the boreal caribou recovery strategy minimum disturbance management threshold of 65% undisturbed habitat (Environment Canada 2012). As discussed in the response to part a, intact peatland matrices are not selected by predators (e.g., wolves) and alternate prey species. However, woodland caribou in heavily disturbed ranges, such as the ESAR and CLAWR, are susceptible to increased predation risk, caused indirectly by increased access and alteration of habitat which provides adequate cover and browse for moose and deer. REFERENCES Bergerud, A.T., H.E. Butler and D.R. Miller Antipredator tactics of calving caribou: dispersion in mountains. Canadian Journal of Zoology 62: Dussault, C., R. Courtois and J.P. Ouellet A habitat suitability index model to assess moose habitat selection at multiple spatial scales. Canadian Journal of Forest Research 36: Environment Canada Recovery Strategy for the Woodland Caribou (Rangifer tarandus caribou), Boreal Population, in Canada. Species at Risk Act Recovery Strategy Series. Environment Canada, Ottawa. Fisher, J.T., M. Hiltz, L. Nolan and L.D. Roy Alberta Boreal Deer Project Fiscal Year Report. Alberta Innovates, Technology Futures, Edmonton, Alberta. James, A.R.C., S. Boutin, D.M. Hebert and A.B Rippin Spatial separation of caribou from moose and its relation to predation by wolves. Journal of Wildlife Management 68: Latham, A.D.M Wolf Ecology and Caribou Primary Prey Wolf Spatial Relationships in Low Productivity Peatland Complexes in Northeastern Alberta. PhD thesis, Dept. of Biol. Sci., Univ. of Alberta, Edmonton, Alberta. Latham, A.D.M., M.C. Latham, N.A. McCutchen and S. Boutin Invading white-tailed deer change wolf-caribou dynamics in northeastern Alberta. Journal of Wildlife Management 75: Latham, A.D.M., M.C. Latham, K.H. Knopff, M. Hebblewhite and S. Boutin Wolves, white-tailed deer, and beaver: implications of seasonal prey switching for woodland caribou declines. Ecography 36: Poley, L.G., B.A. Pond, J.A. Schafer, G.S. Brown, J.C. Ray and D.S. Johnson Occupancy patterns of large mammals in the far north of Ontario under imperfect detection and spatial autocorrelation. Journal of Biogeography 41: October 2014 ESRD/CEAA Page 283

286 ESRD and CEAA Responses Terrestrial Frontier Oil Sands Mine Project Seip, D.R Factors limiting woodland caribou populations and their interrelationships with wolves and moose in southeastern British Columbia. Canadian Journal of Zoology 70: Wasser S.K., J.L. Keim, M.L. Taper and R.L. Subhash The influences of wolf predation, habitat loss, and human activity on caribou and moose in Alberta oil sands. Frontiers in Ecology and the Environment 9: Question 58 SIR2 Response 93, Page 255. Teck was asked to: Describe the specific measures that Teck will implement to reduce or eliminate this predicted Project impact on woodland caribou. Teck has identified two approaches: reclamation, and consideration of potential strategies to mitigate or offset effects of the project on wildlife and wildlife habitat, including those related to general habitat connectivity in the region. Reclamation will not occur for decades, will take time to mature into functional caribou habitat and is associated with considerable uncertainty. While both are positive, neither will reduce or eliminate the predicted Project impact on woodland caribou and neither is specific to the predicted project effect noted for the restricted area habitat north of the PAA. a. Describe the specific mitigation measures Teck will implement to reduce or eliminate the predicted increased predation pressure in the restricted area and in the habitat north of the PAA. b. If Teck is not planning to implement specific mitigation measures to reduce or eliminate this effect, clearly state this Response 58 a. Teck does not have the mandate to implement direct measures (e.g., wolf culls) to control predation pressures on caribou. However, Teck can implement habitat restoration measures as part of the Project s wildlife mitigation and monitoring plan that would reduce the travel and hunting efficiencies of predators active in the PAA and surrounding areas. These measures might include, but are not restricted to, reclamation of existing linear disturbances (e.g., mounding, tree planting and distribution of coarse woody debris) to discourage natural predators and hunters from using these corridors. Such measures would focus mostly on portions of Teck s oil sands leases where the PDA overlaps known caribou ranges. The final list of mitigation measures will be based on the anticipated EPEA approval for the Project. ESRD/CEAA Page 284 October 2014

287 Frontier Oil Sands Mine Project ESRD and CEAA Responses Terrestrial Teck had previously committed to initiate development of the wildlife mitigation and monitoring plan for the Project in 2014 in conjunction with regulators and potentially affected Aboriginal communities. As Teck is currently preparing a Project Update (see the response to AER Round 3 SIR 1), development of the wildlife mitigation and monitoring plan will be delayed. Teck is delaying development of the wildlife mitigation and monitoring plan to allow for a design that will better reflect the updated Project. b. See the response to part a. Question 59 SIR2 Response 95, Page Teck indicated that there will be a loss of ha of high quality caribou habitat, 862 ha of moderate quality caribou habitat, and 4,545 ha of low quality caribou habitat from base case to application case at maximum build-out. It was also noted that The Woodland Caribou Policy for Alberta states that maintenance of caribou habitat is the immediate priority and that Caribou conservation is a shared government, public and private sector responsibility, led by government (ESRD 2011). Teck was asked to address the inconsistency between the Project and A Woodland Caribou Policy for Alberta specifically with respect to habitat maintenance. Teck s response identifies that the Project is not located within currently delineated caribou range. This is acknowledged; however, the underlying intent behind both the federal and provincial caribou policies is to recover caribou populations. If the habitat present is supporting caribou, its elimination or disruption has the potential to influence caribou. Teck was also asked how it will adjust the Project mitigation measures proposed to ensure it is not in conflict with the provincial policy and to ensure the response addresses all aspects of the policy, not just habitat availability. In response, Teck identifies reclamation and cooperative participation on COSIA. While both are positive, neither is an adjustment to the project mitigation measures as proposed to ensure it is not in conflict with the provincial policy. a. Address the inconsistency between the Project and A Woodland Caribou Policy for Alberta, specifically with respect to habitat maintenance. b. Describe how Teck will adjust its Project and proposed mitigation measures, to ensure it is not in conflict with the provincial policy. Address all aspects of the policy. October 2014 ESRD/CEAA Page 285

288 ESRD and CEAA Responses Terrestrial Frontier Oil Sands Mine Project Response 59 a. Caribou data provided by ESRD indicate that caribou frequent a small area at the northern tip of the PAA and surrounding habitat (for details, see the response to ESRD/CEAA Round 3 SIR 87). As described in response to ESRD/CEAA Round 3 SIR 87, minimum convex polygon (MCP) and kernel density estimates show that individuals from the Red Earth boreal caribou herd periodically venture beyond the recognized Red Earth range and use the PAA and surrounding habitat. Teck acknowledges that this habitat will be lost during the life of the mine. However, as part of the wildlife mitigation and monitoring plan for the Project, Teck will explore options to restore: previously disturbed caribou habitat in its oil sands leases (OSLs) outside the PAA existing linear disturbances (e.g., through tree planting) Other mitigation options could include: blocking access along existing linear disturbances installing roll-back and vegetation screening considering conservation offsets COSIA, of which Teck is a member company, has initiated two studies aimed at restoring seismic lines in caribou habitat and monitoring the effectiveness of restoration efforts on wildlife use and movement. These studies are: the Algar Historic Restoration Project (formally the Oil Sands Leadership Initiative [OSLI] Algar Caribou Habitat Restoration Program) the Linear Deactivation Project The goal is to restore linear disturbances to a vegetated condition similar to adjacent forests and to reduce access and ease of use for humans and wildlife, thereby increasing functional habitat for caribou. Started in 2010, the Algar Historic Restoration Project is located just southwest of the vegetation and wildlife RSA, within a six-township subregion of the Algar caribou herd range (i.e., Algar Region). The region was subdivided into a five-phase operational zone plan that considered access requirements and operational efficiencies. The program takes a phased approach over five years. The Linear Deactivation Project is largely in the Cold Lake Air Weapons Range. The project design was completed in 2012 with work beginning in 2013 (Cenovus 2014). Work completed to date as part of the Algar Historic Restoration Project is summarized as follows: Field verification and ground reconnaissance of Phase 1 was completed in late This included data collection regarding line geometry, ecosite type, regeneration presence and characteristics, coarse woody material (CWM) presence and source, crossings, accessibility, and operational and logistics information. Based on this information, a detailed plan was developed for site preparation and black spruce planting prescriptions (i.e., soil mixing, mounding, plantings, density and CWM treatments) (for details, see OSLI 2012 and Nexen 2013, 2014). ESRD/CEAA Page 286 October 2014

289 Frontier Oil Sands Mine Project ESRD and CEAA Responses Terrestrial Field verification and ground reconnaissance for Phases 2 and 3 were completed in late Plan implementation began in February 2012 (Phase 1), February 2013 (Phases 2 and 3), and February 2014 (Phase 2 and 3) once operational and logistics work was complete. In 2012, treatments were completed for 75 km of linear disturbance in Phase 1 with 34 km mounded, 67 km treated for CWM, 3 km seeded with Jack pine/white spruce/black spruce and 45,300 black spruce seedlings planted. In 2013, treatments were completed on 36.6 km of linear disturbance in Phase 2 with 25.3 km mounded, 24.6 km treated for CWM and 27,950 black spruce seedlings planted. The amount of treatments completed in 2013 was below expectations because of operational and logistical challenges associated with weather. In 2014, treatments were completed on 98.3 km of linear disturbance in Phase 2 and Phase 3 areas, with 52.7 km mounded, 48.9 km treated for CWM and 54,532 black spruce seedlings planted. A robust monitoring program with appropriate replication has been designed and implemented for the Algar Region. Results to date (Nexen 2014) indicate: 95% survival of seedlings evidence of natural vegetation establishing on mounds (e.g., herbs, forbs and grasses) an increase in overall stocking of lines an increase in CWM presence on treated lines These results suggest that the Algar Caribou Historic Restoration Program should improve wildlife connectivity in the region. These initiatives align with management strategies outlined in LARP, including the timely restoration of linear disturbances where not suitable for re-purposing as approved trails or recreational access routes (GOA 2012, p. 28). It is therefore Teck s view, despite temporary (mining life) loss of caribou habitat in a portion of the PAA, that the activities included in the wildlife mitigation and monitoring plan will address the specific concerns outlined in A Woodland Caribou Policy for Alberta (GOA 2011). These activities will include maintenance and restoration of caribou habitat outside the PAA that are on Teck OSLs, including caribou habitat found outside of the Red Earth caribou range. For areas of temporary habitat loss, the post-mining landscape will be developed with caribou habitat restoration included as a component. b. The Project will have a direct effect on habitat being used by caribou outside of the designated Red Earth range. Development of the North pit is expected to have direct effects on habitat with high and moderate suitability for caribou. Development of the North pit has been considered as part of the Project economics and aligns with Directive 082: Operating Criteria: Resource Recovery Requirements for Oil Sands Mine and Processing Plant Operations (AER 2013). Teck recognizes that caribou conservation is a national priority. It is anticipated that the successes and learnings of work currently underway by COSIA will October 2014 ESRD/CEAA Page 287

290 ESRD and CEAA Responses Terrestrial Frontier Oil Sands Mine Project assist Teck in developing a wildlife mitigation and monitoring plan (see the response to part a). This plan will consider caribou and locations outside the PAA that are on Teck OSLs (i.e., locations north of the North pit). The plan will include mitigation measures focused on maintaining caribou habitat (where possible), restoring disturbed caribou habitat and managing Project influences associated with mortality risk to caribou (direct and indirect). Further details about the wildlife mitigation and monitoring plan are expected to be finalized after the anticipated EPEA approval for the Project is received and the Canadian Environmental Assessment Agency (CEAA) has provided input on the design. The wildlife mitigation and monitoring plan will, in part, be considered a follow-up program that has specific processes defined under the Operational Policy Statement for Assessing Cumulative Environmental Effects under the Canadian Environmental Assessment Act, 2012 (CEAA 2013). REFERENCES AER (Alberta Energy Regulator) Directive 082: Operating Criteria: Resource Recovery Requirements for Oil Sands Mine and Processing Plant Operations. Available at: Accessed June CEAA (Canadian Environmental Assessment Agency) Operational Policy Statement - Assessing Cumulative Environmental Effects under the Canadian Environmental Assessment Act, Available at: B340E81DD6AE/CEA_OPS_May_2013-eng.pdf. Accessed June Cenovus Cenovus s Linear Deactivation Project. Available at: Accessed June GOA (Government of Alberta) A Woodland Caribou Policy for Alberta. Available at: Accessed June GOA Lower Athabasca Regional Plan Edmonton, Alberta. August Nexen (Nexen Energy ULC) Algar Caribou Habitat Restoration Program 2012/2013 Phase 2 and 3 Areas. Field Operations Report. Nexen Algar Caribou Habitat Restoration Program 2013/2014 Phase 2 and 3 Areas. Field Operations Report. OSLI (Oil Sands Leadership Initiative) Algar Caribou Habitat Restoration Program Field Operations: Phase 1 Area. ESRD/CEAA Page 288 October 2014

291 Frontier Oil Sands Mine Project ESRD and CEAA Responses Terrestrial Question 60 SIR2 Response 97, Page 262. Teck was asked to provide appropriate mitigation for effects on caribou habitat during construction and operation consistent with A Woodland Caribou Policy for Alberta (2011). Teck was also asked to Ensure the habitat where woodland caribou are known to occur is specifically addressed. Teck responded that In A Woodland Caribou Policy for Alberta (ESRD 2011), under Policy Implementation, it states that Planning will focus at the caribou range level, and that the establishment of caribou population and habitat objectives and specific measurable targets will be range-specific. In addition, the policy implementation states that different types and levels of management actions will be applied within individual ranges. Because the Frontier Project does not overlap any of the identified caribou ranges in Alberta (as shown in ESRD 2011, Figure 1), it is Teck s understanding that the Project is consistent with the policy. Teck recognizes that caribou conservation is a national priority and as a member of COSIA, is actively participating in discussions about opportunities to maintain regional habitat connectivity for caribou through rehabilitation of disturbed habitat. It is agreed that plans will be developed at a range level, specific habitat objectives and targets will be range-specific, and, implementation will be applied within individual ranges. However, mitigation actions will be undertaken to meet these objectives and these mitigations will necessarily be at the operational level. Further, the underlying intent of the policy is to address woodland caribou declines. Teck has identified effects to caribou habitat as identified both by habitat assessment and use of the area by collared caribou. a. Describe what specific operational/project level mitigation Teck will undertake to address the described effects on caribou habitat during construction and operations. Response 60 a. Teck anticipates that the successes and learnings of work currently underway by COSIA for caribou will assist Teck in developing a wildlife mitigation and monitoring plan for the Project. For a description of the work being undertaken by COSIA, see the response to ESRD/CEAA Round 3 SIR 59. Teck s plan will consider caribou and locations outside the PAA that are on Teck OSLs (i.e., locations north of the North pit). However, details of the program are not expected to be final until after the anticipated EPEA approval for the Project is received and the province, the Canadian Environmental Assessment Agency (CEAA), potentially affected Aboriginal communities and other stakeholders have had input on its design. The wildlife mitigation and monitoring plan will be considered a follow-up program that has specific processes defined under CEAA s operational policy. October 2014 ESRD/CEAA Page 289

292 ESRD and CEAA Responses Terrestrial Frontier Oil Sands Mine Project Teck had previously committed to initiate development of the wildlife mitigation and monitoring plan for the Project in 2014 in conjunction with regulators and potentially affected Aboriginal communities. As Teck is currently preparing a Project Update (see the response to AER Round 3 SIR 1), development of the wildlife mitigation and monitoring plan will be delayed. Teck is delaying development of the wildlife mitigation and monitoring plan to allow for a design that will better reflect the updated Project. Question 61 SIR2 Response 104, Page 293. Teck has identified that they plan to provide further funding for directed research on Ronald Lake Bison, and will continue to discuss management approaches with First Nations and other stakeholders. a. Provide an updated description of research currently underway and any additional research results since the SIR2 response. b. Describe the broader research vision and timing. c. Which First Nations communities and other stakeholders are involved? d. How or who is determining the research questions to be tackled? Has a working group been convened? If so, describe the structure, membership, and mandate of the group. e. Describe how TEK will inform the directed research. Response 61 a. ESRD is currently leading a long-term study on the Ronald Lake bison herd for which Teck is providing financial support. In addition, Teck is collecting on-site data using wildlife sightings cards and remote cameras to understand whether individuals from the Ronald Lake bison herd were displaced by drilling activities. Teck has also investigated the extent of limiting winter habitat for an expanded area that includes the southern part of Wood Buffalo National Park (WBNP) (see the response to ESRD/CEAA Round 3 SIR 85a, Appendix 85a.1). Results and observations from these studies are summarized below. ESRD LONG-TERM STUDY AND WINTER PROGRAM This ongoing, multi-year study aims to collect data related to gaps in knowledge about the Ronald Lake bison herd. The study includes aerial surveys, sample collection for disease and genetic testing, and bison tracking with GPS telemetry collars. Data from the collars will help describe the Ronald Lake bison herd range and develop a resource selection function habitat suitability model. Funding ESRD/CEAA Page 290 October 2014

293 Frontier Oil Sands Mine Project ESRD and CEAA Responses Terrestrial provided by Teck supports work planned and conducted by ESRD between November 1, 2013 and March 31, The winter program (GOA 2013) focused on addressing knowledge gaps about the Ronald Lake bison herd (e.g., herd range and seasonal habitat use). Traditional knowledge provided by Athabasca Chipewyan First Nation (ACFN) (Candler et al. 2013a) and Mikisew Cree First Nation (MCFN) (Candler et al. 2013b) suggest that these bison have been there a long time and are not likely migrants from WBNP, but are possibly a long-established population that is genetically distinct and disease-free (ASRD 2010; GOA 2013). Scouting flights conducted in December 2012 and March 2013 observed a total of 167 and 186 bison, respectively (GOA 2013), an increase from the previous estimate of 101 bison in 2010 (ASRD 2010). Population estimates will be updated following a mark/resight aerial survey, which is planned for the field season. A total of 24 bison were tested for bovine tuberculosis and brucellosis (GOA 2013). Tissue and blood samples were collected from 11 individuals, and blood samples were collected from the 12 bison immobilized for collar deployment. One additional blood sample was submitted by a hunter from a harvested bison (GOA 2013). Results (n=24) suggest that disease prevalence for the Ronald Lake bison herd ranges from 0% to 25% for tuberculosis and 0% to 12% for brucellosis, levels that are both less than the disease prevalence observed for bison in WBNP (GOA 2013). Additional sampling in 2014 increased confidence in the disease-free status of the herd and suggests that the disease prevalence is less than 5% (Skilnick 2014, pers. comm.). Genetic testing of the Ronald Lake bison herd indicates they are genetically similar to bison in WBNP though the level of differentiation is strong, suggesting genetic exchange is negligible (Ball 2013). Genetic testing further suggests that the Ronald Lake Bison herd is not currently composed of genetically pure wood bison or pure plains bison, but rather that the herd shares a genetic association with both sub-species (Ball 2013). In March 2013, 12 bison cows were collared with satellite collars programmed to record their location every 90 minutes for approximately two years (GOA 2013). Only 6 of the 12 collars were functional through the first year of the study. A minimum convex polygon of the herd s range has been calculated using bison locations observed during scouting flights and from location data downloaded from the deployed collars (GOA 2013). Preliminary data collected from the collaring effort (based on 13 months of data collection) show that members of the Ronald Lake bison herd are travelling at least 10 km into WBNP. ESRD is currently analyzing collar data, and an update and new map are expected to be available in Additional bison collaring is planned for the 2014 field season, and data collection will continue until approximately March Although early results indicate that members of the Ronald Lake bison herd enter WBNP, there are no previous data to confirm whether WBNP is part of the herd s traditional range, a range expansion, or a shift resulting from some other factor. October 2014 ESRD/CEAA Page 291

294 ESRD and CEAA Responses Terrestrial Frontier Oil Sands Mine Project TECK WILDLIFE OBSERVATIONS AND ON-SITE MONITORING During the winter program, Project workers submitted 217 wildlife records, including 21 observations of bison (see Appendix 61a.1). The following year, more than twice as many wildlife records (523) were submitted as part of the winter program. These records included 17 observations of bison; each observation ranged from a single bison to groups of five bison, for a total of 36 bison (see Appendix 61a.1). Of the 36 bison observed, only two were observed to be running. Teck acknowledges that incidental wildlife sightings provide limited information; however, these sightings confirm the continued presence of the species in the area during the period that the drilling program was active and that the majority of the animals were not startled by the presence of human observers. The remote camera monitoring, which occurred from October 2013 to October 2014, was based on a BACI sampling design, with 20 cameras in the PDA (i.e., impact cameras) and 20 in a control setting (i.e., control cameras) (Golder 2014). Interim results showed bison at 10 control cameras and nine impact cameras, with bison recorded at 16 of the 19 cameras (10 control; 6 impact) occurring in undisturbed sites (see Appendix 61a.2). As with the sighting cards, impact PDA cameras recorded bison during the drilling program, confirming that bison remained in the area during drilling. ADDITIONAL FIELD INVESTIGATIONS AND MAPPING As described in the response to ESRD/CEAA Round 3 SIR 85, Teck has investigated the extent of limiting winter habitat for an expanded area that includes the southern part of WBNP. This study was completed to better understand winter habitat availability within and outside the area currently identified as the Ronald Lake bison herd range. This area has been defined based on known information (i.e., the range defined in the response to ESRD/CEAA Round 1 SIR 219c, Appendix 219c.1 and the minimum convex polygon defined by GOA [2013]). Preliminary data from this study is provided in response to ESRD/CEAA Round 3 SIR 85a, Appendix 85a.1. MCFN and Teck have jointly identified gaps in available information about the Ronald Lake bison herd and areas where Teck might need to reassess certain conclusions regarding potential effects on the Ronald Lake bison herd. These conclusions will be revisited as part of the Project Update following further engagement with MCFN. b. In Managing Disease Risk in Alberta s Wood Bison with Special Focus on Bison to the West of Wood Buffalo National Park: Progress Report, GOA (2012) makes a recommendation to: include the Ronald Lake bison herd... as part of the [provincial] disease management program. This would include bringing local stakeholders and aboriginal groups up-to-date on the disease management program, establishing good estimates for herd size and distribution, and determining the herd s disease status. ESRD/CEAA Page 292 October 2014

295 Frontier Oil Sands Mine Project ESRD and CEAA Responses Terrestrial GOA (2013) acknowledges that existing data gaps must be addressed to effectively determine whether the Ronald Lake bison herd should be managed differently from the current provincial approach. As part of its research, ESRD will: acquire samples from the Ronald Lake bison herd for disease and genetic testing collar additional bison with GPS telemetry transmitters collect bison location data convene a small technical committee comprising representatives from industry, local Aboriginal communities and third-party experts. The committee s objective will be to direct the analysis of bison telemetry data to investigate bison habitat use and the effects of industrial development on bison use of their range. c. In February 2014, the Government of Alberta (via ESRD) held a meeting to discuss interest and options for expanding participation and input in directed studies of the Ronald Lake bison herd. The meeting also focused on establishing guiding principles for the Ronald Lake Bison Herd Technical Studies Team. The meeting included participation by: members of ACFN, MCFN, Métis Local 1935, Fort McKay the University of Alberta the Royal Alberta Museum Parks Canada and Environment Canada industry representatives from Teck, Shell and SilverWillow A follow-up meeting of the technical committee was held in June 2014 to discuss the future of the team and research progress to date. Minutes from the February meeting are provided in the response to ESRD/CEAA Round 3 SIR 81, Appendix 81c.1. Minutes from the June meeting were not final at the time this response was drafted. d. Moving forward, the goals and objectives of data collection and subsequent research related to the Ronald Lake bison herd will be led by the Ronald Lake Bison Herd Technical Studies Team. Members of the team, as well as the team s terms of reference are still to be determined. It is anticipated that the terms of reference will outline the structure, membership and mandate of the group. MCFN has told Teck that it has a number of concerns about this technical team and asked Teck to present these concerns in this response. MCFN concerns include: exclusion from designing and carrying out these studies the role of indigenous knowledge in the work of the technical team a lack of transparency with the team other concerns relating to the draft terms of reference Teck understands that the draft terms of reference do not incorporate assessment of impacts to MCFN s rights. MCFN has also raised concerns about Alberta s unwillingness to provide bison data to MCFN. October 2014 ESRD/CEAA Page 293

296 ESRD and CEAA Responses Terrestrial Frontier Oil Sands Mine Project e. The Ronald Lake Bison Herd Technical Studies Team includes representation by Aboriginal communities. It is hoped that Aboriginal communities will actively participate in defining traditionalknowledge-based research, including the questions to be answered and how the research will be integrated into future decision-making regarding the management of the herd. All members of the technical team will play an equal role in all decisions that fall under the terms of reference. As noted in the response to part d, MCFN has expressed concerns about the Technical Studies Team. MCFN has clearly stated that it has concerns with the degree and manner with which MCFN s traditional knowledge and Aboriginal perspectives have been considered and incorporated by Teck, particularly in assessing impacts to MCFN s rights and culture. To this end, MCFN has expressed the need for further engagement regarding this SIR. Teck will revisit this SIR and conclusions contained in it once the parties have pursued the collaborative process that Teck and MCFN are working to develop as additional information is gathered. In addition, Teck has committed capacity funding for MCFN to undertake several additional studies that include two related to bison: an MCFN-led documentary that documents a traditional MCFN bison hunt a species-specific MCFN indigenous knowledge and use report on bison for the Frontier Project. The objective of this study is to produce a species-specific indigenous knowledge report that considers the Frontier Project. MCFN and Teck expect the outcomes of the report to inform discussion between MCFN, Teck and regulators regarding bison. These studies are expected to be completed in REFERENCES ASRD (Alberta Sustainable Resource Development) Ronald Lake (Bison bison) Survey February Prepared by Todd Powell and Traci Morgan, ASRD, Fort McMurray, Alberta. November Ball, M.C Characterizing the Genetic Population Structure of Wild Bison in Alberta, Canada. Alberta Environment and Sustainable Resource Development. October Candler, C., Firelight Group Research Cooperative, with the Athabasca Chipewyan First Nation. 2013a. Athabasca Chipewyan First Nation Indigenous Knowledge and Use Report and Assessment for Teck Resources Limited Proposed Frontier Oil Sands Mine Project. November 20, Candler, C., Olson, R., Firelight Group Research Cooperative, with the Mikisew Cree First Nation. 2013b. Mikisew Cree First Nation Knowledge and Use Report and Assessment for Teck Resources Limited Proposed Frontier Oil Sands Mine Project. November 15, Golder (Golder Associates Ltd.) Teck Frontier Wood Bison Camera Monitoring Interim Report. Prepared for Teck Resources and Shell Canada Limited. ESRD/CEAA Page 294 October 2014

297 Frontier Oil Sands Mine Project ESRD and CEAA Responses Terrestrial GOA (Government of Alberta) Managing Disease Risk in Alberta s Wood Bison with Special Focus on Bison to the West of Wood Buffalo National Park: Progress Report. Government of Alberta, Edmonton, Alberta. August GOA Ronald Lake (Bison bison) Winter Activities Progress Report. Government of Alberta, Edmonton Alberta. GOA Summary Notes from Ronald Lake Bison Herd Meeting. February 5, Skilnick, J Preliminary Activities Presented to the Ronald Lake Bison Herd Technical Studies Team. Senior Wildlife Biologist, Alberta Environment and Sustainable Resource Development. Fort McMurray, Alberta. Question 62 SIR2 Response 105 e and f, Page Teck was asked What percentage change in mean patch area would have resulted in a high environmental consequence rating by Teck? Teck s response does not provide a percent change value that would have resulted in a high environmental consequence rating. a. Discuss the value that would have resulted in a high environmental consequence rating. Teck was asked to Explain how the reliance on reversibility of effects has biased the terrestrial assessment towards low-moderate environmental consequence ratings. Teck concludes in its response that The assessment for vegetation and wildlife key indicators is considered realistic and not biased. b. Are there any indicators for which a high environmental consequence rating is possible if reversibility is factored into the rating? c. If so, provide an example. d. If not, provide further discussion of how the consequence ratings may be pre-disposed toward low and moderate ratings when reversibility is considered. e. Provide a discussion of the uncertainty associated with reversibility predictions for vegetation and wildlife indicators and how that has been incorporated into the effects assessment. Describe how resilience is factored in. Response 62 a. Environmental consequence ratings were developed for relevant ecological, receptor-based disciplines. Environmental consequence was defined as low, moderate or high and was considered relative to predevelopment. The rating indicates the potential for the Project to contribute to adverse effects in conjunction with other operating, approved and planned developments in the region. October 2014 ESRD/CEAA Page 295

298 ESRD and CEAA Responses Terrestrial Frontier Oil Sands Mine Project Environmental consequence ratings provide a means to evaluate environmental effects on ecologicalbased receptors (i.e., key indicators and key indicator species) and place effects into an assessment context. For example, the vegetation assessment included patch metrics and the definitions for environmental consequence considered both the magnitude of change and reversibility (see Table 62a-1). Loss of vegetation components such as peatland ecosystems or rare plants was considered an irreversible change. In contrast, other vegetation components were considered reclaimable to common boreal ecosystems, and effects were therefore considered reversible, aligning with the requirements of the Environmental Protection and Enhancement Act (EPEA) and the management objectives of the Lower Athabasca Regional Plan (LARP) (GOA 2012). Because the effects to patch metrics (i.e., disturbance) were considered reversible, a high environmental consequence would not be an outcome following the defined assessment criteria. Table 62a-1 Environmental Consequence Vegetation Magnitude Irreversible Reversible High 1 High environmental consequence Moderate environmental consequence Moderate 1 Moderate environmental consequence Low environmental consequence Low 1 Low environmental consequence Low environmental consequence NOTE: 1 For community and species diversity, change is measured relative to the 95% lower and upper confidence limits of the mean for measureable parameters where the range of natural variability is defined. SOURCE: Adapted from Volume 6, Section 3.3.6, Table 3-5, Page b. See the response to part a. c. The vegetation and wildlife assessments presented in the, and the additional key indicators assessed as part of SIRs, identified the following cumulative effects as having high environmental consequence: effects on peat-accumulating wetlands (see Volume 6, Section 3.6.8, Page 3-76 and as revised in response to ESRD/CEAA Round 2 SIR 136a, Appendix 136a.1) effects on rare species for which the only known regional occurrence is in the Project footprint (see Volume 6, Section 3.7.8, Pages 3-98 to 3-99 and as revised in response to ESRD/CEAA Round 2 SIR 136a, Appendix 136a.1) habitat loss for wetland-dependent wildlife species assessed as part of the including yellow rail, short-eared owl, rusty blackbird and western toad (see Volume 6, Section , Pages to and as revised in the response to ESRD/CEAA Round 2 SIR 136a, Appendix 136a.4) habitat loss for woodland caribou, as assessed for the revised Project (see the response to ESRD/CEAA Round 2 SIR 136a, Appendix 136a.4) ESRD/CEAA Page 296 October 2014

299 Frontier Oil Sands Mine Project ESRD and CEAA Responses Terrestrial habitat loss for horned grebe, as assessed in the response to ESRD/CEAA Round 1 SIR 448a, Appendix 448a.1 and revised in the response to ESRD/CEAA Round 2 SIR 136a, Appendix 136a.4 a potential shift of the Ronald Lake bison herd north into Wood Buffalo National Park (WBNP), if they are found to be disease-free bison that could interact more frequently with known diseased hybrid bison found in WBNP (as discussed in the response to ESRD/CEAA Round 2 SIR 188). The high environmental consequence rating was based on the potential for a population decline of the herd that might result from shifting the herd north and introducing disease that would potentially increase mortality rates. effects on biodiversity in general based on the assessment conclusions made above and following the methods used by the Joint Review Panel for the Jackpine Mine Expansion (see the response to ESRD/CEAA Round 2 SIR 185) The Project was identified to incrementally contribute to these cumulative effects without consideration for mitigation, including offsets or other management measures. As described in the response to ERCB Round 1 SIR 96 and ERCB Round 2 SIR 29: It is anticipated that the Government of Canada, in consultation with the Government of Alberta, will provide guidance on the potential need for additional mitigation to meet the requirements of Section 79(2) of the Species at Risk Act to avoid or lessen Project effects, including effects to wetlands and biodiversity. Teck believes that the development of detailed mitigation measures or offset plans that could form the basis of a Conservation Agreement or Conservation Allowance should not occur until the anticipated EPEA approval for the Project is received, and consultation with regulators and potentially affected Aboriginal communities and stakeholders is completed. d. It is Teck s opinion that the vegetation and wildlife assessments provided in the and subsequent SIR responses provide a balanced and realistic approach that accounts for irreversibility as well as the legal requirements for reclamation under EPEA and management objectives set out under LARP. e. The vegetation and wildlife assessments completed for the Frontier Project considered uncertainty as part of an evaluation of prediction confidence. The assessments rated confidence in reclamation, (and as a result, reversibility) as moderate for community diversity for most common boreal ecosystems (see Volume 6, Section 3.6.9, Pages 3-76 to 3-77) and the wildlife species that use these common boreal ecosystems for habitat (see Volume 6, Section , Pages to 4-251). As discussed in Volume 1, Section , Pages 13-5 to 13-7, the conceptual reclamation plan developed for the Frontier Project incorporated relevant Acts, regulations, guidance documents, regional plans, industry best practices and peer-reviewed literature. Results of recent research and monitoring data were also considered. As discussed in Volume 6, Section , Pages 3-55 to 3-57, October 2014 ESRD/CEAA Page 297

300 ESRD and CEAA Responses Terrestrial Frontier Oil Sands Mine Project data from CEMA s long-term monitoring plots indicate that, for the most part, reclaimed oil sands sites appear to be moving toward natural ecosystems. As stated in Volume 6, Section : From a site-productivity perspective, preliminary measures from older monitoring plots indicate that early tree growth on reconstructed soils is comparable to growth rates of trees on natural soils, although the long-term sustainability of this growth is still in question (Timberline Natural Resource Group 2008). Long-term monitoring plots document that, for the most part, reclaimed oil sands sites appear to be developing into ecosystems with similar plant community composition and nutrient availability to those which occur naturally (see Rowland et al for an evaluation of long-term reclamation monitoring data). However, from a community-succession perspective, the diversity of plants on sites with reconstructed peat/mineral mix soils still remains well below natural site levels when these young reclaimed stands are compared to more mature natural sites (Stantec 2009). For additional information about reclamation success from Teck s operations in other parts of western Canada, see the responses to ESRD/CEAA Round 3 SIR 78 (vegetation) and ESRD/CEAA Round 3 SIR 63 (wildlife). Although the assessment did consider that most common boreal ecosystems would be reclaimed, some ecosystems (e.g., peatlands) will likely not be present in the same extents regionally. As a result, effects on vegetation and wildlife species with a high fidelity to peatlands were considered irreversible, as were effects to rare vegetation species. For a more detailed discussion about resilience as it applies to reclamation in the oil sands region, and its inclusion in the assessment, see the response to ESRD/CEAA Round 3 SIR 67. REFERENCES GOA (Government of Alberta) Lower Athabasca Regional Plan Edmonton, Alberta. August Rowland, S.M., C.E. Prescott, S.J. Grayston, S.A. Quideau and G.E. Bradfield Recreating a functional forest soil in reclamation oil sands in northern Alberta: an approach for measuring success in ecological restoration. Journal of Environmental Quality 38: Stantec (Stantec Consulting Ltd.) Results from Long Term Soil and Vegetation Plots Established in the Oil Sands Region (2009). Prepared for Cumulative Environmental Management Association, Fort McMurray, Alberta and other annual reports (2001 through 2008). Timberline Natural Resource Group Ltd Analyzing and relationship between LCCS Ratings and Site Productivity. Cumulative Environmental Management Association, Fort McMurray, Alberta. ESRD/CEAA Page 298 October 2014

301 Frontier Oil Sands Mine Project ESRD and CEAA Responses Terrestrial Question 63 SIR2 Response 107, Page Teck was asked to Provide further evidence from scientific, peer-reviewed and regional literature that supports Teck s claim that this assessment took a conservative approach to assessing impacts on wildlife. Teck s response provides some acknowledgement of the uncertainty associated with reclamation outcomes and wildlife responses; however, Teck concludes that As such, inclusion of progressive reclamation in the represents a useful tool for predictive assessment. The response does not connect the uncertainty noted around reclamation outcomes and wildlife recolonization of the reclaimed habitat and the assessment approach to explain how the approach is conservative. It is unclear how the complexity of biological responses and resilience have been considered in the assessment of effects. Teck seems to suggest that reclamation is predicted to be fully successful, and that wildlife populations will return to a pre-disturbance level. The available peer-reviewed and regional literature discussed by Teck does not seem to support this. a. Provide further evidence from scientific, peer-reviewed and regional literature that supports Teck s claim that the assessment took a conservative approach to assessing effects on wildlife. b. Provide further discussion of how the uncertainty associated with reclamation success and outcomes has been considered in the assessment approach. c. Provide a discussion of resilience in the context of whether the approach taken is conservative. Response 63 a. The wildlife assessments prepared as part of the EIAs for three other oil sands mines (i.e., Joslyn North Mine and Jackpine Mine Expansion/PRM) indicate that all effects resulting from habitat loss are reversible (Shell 2007; Total 2010) or were implied to be reversible (Imperial Oil 2005). As described in the (see Volume 6, Section 4), Teck assumed that loss of peatlands would be irreversible because technology regarding peatland reclamation is still evolving. Compared to previous oil sands EIAs, Teck s approach is conservative with respect to this aspect of habitat loss. With respect to progressive reclamation, Teck s approach was to include this and other mitigation measures in the assessment to allow for a realistic assessment of residual effects within the context of common boreal ecosystems. Teck recognizes that including reclamation provides a best-case scenario as it is conceivable that some reclamation goals might not be met. Climate change might also affect outcomes and not all vegetation species are expected to return (for more information about effects on vegetation species diversity, see Volume 6, Section 3.7, Pages 3-81 to 3-101). However, because oil sands approvals require reclamation under EPEA, it is unrealistic to complete an assessment without considering reclamation. Failing to include mitigation in the assessment would overstate the effects to October 2014 ESRD/CEAA Page 299

302 ESRD and CEAA Responses Terrestrial Frontier Oil Sands Mine Project vegetation and wildlife (i.e., worst-case scenario). The success of progressive reclamation will be enhanced by incorporating an adaptive monitoring program that will include ongoing assessments of reclamation success (including use by wildlife) and by determining the need to modify reclamation prescriptions and revegetation based on specific objectives. As stated in ESRD/CEAA Round 2 SIR 107b: there is available empirical data on the success of vegetation establishment and growth in the oil sands based on research and long-term reclamation monitoring completed by CEMA (see Volume 6, Section , Pages 3-55 to 3-57 and the response to ESRD/CEAA Round 1 SIR 216).... [However,] Teck acknowledges that empirical information specifically from the oil sands region that documents successful reclamation of wildlife habitats including use of habitat is more limited [(see AENV 2010)]. Further work is needed to identify standardized monitoring methods; however, this work is still in the early stages (Hawkes and Tuttle 2011). Despite this, Teck s experience with reclamation elsewhere in western Canada has shown that reclaimed sites are used by a variety of wildlife species. As part of a COSIA-led initiative to outline state-of-the-art mine reclamation practices, Teck has contributed knowledge from its 40 years of mine reclamation experience at its steel-making coal mines in western Canada (as summarized in the response to ESRD/CEAA Round 3 SIR 78). Teck s reclamation experience and knowledge transfer is based on three areas of operation: the Cheviot and Luscar mines (collectively referred to as Cardinal River Operations), in southwest Alberta Elk Valley, in southeast British Columbia the Quintette and Bullmoose mines in the northeast British Columbia coal block Documents prepared by Teck (specifically O Brien and Straker [2010] and Straker et al. [2012]) are included in the response to ESRD/CEAA Round 3 SIR 78, Appendix 78a.1 and 78a.2. Reclamation outcomes and information relevant to wildlife are summarized below. The learnings and methods are provided in response to this information request and will not necessarily be used at the Frontier Project. The reclamation plan for the Project is conceptual and will be refined over the life of the mine based on site-specific conditions. WILDLIFE HABITAT AND RECLAMATION SUCCESS Creation of wildlife habitat has been one of the primary reclamation goals for all of Teck s properties in Alberta and British Columbia. As such, Teck has developed and completed various monitoring programs to evaluate the success of reclamation activities and use of reclaimed landscapes by wildlife. For instance, reclamation research has identified preferred forage species (native and naturalized or introduced) for elk and bighorn sheep (e.g., O Brien and Straker 2010). Preferred forage species are quick to establish, have high nutritional value and are used by ungulates. This work ESRD/CEAA Page 300 October 2014

303 Frontier Oil Sands Mine Project ESRD and CEAA Responses Terrestrial also identified advantages of using naturalized or introduced grass and forb species, particularly their rapid and reliable establishment, which provides more forage for wildlife. Although native species can take longer to establish, they contribute to biodiversity objectives. In addition to grasses and forbs, a variety of native tree and shrub species that are preferred elk browse have been successfully established. Consideration of planting window, plant protection against browse damage and wind and cold desiccation, and legume interseeding have contributed to these successes. Research focusing on forage quality has indicated that forbs and grasses exceed minimum dietary crude protein requirements for ungulates during the growing season, but diminish in value in late fall and winter (O Brien and Straker 2010). During winter, dietary requirements are met through use of native woody species, which are capable of maintaining threshold levels of digestible nutrients for ungulates. Additional habitat enhancement for birds and small mammals has also been tested through selective placement of standing snags, nest boxes, log or brush piles, and tunneling materials. This work has shown that providing such habitat structures can rapidly increase habitat use and promote reproduction by a variety of birds and small mammals. The following summaries describe species group responses to the reclamation work undertaken at Teck s properties. Wildlife use of reclaimed waterbodies is also included. Because reclamation activities have focused on developing forage for ungulates and enhancement measures for small mammals and birds, available habitat are typically young seral stages. This influences the species observed (i.e., lack of mature and old-growth communities results in no or low numbers of species that prefer these habitats). UNGULATES At Teck s steel-making coal operations in Alberta and British Columbia, reclamation of ungulate habitat has been a primary focus. In Alberta, reclamation efforts at the Luscar and Gregg River mines have resulted in an increased density of bighorn sheep, an expanded winter and lambing range, and an increase in escape terrain (i.e., through exposed cut-faces) (O Brien and Straker 2010). At the Luscar Mine, bighorn sheep populations increased 3.8% annually between 1985 and 2002, coinciding with reclamation efforts (MacCallum 2003). Other studies have also shown increases in resident bighorn sheep populations at reclaimed sites (Acott 1983; Knapik et al. 1995). Surplus bighorn sheep are being captured and reintroduced to extripated ranges in the United States from Teck s Cardinal River Operations (Teck 2013) Studies at Teck s mines in the Elk Valley have been ongoing since the 1970s and have focused on elk and bighorn sheep (O Brien and Straker 2010). At these sites, elk and mule deer were both observed to inhabit the reclaimed area over the winter; forage appeared to be of good quality and sufficient to meet ungulate dietary needs. Legumes were noted as being important food sources (Kaiser Resources 1978). Although there was high elk use on some of the reclaimed sites, the low structural and October 2014 ESRD/CEAA Page 301

304 ESRD and CEAA Responses Terrestrial Frontier Oil Sands Mine Project vegetation diversity and limited forest cover were thought to have negatively affected colonization by other wildlife species. Overall, ungulates used slopes that were steep, south facing and at low elevations during the winter (Fraser 1984). SMALL MAMMALS Studies have shown a high use of reclaimed areas by some groups of small mammals (Westar Mining 1983a, 1984; Smyth 1999; O Brien and Straker 2010). Changes in terrain at a reclaimed site (e.g., the addition of rock piles and logs) can provide more topographic requirements for wildlife that use topographic features for residence or cover (Westar Mining 1983a; Quintette Operating Corporation 1999). For example, pikas, ground squirrels and wood rats were observed to have colonized talus slopes or loose rubble at two reclaimed mine sites (Westar Mining 1983a). Evidence of log use by small mammals through fecal observations has also been documented (Westar Mining 1984; Smyth 1999). Other small mammals, including fisher, marten and snowshoe hare, were found to use and inhabit undisturbed forest areas along the mine boundary rather than at the reclaimed site (Environmental Insight and Myosotis Ecological Consulting 1997). CARNIVORES Large carnivores (e.g., wolf, coyote, fox, bear, wolverine, cougar and lynx) tend be uncommon at reclaimed mine sites (Environmental Insight and Myosotis Ecological Consulting 1997; MacCallum 2003). Although in low numbers, carnivores especially grizzly bears and black bears increased their use and activity of reclaimed sites in Alberta (O Brien and Straker 2010) and northeastern British Columbia (Smyth 1999; EBA 2003). Various animal behaviours were observed during carnivore sightings, including feeding, travelling in family groups (i.e., bears), denning (i.e., red fox), and mating (Environmental Insight and Myosotis Ecological Consulting 1997; Quintette Operation Corporation 2001). TERRESTRIAL BIRDS Since the early 1980s, wildlife habitat enhancements have been successfully used at operating mines. Enhancements have included snags (as perches and nesting sites for birds) and nest boxes (Westar Mining 1983b, 1984, 1987; Quintette Operation Corporation 1999, 2000). In all instances, snags and nest boxes were used by local bird species (e.g., kestrels, red-tailed hawks, woodpeckers, finches and swallows). Brush piles on reclaimed sites have also been observed to be used by various birds, including American robins, horned larks, mountain bluebirds, tree swallows and ravens (Westar Mining 1986). ESRD/CEAA Page 302 October 2014

305 Frontier Oil Sands Mine Project ESRD and CEAA Responses Terrestrial WILDLIFE USE OF RECLAIMED WATERBODIES AND WETLANDS Reclamation of mine sites largely focuses on returning the land to its pre-mining conditions, which can include the development of lakes and wetlands. Mine pit lakes can provide suitable habitat and staging areas for waterfowl, breeding areas for amphibians, and habitat for aquatic mammals (Luscar et al. 1994). They can also benefit terrestrial and aerial wildlife in the area by providing a water source for ungulates and an area for bats and swallows to feed on insects (Luscar et al. 1994). Luscar et al. (1994) conducted a study to evaluate wildlife use of mine pit lakes in Alberta. The study compared three reclaimed lakes developed on coal mines to an undisturbed, natural lake. Although all lakes had limited waterfowl habitat suitability, migrants and breeding birds (e.g., shorebirds, ducks, swallows and warblers) were found to use the lakes and adjacent areas. The reclaimed lakes also supported an abundance of invertebrates, and bats were observed feeding over the lakes. Reclaimed lakes can potentially support more complex aquatic food chains. Amphibians (e.g., western toads and tadpoles) have been observed breeding at mine pit lakes and sedimentation ponds (Luscar et al. 1994; Environmental Insight and Myosotis Ecological Consulting 1997). Teck acknowledges that inclusion of regional progressive reclamation in an EIA, while a realistic approach, should be compared to a worst-case scenario (i.e., where reclamation practices are not considered) as an environmental assessment best practice. As discussed in the response to ESRD/CEAA Round 2 SIR 136, Teck updated the vegetation and wildlife assessment and conclusions to address three different assessment approaches: A revised assessment (see Appendices 136a.1 [vegetation] and 136a.4 [wildlife]) presents a bestcase and realistic scenario with environmental consequence rankings considering reversibility of effects following the methods used in the. Teck considers this scenario the appropriate method for examining cumulative effects. A refined assessment (see Appendices [vegetation] and 136a.5 [wildlife]) that represents a worst-case and unrealistic scenario with environmental consequence rankings not considering reversibility associated with reclamation. Teck does not consider this scenario to be an appropriate method for examining cumulative effects given industry commitments and regulatory requirements to achieve reclamation. An alternate assessment (see Appendices 136a.3 [vegetation] and 136a.6 [wildlife]) that represents a worst-case and unrealistic scenario with environmental consequence rankings not considering reversibility associated with reclamation. The alternate assessment included a different development inclusion list. Like the refined assessment, Teck does not consider this scenario to be an appropriate method for examining cumulative effects. October 2014 ESRD/CEAA Page 303

306 ESRD and CEAA Responses Terrestrial Frontier Oil Sands Mine Project For a comparison of environmental consequence conclusions, see the response to ESRD/CEAA Round 2 SIR 197a, Table 197a-3. As expected, the worst-case scenario predicts severe effects that are not realistic: 7 of the 9 vegetation indicators shifted to a high environmental consequence when progressive reclamation and the associated concept of reversibility is removed 24 of the 38 wildlife habitat indicators shifted to a high environmental consequence when progressive reclamation and the associated concept of reversibility is removed 6 of the 9 wildlife connectivity indicators shift to a high environmental consequence when progressive reclamation and the associated concept of reversibility is removed Teck feels that the discussion above, in combination with previous discussion in response to ESRD/CEAA Round 2 SIR 107, justifies Teck s assessment approach and explains why successful reclamation and the concept of reversibility were included. The diverse assessment approaches presented in response to ESRD/CEAA Round 2 SIR 136 provide further information and comparisons of potential Project effects. b. Teck incorporated uncertainty regarding reclamation success based on a review of existing data. This affected both the determination of reversibility and prediction confidence in the assessment conclusions. As part of the, Teck reviewed existing reclamation reports in the oil sands region. Results of this desktop review follow: As discussed in Volume 6, Section , Pages 3-55 to 3-57, data from the CEMA long-term reclamation plots show that vegetation appears to be mostly moving toward natural ecosystems. Preliminary results from older monitoring plots indicate that early tree growth on reconstructed soils is comparable to growth rates of trees on natural soils, although the long-term sustainability of this growth is still in question (Timberline Natural Resource Group 2008). In most cases, long-term reclamation plots show that reclaimed oil sands sites appear to be developing into ecosystems with similar plant community composition and nutrient availability to those occurring naturally (see Rowland et al for an evaluation of long-term reclamation monitoring data). However, from a community-succession perspective, vegetation diversity at sites with reconstructed peat/mineral mix soils remains well below natural levels when these young reclaimed stands are compared to more mature natural sites (Stantec 2009). Although most reclamation treatments were developing as natural forest ecotypes, reclaimed sites on tailing sands that did not receive appropriate nutrient treatments and had a thick layer of peatmineral mix (i.e., 0.15 m) appear to be developing into novel ecosystems (i.e., assemblage of species that does not occur in nature) (Rowland et al. 2009). As documented by Rowland et al. (2009), reclamation results improve when a thicker peat/mineral mix layer is applied to tailings sand. For additional discussion about novel ecosystems, see the response to ESRD/CEAA Round 1 SIR 473. ESRD/CEAA Page 304 October 2014

307 Frontier Oil Sands Mine Project ESRD and CEAA Responses Terrestrial c. See the response to ESRD/CEAA Round 3 SIR 67 for a discussion of resilience as it applies to reclamation in the oil sands region and its inclusion in the assessment. REFERENCES Acott, G.B Reclamation Strategy at Cardinal River Coals Ltd. Proceeding of the 7th Annual British Columbia Mine Reclamation Symposium, Victoria, British Columbia. AENV (Alberta Environment) Guidelines for Reclamation to Forest Vegetation in the Athabasca Oil Sands Region, 2nd Edition. Prepared by the Terrestrial Subgroup of the Reclamation Working Group of the Cumulative Environmental Management Association, Fort McMurray, Alberta. EBA (EBA Engineering Consultants Ltd.) Reclamation Monitoring Assessment. Quintette Operating Corporation. Environmental Insight and Myosotis Ecological Consulting Wildlife Habitat Assessment. Bullmoose Operating Corporation. Fraser, D.F From Test Plot to Nest Box: An Overview of Reclamation Research at a Coal Mine in Southeastern British Columbia. Westar Mining s Balmer Operation. Hawkes, V.C. and K.N. Tuttle Early Successional Wildlife Monitoring on Reclaimed Plots in the Oil Sand Region. Year Annual Report. LGL Report EA248. Unpublished report by LGL Limited Environmental Research Associates, Sidney, British Columbia for CEMA The Reclamation Working Group (RWG), Fort McMurray, Alberta. Imperial Oil (Imperial Oil Resources Ventures Ltd.) Kearl Oil Sands Project. Environmental Impact Assessment, Volume 7, Section 5. Prepared by AXYS Environmental. Kaiser Resources Ltd Annual Reclamation for 1977 and Proposed Program for Knapik, L.J., A.M. Hammermeister and D.G. Walker Characteristics and Quality of Minesoil Landscapes and Minesoil Profiles at the Luscar Mine. Cardinal River Coals. Luscar Ltd., Luscar-Sterco Ltd., Cardinal River Coals Ltd., Pisces Environmental Consulting Services Ltd. and Bighorn Environmental Design Ltd Development of Sport Fisheries in Lakes Created by Coal Mining Operations in the Eastern Slopes: Final Report. MacCallum, B Reclamation to Wildlife Habitat in Alberta s Foothills. Bighorn Environmental Design Ltd. O Brien, B. and J. Straker Teck Coal Limited Reclamation Research Summary What We Have Learned What We Need to Know Calgary, Alberta. Quintette Operating Corporation Quintette Operating Corporation 1998 Reclamation Report. Quintette Operating Corporation Quintette Operating Corporation 1999 Reclamation Report. Quintette Operating Corporation Quintette Mine Closure Report Reclamation Permit No. C-156. October 2014 ESRD/CEAA Page 305

308 ESRD and CEAA Responses Terrestrial Frontier Oil Sands Mine Project Rowland, S.M., C.E. Prescott, S.J. Grayston, S.A. Quideau and G.E. Bradfield Recreating a functional forest soil in reclamation oil sands in northern Alberta: an approach for measuring success in ecological restoration. Journal of Environmental Quality 38: Shell (Shell Canada Ltd.) Shell Jackpine Mine Expansion and Pierre River Mine Project. Environmental Impact Assessment. Prepared by Golder Associates. Smyth, C.R Reclamation Assessment Bullmoose Operating Corporation. Stantec (Stantec Consulting Ltd.) Results from Long Term Soil and Vegetation Plots Established in the Oil Sands Region (2009). Prepared for Cumulative Environmental Management Association, Fort McMurray, Alberta and other annual reports (2001 through 2008). Straker, J., B. O'Brien and R. Jones Teck Coal s Reclamation Research Program A Synthesis of 40 Years of Experience in Mountain Mine Reclamation. Teck Coal Ltd. Calgary, Alberta. Teck (Teck Resource Limited) Resourceful. Teck 2013 Sustainability Report. Available at: y&portalname=tc. Accessed July Timberline Natural Resource Group Ltd Analyzing and Relationship between LCCS Ratings and Site Productivity. Cumulative Environmental Management Association, Fort McMurray, Alberta. Total (Total E&P Joslyn Ltd.) Joslyn North Mine Project. Environmental Impact Assessment. Prepared by Golder Associates and Stantec Consulting Ltd. Westar Mining Ltd. 1983a. End Land Use Goals for the Balmer Minesite. A Specific Reclamation Plan for the Balmer Minesite, Westar Mining Ltd. 1983b Annual Report and Proposed Program for Westar Mining Ltd Annual Report and Proposed Program for Westar Mining Ltd Annual Report and Proposed Program for Westar Mining Ltd Annual Report and Proposed Program for Question 64 SIR2 Response 108, Page 339. Teck confirms its intent not to incorporate all process-affected ponds into the bird deterrent system and provides the following rationale: Ponds that occur within or adjacent to the plant site perimeter were deemed to have sufficient deterrents from high traffic volumes and sensory disturbance from lights. As part of the monitoring program for the Project, Teck will monitor these ponds to determine if bird use occurs during operation. Teck will review monitoring data to determine if these ponds need to be incorporated into the bird deterrent system. ESRD/CEAA Page 306 October 2014

309 Frontier Oil Sands Mine Project ESRD and CEAA Responses Terrestrial a. How was it determined that ponds that occur within or adjacent to the plant site would have sufficient deterrents from high traffic volumes and sensory disturbance from lights? b. Compare the ponds not incorporated into the bird deterrent system with ponds and bird/process-water contact data from other regional mines to corroborate the conclusion. Ensure the location, level of disturbance and pond type and size are comparable. c. Describe how this is a precautionary approach. d. Discuss how this approach meets the expectations of provincial and federal legislation. Response 64 a. After further consideration, Teck is prepared to install bird deterrents at all ponds associated with the Project that have process-affected water that could be detrimental to birds. b. See the response to part a. c. See the response to part a. d. See the response to part a. Question 65 SIR2 Response 109, Page Teck was asked to provide further clarity on how it will avoid wildlife mortality during tailings pond start-up. Should initiation of tailings flow occur between April 1 and August 31, Teck is relying on the deterrent system to ensure wildlife mortality does not occur. Other operators have had challenges associated with tailings pond start-up and valuable lessons have been learned. Teck does not describe the full scope of planning, operations, and mitigation measures that might be implemented to avoid similar issues. Teck has not committed to the use of a radar based detection and deterrent system, so it is unclear whether habituation potential will be addressed. a. Describe what planning, operational, and mitigation lessons have been learned during tailings pond start-up by other operators. b. Specifically, identify how Teck has and will incorporate each of these lessons learned into its tailings pond start-up plan. c. Since Teck has not committed to an on-demand system, describe how habituation potential will be addressed. Provide peer-reviewed support for the efficacy of the approach chosen. Teck states that If nests, eggs, nestlings, fledglings or molting birds are discovered prior to the addition of tailings and water into tailings areas, Teck will contact ESRD and Environment Canada to discuss mitigation options. October 2014 ESRD/CEAA Page 307

310 ESRD and CEAA Responses Terrestrial Frontier Oil Sands Mine Project d. Provide a list of feasible mitigation options that Teck would present to ESRD and Environment Canada that would be consistent with federal and provincial legislation, should Teck discover nests, eggs, nestlings, fledglings, or moulting birds prior to the addition of tailings and water into tailings areas. Response 65 a. There is currently no specific guidance available for dealing with bird interactions during the start-up of tailings ponds in the oil sands region. As well, information that may be present in annual reports developed by other oil sands operators is not readily available. In spite of this, it is known that where pond areas were cleared in previous years, and vegetation has started regrowing, birds may start using the new regrowth. This can be an operating challenge when the tailings elevation increases and inundates the area, thereby affecting wildlife (e.g., birds) inhabiting those areas. Recent collaboration by provincial and federal agencies, the University of Alberta and industry representatives has focused on developing guidance and standardized protocols for monitoring bird contact with ponds containing process-affected waters (e.g., tailings ponds) and bird mortality (St. Clair 2014). However, this program did not provide any specific recommendations for protocols during the start-up of tailings ponds. As a member of COSIA, Teck will consult other operators in the oil sands region about lessons learned from their experiences with various mitigation options. Teck will use this information in developing detailed construction and operational procedures and mitigation measures to reduce wildlife mortality risk during tailings pond start-up. This information could be used in the future to provide collective guidance regarding bird-related mitigation options during tailings pond start-up. b. See the response to part a. c. On-demand (i.e., radar-based) systems are considered the best available method to deter birds from tailings areas. Teck will commit, at minimum, to using this type of system for the tailings areas and other ponds containing process-affected water. Because radar-based on-demand systems respond to bird activity, they are generally believed to reduce habituation compared to other auditory (e.g., conventional cannons) and visual deterrents that are encountered by birds annually along migration routes (Ronconi and St. Clair 2006). d. Clearing all aboveground vegetation (and some belowground vegetation) before adding tailings and water to ETA 1, and installing and operating an on-demand bird deterrent system will help reduce potential interactions between migratory birds and tailings areas. Therefore, the risk to migratory bird species will be very low, except for a few species (e.g., killdeer, which nests on bare ground). Additional technologies used in other jurisdictions and sectors (e.g., use of unmanned vehicle systems or drones to disperse nuisance animals) will also be explored to dissuade birds from nesting in the areas planned for tailings. ESRD/CEAA Page 308 October 2014

311 Frontier Oil Sands Mine Project ESRD and CEAA Responses Terrestrial As stated in the response to ESRD/CEAA Round 2 SIR 109h: Assuming that tailings and water are slated to be added between April 1 and August 31 (migratory bird breeding window for the region), to deter birds from nesting, in the spring prior to the addition of tailings and water (i.e., around April 1),... the proposed bird deterrent system will be implemented. Deterring birds from nesting in the proposed tailings areas will extend through the migratory bird breeding window. If tailings and water are scheduled to be added after August 31, the bird deterrent system will be implemented only once tailings and water are added. REFERENCES Ronconi, R.A. and C.C. St. Clair Efficacy of a radar-activated on-demand system for deterring waterfowl from oil sands tailing ponds. Journal of Applied Ecology 43: St. Clair, C.C Final Report on the Research on Avian Protection Project. Prepared for Alberta Justice, Edmonton, Alberta. Question 66 SIR2 Response 110, Page , SIR2 Response 111, Page 345, and SIR2 Response 185, Page 518. Teck was asked, For each ecosite phase and wetland class, provide an estimate of species richness and evenness which includes wildlife and not just the habitat preferences of the KIRs used for the wildlife assessment. Teck directs the reviewer to SIR2 Response 185. The response does not provide an estimate of species richness and evenness which includes wildlife and not just the habitat preferences of the KIRs used for the wildlife assessment. It is unclear how the use of habitat preferences of KIRs would be linked to totality of genes, species and ecosystems as noted by Teck as presented in the Shell Jackpine Expansion Panel Decision: interprets biodiversity to refer to the totality of genes, species, and ecosystems of a region. a. Provide an estimate of species richness and evenness which includes wildlife and not just the habitat preferences of the KIRs used for the wildlife assessment. Teck states that The results of the assessment of key indicators in the identify that the Project together with operating, approved and planned developments will incrementally contribute to a regional decline in biodiversity. This decline is thought to be largely associated with a decline in the abundance of wetlands and habitat for wetland-dependent species. As with the assessment of wetlands and wetland-dependent wildlife species, this decline is predicted to have high environmental consequence. In addition, there will be a regional decline in mature and old growth forest in the vegetation and wildlife RSA and a decline in available habitat for species that depend on these ecosystems. Because the decline is expected to be reversible in the long-term, and can be October 2014 ESRD/CEAA Page 309

312 ESRD and CEAA Responses Terrestrial Frontier Oil Sands Mine Project mitigated using integrated land management, this change is considered to have a moderate environment consequence to biodiversity. b. Provide peer-reviewed support and discussion for the statement indicating the decline is thought to be largely associated with a decline in wetland abundance and habitat for wetland-dependent species. c. Referencing earlier questions regarding the uncertainty of reclamation outcomes, ecological complexity, and ecological resilience, clarify the extent of the reversibility Teck intends to convey associated with the prediction and describe how the conclusion is conservative. d. Explain what Teck means in suggesting biodiversity declines can be mitigated by integrated land management. Provide an example of how biodiversity declines would be mitigated by integrated land management. Response 66 a. As discussed in the response to AER Round 3 SIR 1, Teck intends to update the for the Project to: recover additional resource from leases acquired from Shell during the Teck Shell asset exchange optimize the tailings management strategy in consideration of the current state of engineering practice and improved understanding of site-specific conditions reflect additional engineering studies and information obtained from Shell as part of the asset exchange consider input received from regulators and potentially affected Aboriginal communities during the review process The Project Update will include a revised assessment of biodiversity that addresses the biodiversity potential of various ecosite phases and wetland classes. The biodiversity assessment will be based on wildlife and vegetation empirical data collected for the Frontier Project as well as information from the literature, including reports from the oil sands region. The assessment will: detail habitat preferences of wildlife species of management concern found in the oil sands region rate ecosite phases for biodiversity, including considerations of species richness and evenness, where possible focus primarily on species- and ecosystem-level parameters, given that genes are beyond the scope of the assessment Teck will complete the requested biodiversity assessment as part of the Project Update. b. In assessing Project effects on biodiversity, Teck has assumed that the decline of wetlands could incrementally contribute to a potential decline in regional biodiversity because current reclamation practices and technologies to reclaim peatlands are still evolving. Coinciding with this, closure plans for reclaimed landscapes are predominantly upland ecosites. Rooney et al. (2012) evaluated this ESRD/CEAA Page 310 October 2014

313 Frontier Oil Sands Mine Project ESRD and CEAA Responses Terrestrial change and found that for several oil sands mines in the region, uplands will increase by 15,030 ha on the leaseholds, mainly at the expense of peatlands, which will decrease by 12,414 ha. Although the effect of this change on biodiversity has not been fully quantified, given the wildlife and vegetation species using and occurring in wetlands, one could assume that the loss of areal extent of wetlands could result in a decline in biodiversity. As a result, Teck concluded that, without mitigation (e.g., offsets), cumulative effects to biodiversity would have a high environmental consequence (see the response to ESRD/CEAA Round 2 SIR 185). c. See the response to ESRD/CEAA Round 3 SIR 67 for further discussion about the uncertainty of reclamation outcomes, ecological resilience and assessment conclusions. d. The Lower Athabasca Regional Plan (LARP) is the integrated land management framework encompassing the Mineable Oil Sands Area (MOSA). One of the specific outcomes LARP identifies is managing landscapes to maintain ecosystem function and biodiversity (Government of Alberta 2012). The biodiversity management framework has not been released yet, but it is expected to take proactive approaches and set limits and triggers to manage regional biodiversity. In addition, targets are expected to be set for selected biodiversity indicators. As stated in LARP, the biodiversity management framework will provide context within which decisions about future activities and management of existing activities should occur (Government of Alberta 2012). Teck is a member of COSIA and biodiversity is within the Scope of the Land Environmental Priority Area. Teck supports performance goals and Joint Industry Projects that serve to maintain high regional species intactness. COSIA initiatives will fit within the framework provided by the LARP but might also consider strategies provided by the TEMF and the associated Triad Land Management concept. REFERENCES Government of Alberta Lower Athabasca Integrated Regional Plan Edmonton, Alberta. August Rooney, R.C., S.E. Bayley and D.W. Schindler Oil sands mining and reclamation cause massive loss of peatland and stored carbon. Proceedings of the National Academy of Sciences 109: October 2014 ESRD/CEAA Page 311

314 ESRD and CEAA Responses Terrestrial Frontier Oil Sands Mine Project Question 67 SIR2 Response 196, Page Teck states that The assessment of potential Project-related effects on regional wildlife populations is habitat-based and does not try to explicitly predict population densities... and further states that In the absence of understanding the regional population abundance and distribution of species (managed by the provincial and federal governments), and in particular the current carrying capacity of the species in various parts of the region, it is beyond the scope of the to determine changes in the actual population levels and corresponding potential effects on ecosystem processes. This suggests that Teck s assessment predictions do not fully consider effects beyond habitat-based effects and underlines the uncertainty associated with Teck s environmental effects conclusions. Teck references land use planning undertaken for the Lower Athabasca Region and modelling work undertaken in support of the CEMA-generated Terrestrial Ecosystem Management Framework in several responses (e.g. SIR2 Response 106, Page ). a. Provide a discussion of the gaps and uncertainty associated with the assessment information presented with particular reference to regional wildlife populations. Specifically discuss conclusions, confidence and residual effects. b. Provide a discussion of resilience (capacity of the ecosystem to respond to perturbation) and the risk that land use change in the mineable oils sands area will result in profound ecosystem shift. c. Discuss the dose-response curves used in the land use planning process for the Lower Athabasca Regional Plan and the Terrestrial Ecosystem Management Framework and describe whether Teck s assessment predictions are consistent with the response curves used in the Plan and Framework. Response 67 a. Teck recognizes that the assessment of species-specific, population-level effects presented in the represented a high-level assessment. A detailed and more robust assessment of wildlife populations would require accurate population size information as well as a detailed understanding of potential limiting and interacting factors (biotic and abiotic) that influence wildlife population abundance for each species. This level of knowledge will only be gained through cooperative initiatives that include government, industry, Aboriginal communities and the academic community. Overall, as discussed in the response to ESRD/CEAA Round 2 SIR 196, a habitat-based approach, supplemented with relative abundance indices derived from wildlife field surveys, provides a reasonable and reliable method for assessing effects of the Project on wildlife populations. ESRD/CEAA Page 312 October 2014

315 Frontier Oil Sands Mine Project ESRD and CEAA Responses Terrestrial Teck stands by its original conclusions taking into account the uncertainty and prediction confidence associated with the residual effects discussed in the and follow-up SIRs, specifically the response to ESRD/CEAA Round 1 SIR 231. For further discussion about uncertainty as it relates to use of reclaimed habitat by wildlife, and how it would affect assessment predictions, see the response to ESRD/CEAA Round 3 SIR 63. b. Teck agrees that the concept of ecological resilience is relevant to ecosystem disturbance in the MOSA as reviewed in Pyper et al. (2013). However, defining ecological resilience is complex and defining ways to measure success (i.e., to determine if specific management goals have been achieved) is challenging (Welham et al. 2013; Mumby et al. 2014). Resilience has been defined in two ways: (1) engineering resilience, which refers to the ability of an ecosystem to recover from disturbance; and (2) ecological resilience, which represents the movement of an ecosystem within and between stability domains (Thrush et al. 2009). Both of these definitions have strengths and weaknesses, as outlined in Mumby et al. (2014). In particular, although engineering resilience is intuitively appealing, it is difficult to apply to systems that have multiple community equilibria, rarely reach equilibrium because of periodic disturbance, or have equilibrial states that are difficult to define. Teck s use of range of natural variability (RNV) for the vegetation and wildlife assessments is considered a suitable substitute for a stability domain given that changes in habitat were modelled over long temporal scales and included changing natural disturbance. Ecological resilience is useful to apply to ecosystems that risk losing their ability to recover, and where there is no need to identify a final equilibrial state. However, ecological resiliency can be especially challenging to quantify because it requires complex ecological models and long-term time series data (i.e., more than 100 years) from the same environment (Thrush et al. 2009). It is therefore beyond the scope of an EIA and traditional monitoring. However, the general concepts of engineering and ecological resilience can be applied to reclamation and monitoring programs. Boreal ecosystems tend to be inherently resilient (in terms of engineering resilience) because they are adapted to natural disturbance regimes (e.g., fire, insect and pathogens) and possess biological or historical legacies (e.g., trees, seeds, nutrients) that enable them to recover or self-organize (Welham et al. 2013). In contrast, reclaimed systems have relatively low resilience initially because they lack these historical legacies (e.g., availability of propagules in soils, presence of snags and coarse woody debris, presence of microtopography). The challenge, therefore, is to manage resiliency in the context of an oil sands mine (and other developments) by implementing reclamation practices that increase the probability that a desired state will be achieved and will persist over time, recognizing that potential for resiliency may vary with the type of perturbation and the features of the community (Welham et al. 2013). This would involve including, for instance, coarse woody debris, propagules via direct placement, meso- and micro-topography in the reclamation landscape along with planting of seedlings. The intent would be to mimic or improve the engineering resilience of reclaimed sites compared to natural habitats. Teck has committed to incorporating all of these reclamation practices and will continue to participate in reclamation research and monitor developing technologies used October 2014 ESRD/CEAA Page 313

316 ESRD and CEAA Responses Terrestrial Frontier Oil Sands Mine Project elsewhere in Teck s and other, third-party operations in Canada and around the world. Of note, Teck manages many closed and reclaimed sites in Canada and around the world and have received numerous meritorious citations and awards for efforts related to re-establishment of productive ecosystems (see the response to ESRD Round 3 SIR 63 for examples of research and outcomes). This corporate knowledge will be included in the efforts brought to developing post-mining outcomes at this location. The concept of ecological resilience is being discussed by researchers and industry in the oil sands region (Pyper et al. 2013; Welham 2013). Incorporating ecological resilience into the management of oil sands seems most applicable to reclamation. CEMA, for example, is considering including ecological resilience in the Criteria and Indicators Framework for assessing reclamation success in oil sands mines (Poscente 2009; Poscente and Charette 2012). However, further research is still needed to understand how resilience can be applied to ecological systems, including those affected by anthropogenic disturbance such as oil sands mines (Thrush et al. 2009; Pyper et al. 2013). Teck believes that oil sands monitoring programs that are designed to measure reclamation success, and that use reference condition benchmarks that may consider chronosequences, will provide the necessary empirical time-series data to determine whether the function and structure of an ecosystem is on track to recovery. Over the short-term, such data would contribute to the current understanding of how reclaimed areas are recovering from disturbance (i.e., engineering resilience). As more data are compiled over time, our understanding of the equilibria of reclaimed areas will improve and the longer-term relationship to ecological resilience is expected to evolve. c. As described in Silvatech (2008a), in developing the Terrestrial Ecosystem Management Framework (TEMF), a customized version of ALCES was used to generate natural range of variation (NRV) data for management indicators (e.g., moose, fisher, black bear, woodland caribou and old growth birds). Specifically, bitumen and timber production rates were converted to area disturbance by landscape type. Results were used to determine fire area disturbance by landscape type and to assess regional and triad zone level indicator performance for the management options evaluated by CEMA s Sustainable Ecosystem Working Group. Direct comparisons between the wildlife assessment conclusions and those included in the TEMF are challenging because of several key differences between the TEMF process and that used for the. For example: TEMF modelling scenarios were run for the Regional Municipality of Wood Buffalo (RMWB), an area almost an order of magnitude larger than the vegetation and wildlife RSA. The RMWB includes a high amount of in-situ developments that are not found in the Project s vegetation and wildlife RSA. The increase in linear feature density associated with these developments as part of the TEMF modelling process (no increase in the ) is considered a key driver for the expected decline in the performance of environmental indicators (CEMA 2008). The TEMF process forecasted changes out to 100 years whereas for the, maximum build-out was at 2057 (i.e., approximately half the time period used in the TEMF). ESRD/CEAA Page 314 October 2014

317 Frontier Oil Sands Mine Project ESRD and CEAA Responses Terrestrial Although the TEMF and both simulated natural fire, the locations of these fires were not identical. Wildlife habitat suitability models and the corresponding vegetation mapping used in the TEMF and the were also different (i.e., vegetation mapping was more detailed in the ); for the Project, it was important to have the wildlife and vegetation assessments in the use a common dataset. One commonality between the TEMF and the was the use of NRV (termed range of natural variability [RNV] in the ) as part of the modelling process. Conclusions regarding management response triggers in the TEMF (CEMA 2008) and the magnitude of effects in the both focused on change from the lower limit of NRV. Based on the management response triggers defined in TEMF (CEMA 2008): moose (habitat) and old growth birds (habitat) are currently in the green condition fisher (habitat) and black bear (habitat) are in the yellow condition woodland caribou (population) are in the red condition Based on modelling for the TEMF: caribou, black bear and fisher would be in the red condition in the future (100 year forecast) moose would decline to the yellow condition old growth birds would remain in the green condition For the, the thresholds used in the TEMF were used as the basis for determining the magnitude of effects on wildlife (see Volume 6, Section 4.3.5, Pages 4-20 to 4-23). As such, low magnitude is similar to the green condition, moderate magnitude to the yellow condition and high magnitude to the red condition. Considering this, when compared against the Application Case: woodland caribou, black bear and fisher were all high magnitude (i.e., red condition) moose was moderate magnitude (i.e., yellow condition) birds preferring mature or old growth forests (e.g., olive-sided flycatcher and Canada warbler) were high magnitude (i.e., red condition), and not low magnitude (i.e., green condition) as predicted in TEMF Therefore, it appears that despite differences in modelling processes and inputs, the conclusions in the TEMF are similar to what was predicted in the with the exception of mature/old growth forest bird species. The proportional area of old growth forest used by TEMF (for the RMWB) and the (for the vegetation and wildlife RSA) are similar for existing conditions (3.5% [Silvatech 2008b] and 3.2% [see Volume 2, Section 8.3.1, Table 8-10, Page 8-33], respectively), so this difference is likely driven by differences in ecological model inputs. Specifically, wildlife models used for mature/old growth forest bird species in the Integrated Application were dependent (and therefore sensitive to) stand age. In contrast, modelling completed October 2014 ESRD/CEAA Page 315

318 ESRD and CEAA Responses Terrestrial Frontier Oil Sands Mine Project for TEMF was considered only moderately sensitive to stand age, with the guild of old growth birds using a broad range of seral stages (Silvatech 2008c). REFERENCES CEMA (Cumulative Environmental Management Association) Terrestrial Ecosystem Management Framework for the Regional Municipality of Wood Buffalo. Fort McMurray, Alberta. Mumby, P.J., I. Chollett, Y-M. Bozec and N.H. Wolff Ecological resilience, robustness and vulnerability: how do these concepts benefit ecosystem management? Current Opinion in Environmental Sustainability 7: Poscente, M A Framework for Reclamation Certification Criteria and Indicators for Mineable Oil Sands. Cumulative Environmental Management Association, Fort McMurray, AB. CEMA Contract No RWG. Poscente, M. and T. Charette Criteria and Indicators Framework for Oil Sands Mine Reclamation Certification. Cumulative Environmental Management Association, Fort McMurray, AB. CEMA Contract No RWG. Pyper, M.P., C.B. Powter and T. Vinge Summary of Resiliency of Boreal Forest. Landscapes Seminar, Oil Sands Research and Information Network. University of Alberta. School of Energy and Environment, Edmonton Alberta. OSRIN Report TR- 30. Available: Silvatech (Silvatech Group). 2008a. Summary of Methodology for the Development of the Terrestrial Ecosystem Management Framework. Prepared for the Sustainable Ecosystem Working Group, Cumulative Environmental Management Association. June Silvatech. 2008b. SEWG Workplan Facilitation and Modelling Project Data Inputs and Assumptions. Prepared for the Sustainable Ecosystem Working Group, Cumulative Environmental Management Association. June Silvatech. 2008c. Indicator Synthesis: Selection Rationale, Modelling Results and Monitoring Considerations for Key Indicators of the Terrestrial Ecosystem Management Framework. Prepared for the Sustainable Ecosystem Working Group, Cumulative Environmental Management Association. June Thrush, F., J.E. Hewitt, P.K. Dayton, G. Coco, A.M. Lohrer. A. Norkko, J. Norkko and M. Chiantore Forecasting the limits of resilience: integrating empirical research with theory. Proceedings of the Royal Society B 276: Welham, C Factors Affecting Ecological Resilience of Reclaimed Oil Sands Uplands. Oil Sands Research and Information Network, University of Alberta, School of Energy and the Environment, Edmonton, Alberta. OSRIN Report No. TR-34. ESRD/CEAA Page 316 October 2014

319 Frontier Oil Sands Mine Project ESRD and CEAA Responses Health 6 HEALTH Question 68 Volume 2, Appendix 113a.1, Section , Table 113a-23, Pages 2-37 to 2-40 In the text on page 2-37, Teck states that all ILCRs are predicted to be less than 1.0 in 100,000 in both the original and revised HHRA. However, Table 113a-23 indicates a revised ILCR for leukemogens in the Project case of 1.7 in 100,000. a. Clarify whether the value in the table is correct. b. If the value is correct, update the conclusions with respect to chronic inhalation exposure to carcinogens, accordingly. Response 68 a. The revised incremental lifetime cancer risk (ILCR) presented for leukemogens (1.7 in 100,000) is incorrect. This value, presented for the recreational group in the response to ESRD/CEAA Round 2 SIR 113, Appendix 113a.1, Table 113a-23, arose from a calculation error in the mixture ILCR. Further examination reveals that the chronic nasal and lung cancer ILCRs for the recreational group were affected by the same formula error (although these ILCRs were both less than 1.0 in 100,000). Corrected ILCR values are presented in Table 68a-1 for chemical mixtures. No changes to the future (i.e., PDC incremental) ILCR values in Appendix 113a.1, Table are required because the calculation error did not affect these values. As Table 68a-1 shows, the corrected ILCR values are less than 1.0 in 100,000. Therefore, the Project-related cancer risks are considered negligible for these carcinogens. Table 68a-1 Revised ILCRs for the Recreational Group, Project Case (Corrected) Nasal carcinogens Leukemogens Lung carcinogens Mixtures 1 Revised ILCR (Project) 2.1E E E-02 NOTE: 1 Individual constituents of the chemical mixtures are identified in the original human health and risk assessment (HHRA) (see Volume 7, Section 2.7.3, Table 2-15, Pages 2-50 to 2-51). The addition of individual ILCR values (provided above) for a mixture s chemical constituents might not necessarily equate to the ILCR value for the mixture because the ILCR values in the table represent the highest ILCR for each group of locations, regardless of the fixed location at which it occurred. October 2014 ESRD/CEAA Page 317

320 ESRD and CEAA Responses Health Frontier Oil Sands Mine Project b. The conclusions regarding chronic inhalation exposure to carcinogens remain unchanged. See the response to part a. ESRD/CEAA Page 318 October 2014

321 Frontier Oil Sands Mine Project ESRD and CEAA Responses Approvals 7 APPROVALS The responses to SIRs in the Approvals Section will not be considered as part of the EIA completeness decision made by Alberta Environment and Sustainable Resource Development. 7.1 Federal Effects of changes to the environment on Aboriginal Peoples Question 69 Volume 1, ESRD/CEAA SIR 1, Page 1 The response to ESRD/CEAA SIR 1 does not provide information on all potentially affected Aboriginal groups, and only specifically addresses ACFN, MCFN, Fort McKay and Fort Chipewyan Métis. Furthermore, insufficient detail is provided on those four groups. In order to understand the potential effects of the Project on Aboriginal peoples, as required under section 5(1)(c) of CEAA 2012, information is required on all potentially affected Aboriginal groups. a. Provide an update on all consultation activities undertaken to date. b. Clearly identify which Aboriginal groups Teck considers to be potentially affected. c. Describe how Teck has addressed the concerns raised by Fort McMurray Métis local 1935, Lakeland Métis local 1909, Métis Nation of Alberta Region 1, and Fort McMurray First Nation #468. Response 69 a. An update on all consultation activities undertaken to date is provided in response to AER Round 3 SIR 2. b. As described in Teck s Aboriginal consultation plan (submitted to ESRD and CEAA and provided in response to ESRD/CEAA Round 2 SIR 139c, Appendix 139c.1), Teck consults with Aboriginal communities it has identified as being potentially affected by the Frontier Project. These communities include: Fort McKay (First Nation and Métis Local 63) Athabasca Chipewyan First Nation October 2014 ESRD/CEAA Page 319

322 ESRD and CEAA Responses Approvals Frontier Oil Sands Mine Project Mikisew Cree First Nation Fort Chipewyan Métis (Métis Local 125) Based on guidance from past regulatory proceedings, the Project s Aboriginal Consultation Plan and interest expressed in the Project during consultations, Teck has engaged and responded to concerns from additional Aboriginal communities, including: Fort McMurray Métis (Métis Local 1935) Lac La Biche Métis (Métis Local 1909) Métis Nation of Alberta Region 1 Fort McMurray First Nation #468 In addition, Teck keeps the following Aboriginal communities informed about the Frontier Project through regular updates: Métis Local 2020 Chipewyan Prairie First Nation Métis Local 193 (Conklin) Métis Local 214 (Chard) Métis Local 780 (Anzac) Wood Buffalo First Nation (Wood Buffalo First Nation Elders Society, Clearwater River Band #175) Athabasca Tribal Council Treaty 8 First Nations of Alberta Métis Nation of Alberta Bigstone Cree First Nation Deninu K ue First Nation Salt River First Nation Smiths Landing First Nation Akaitcho Territory Government Deh Cho First Nations K a a gee Tu First Nation K atlodeeche First Nation West Point First Nation Northwest Territory Métis Nation c. For a summary of how Teck has addressed concerns expressed by Métis Local 1935, Métis Local 1909, MNA R1 and Fort McMurray First Nation #468, see the response to AER Round 3 SIR 2. ESRD/CEAA Page 320 October 2014

323 Frontier Oil Sands Mine Project ESRD and CEAA Responses Approvals Question 70 Volume 1, ESRD/CEAA SIR 137, Page 396 Volume 1, ESRD/CEAA SIR 151, Page 447 Métis Traditional Land Use studies have not been undertaken and other TLU studies have not yet been filed. Information on the current use of land and resources for traditional purposes by all potentially affected Aboriginal groups is required to understand the effects of the Project on Aboriginal people under section 5(1)(c) of CEAA In order to understand the effects of the Project on Aboriginal peoples as required under section 5(1)(c) of CEAA 2012, provide information on the potential effects to current use of lands and resources for traditional purposes, occupancy, rights and interests for all Aboriginal groups, including Métis, that may be affected by the Project. a. Provide traditional land use information and update the traditional land use assessment for all potentially affected Métis groups (in addition to the information on Métis Local (ML) 63, including but not necessarily limited to MNAR1, ML125, ML1935, and ML1909). b. Update the traditional land use assessment once traditional land use studies and indigenous knowledge studies are completed for ACFN and MCFN. Response 70 a. Considerable work, including new traditional land use (TLU) studies and a revised assessment, is underway to address gaps in the information available about traditional and Aboriginal land use. Teck is committed to understanding potentially affected Aboriginal communities use of the land and how this land use may be affected by the Project. This response provides a high-level summary of this ongoing work. Teck received the Fort McKay s TLU study for the Project during finalization of the Integrated Application (August 2011). At that time, Fort McKay requested that this TLU study be included in the. Accordingly, Teck provided Fort McKay s TLU study as Volume 8, Appendix 6A: Traditional Land Use Study for the Teck and SilverBirch Frontier Project (Fort McKay Sustainability Department 2011). Teck and Fort McKay have agreed to work collaboratively outside of the regulatory process to develop a common understanding of effects to Fort McKay rights and traditional land use, including identifying whether there are potential mitigation measures that would be culturally appropriate and supported by Fort McKay. Teck and Fort McKay do not anticipate that this process will affect regulatory timelines. However, information might emerge that Fort McKay or Teck believes is critical to inform the Joint Review Panel report. If so, we will update the future panel. October 2014 ESRD/CEAA Page 321

324 ESRD and CEAA Responses Approvals Frontier Oil Sands Mine Project Teck is funding Métis Local 125 and Métis Local 1935 TLU studies for the Frontier Project. These studies are expected to be completed in 2014 or early Upon receipt of these studies, Teck will follow up with each community to co-create an ongoing process of engagement focused on understanding how they might work with Teck to incorporate traditional land use and traditional knowledge into Project planning, mitigation measures and execution in a meaningful way. Teck has requested meetings or met with other Métis groups, including Métis Local 1909 and the Métis Nation of Alberta Region 1 (MNA R1), in spring Outcomes and context for these meetings and requests are summarized as follows: Teck has undertaken one meeting with the Métis Local 1909 on April 21, During this meeting, Métis Local 1909 requested that Teck provide funding for a Project-specific TLU study to support a better understanding of effects to Métis Local 1909 traditional land use. Métis Local 1909 is located more than 400 km from the Project site. Given this distance and the lack of specific concerns expressed by Métis Local 1909, Teck does not believe a substantial TLU study is appropriate and has offered to meet with potentially affected, concerned or interested community members to better understand potential effects and concerns associated with the Project. If during consultation with the community, Métis Local 1909 identifies specific concerns related to land use in the Project area, Teck is willing to consider conducting a screening-level study to better understand Métis Local 1909 land use in the area. Teck has requested to meet with MNA R1 to continue to discuss concerns and interests with the Frontier Project, but no meeting dates have been successful for MNA R1. b. Work is underway to incorporate traditional land use information provided by ACFN and MCFN. Teck has received TLU studies from ACFN and from MCFN for the Frontier Project. These include the: Athabasca Chipewyan First Nation Knowledge and Use Report and Assessment for Teck Resources Limited s Proposed Frontier Oil Sands Mine Project received February 2014 Mikisew Cree First Nation Indigenous Knowledge and Use Report and Assessment for Teck Resources Limited s Proposed Frontier Oil Sands Mine Project received November 2013 A copy of the MCFN study was provided to regulators, and Teck has requested that ACFN provide a copy of its TLU study to regulators as well. Teck has subsequently invited ACFN and MCFN to define (individually) an ongoing process of engagement to incorporate TLU and aspects of traditional knowledge. This process would focus on addressing outstanding technical concerns and understanding how ACFN and MCFN might work with Teck to incorporate traditional land use and traditional knowledge into Project planning, mitigation measures and execution, in a way that is meaningful for MCFN and ACFN. ESRD/CEAA Page 322 October 2014

325 Frontier Oil Sands Mine Project ESRD and CEAA Responses Approvals Question 71 Volume 1, ESRD/CEAA SIR 137, Page 396 Volume 1, ESRD/CEAA SIR 151, Page 447 To supplement Teck s response to federal SIR # 2.2 part (b) of December 23, 2013, provide a. The responses providing details in terms of the Aboriginal rights identified in table 138a-1 as well as the details on traditional land use which were requested December 23, Response 71 Teck recognizes that consultation with potentially affected Aboriginal communities is an ongoing process. Teck will work with Aboriginal communities throughout the life of the Project to continue to understand their concerns and incorporate their traditional knowledge and perspectives into management, monitoring and future reclamation work. With regards to this SIR and understanding the Project s impacts on Aboriginal rights, Teck plans to provide a comprehensive response to this SIR once key additional studies funded by Teck and undertaken by Aboriginal communities are completed. Although Teck is able to respond based on Teck s current understanding of impacts on Aboriginal rights, key Aboriginal communities have requested that additional consideration be given to their traditional land use, traditional knowledge, culture and Aboriginal perspective so that the impact assessment and estimation of significance can more likely be supported by communities. Teck has expressed support for such work through the funding of additional studies and intends to provide complete responses that address SIRs and SOCs related to Aboriginal rights in the future. Question 72 Volume 1, ESRD/CEAA SIR 138 a, Page 397 In its assessment of the potential effects of the Project on the experience of remoteness and solitude on the land, Teck has assessed the Project s effects on the existing acoustic environment and has determined that predicted sound levels at trapper cabins and Indian Reserves near the Frontier Project are within the permissible sound levels described in ERCB Directive 038. The directive sets permissible sound levels for outdoor noise, taking into consideration that the attenuation of noise through the walls of a dwelling should decrease the indoor sound levels to where normal sleep patterns are not disturbed. In remote areas where no human receptors are expected, a 40 decibel (dba Leq) must be met at 1.5 km. Further, some Aboriginal groups have indicated that the ERCB Directives are not based on levels and/or thresholds which are culturally appropriate to Aboriginal use. October 2014 ESRD/CEAA Page 323

326 ESRD and CEAA Responses Approvals Frontier Oil Sands Mine Project As outdoor traditional land use activities are often practiced outside of Indian reserves, either within or in close proximity to the Project area: a. Justify the use of ERCB directive 038 as appropriate for the assessment of the noise impact on remoteness and solitude. b. Describe Teck s criteria for determining if the area is remote and no receptors are expected. c. Describe the direct and cumulative noise impact, from a pre-industrial baseline, on the experience of remoteness and solitude inside the traditional land use Regional Study Area. d. Describe the consultation activities that Teck has undertaken with Aboriginal groups in the preparation of this assessment of remoteness and solitude. e. Provide references and/or cite sources to substantiate this assessment. f. If Fort McKay First Nation agrees, provide a copy of the memo regarding acoustic, air quality and odour modelling on the trapline belonging to the Fort McKay member. Teck s response does not address the intergenerational impact of the Project on the cultural and spiritual relationship with the land, for example, the transmission of site specific knowledge and practises. Based on consultation and traditional knowledge from all potentially impacted Aboriginal groups: g. Provide an assessment of cultural and spiritual impacts of the Project for each potentially impacted Aboriginal group, including Métis. In table 138a-1, Teck refers to Métis locals 63 and 125. Métis Nation of Alberta Region 1 (MNAR1) represents Métis who are not part of these locals. Describe Teck s consultation activities with MNAR1. h. Provide an assessment of the effects of the Project on MNAR1 rights and traditional use. Teck states that it has reached an agreement regarding compensation for the loss of registered fur management area (RFMA or trapline) However, commercial rights to a RFMA are not the same as the collectively held Aboriginal rights. i. Describe how Teck will compensate for the loss of opportunity to exercise Aboriginal rights associated with the use of the areas with affected traplines. Response 72 a. In most rural acoustic environments, the ambient sound level (ASL) is characterized by natural sound sources including: wind and rain interacting with natural surfaces (e.g., wind noise, thunder, vegetation rustling) stream and river movement animal noises (e.g., birds and insects) ESRD/CEAA Page 324 October 2014

327 Frontier Oil Sands Mine Project ESRD and CEAA Responses Approvals These sources vary by the minute because of changing natural forces and human activities. Measured ASLs also vary depending on location, meteorological conditions, season and time of the day. It is common to have large variability, for example, between daytime and nighttime ASLs at the same location. Directive 038 considers 35 dba the average nighttime ASL for a rural acoustic environment in Alberta. The daytime and nighttime ASLs identified in Directive 038 provide a reference level to qualify the perceptibility of a noise effect. Aboriginal communities have indicated that remoteness and solitude are important considerations for undertaking traditional activities; however, remoteness and solitude are, in part, perceptually based values, which vary from one person to another. In addition, there is no available literature that quantifies the acoustic environment of remoteness and solitude with a sound pressure level. The ASLs set out in Directive 038 provide the best available measureable parameter to quantify the acoustic environment of a rural area and are considered appropriate to quantitatively assess noise effects from the Project. Directive 038 takes a balanced viewpoint by considering the closest residents and the Project. However, it does not guarantee that a resident will not hear noises from a facility, nor do the ASLs represent the quietest period of a specific location in a remote area. Rather, the ASLs defined in Directive 038 provide a reference point for measuring noise from industrial activities so that it does not adversely affect indoor noise levels for residents near a facility. Directive 038 also sets permissible sound levels (PSLs) for outdoor noise, taking into consideration that the attenuation of noise through the walls of a dwelling should decrease indoor sound levels to where normal sleep patterns are not disturbed. MCFN has told Teck that it has concerns with the degree and manner with which MCFN s traditional knowledge and Aboriginal perspectives have been considered and incorporated by Teck, particularly in the assessment of impacts to MCFN s rights and culture. This response does not incorporate traditional knowledge. To this end, Teck acknowledges the need for further engagement regarding this SIR and Teck will revisit this SIR and conclusions contained in it once the parties have pursued the collaborative process that Teck and MCFN are working to develop and as additional information is gathered. ACFN has clearly stated that it has concerns with the degree and manner with which ACFN s traditional knowledge and Aboriginal perspectives have been considered and incorporated by Teck, particularly in the assessment of impacts to ACFN s rights and culture. Recognizing that additional work needs to be done, Teck has requested to meet with ACFN to co-create a process to address outstanding concerns, to revisit certain conclusions made by Teck in the, and to work toward understanding and incorporating ACFN s traditional land use and traditional knowledge into the assessment in a meaningful way. Teck will update regulators on a regular basis about the progress of these discussions. Teck will not be filing responses to Round 3 SIRs that pertain to traditional knowledge or the assessment of impacts October 2014 ESRD/CEAA Page 325

328 ESRD and CEAA Responses Approvals Frontier Oil Sands Mine Project to ACFN s rights and culture with regulators until the parties have pursued the collaborative process referred to above, or until Teck and ACFN agree otherwise. b. The criteria for determining remoteness are based on Section (Resource-based Tourism Industry Products Remote, Semi-Remote and Drive-In) of the Ontario Ministry of Natural Resources (2001) Management Guidelines for Forestry and Resource-Based Tourism. These guidelines define three broad categories for resource-based tourist areas: remote, semi-remote and drive-in. Remote The area is not accessible by road and is based on a remote wilderness experience where access is only gained through air, water or rail... important attributes... include inaccessibility, isolation from visual and auditory impacts, and high quality environmental resources (e.g. fish and wildlife). Semi-remote Similar to a remote... [area] except that road access is limited and may be controlled through artificial means or the use may be limited to protect the resources, opportunity or value. The non-traditional means of access include: restricted road, ATV trail, marine, and portage. The same attributes that are important to remote... [areas] are important here as well, except as how they are changed by the lesser amount of remoteness. Drive-in The area includes unencumbered road access [and] important characteristics... include full accessibility, composite use, and maintenance of both the visual and auditory environmental setting and access to good quality resources. c. As discussed in the response to part a, Teck was not able to identify any literature that quantifies the acoustic environment of remoteness and solitude with a sound pressure level. Directive 038 considers 35 dba the average nighttime ASL for a rural acoustic environment in Alberta. In the absence of a quantifiable measure, Teck has provided figures that show the boundary at which perceptible noise changes above the ASL may be apparent for land users: Figure 72c-1 and Figure 72c-2 show the boundary for direct noise impacts of the Project. Figure 72c-3 shows the 3 km buffer, representing the perceptible noise boundary for the Project in combination with other existing and approved developments that have the potential for noise overlap (i.e., the cumulative noise effects). The perceptibility of a noise effect can be identified based on the criteria listed in Table 72c-1. Table 72c-1 Subjective Effect of Changes in Sound Pressure Level Change in Sound Level (db) Change in Apparent Loudness 3 Just perceptible 5 Clearly noticeable 10 Half or twice as loud 20 Much quieter or louder SOURCE: Bies and Hansen (2003). ESRD/CEAA Page 326 October 2014

329 T103 R13 W4 R12 R11 Ronald Lake R10 R9 ³ Chipewyan I.R. Unnamed Waterbody 20 Unnamed Waterbody 19 Unnamed Waterbody 14 R1 ") Chipewyan Indian Reserve 201G ") T102 Unnam ed Cre ek 18 R10 ") Unnamed Creek 17 Unnamed Creek 16 Unnamed Creek 19 Athabasca River T101 R15 ") Unnamed Waterbody 29 Unnamed Waterbody 12 T100 Unnamed Waterbody 16 Redclay Creek R11 ") Unnamed Waterbody 13 Unnamed Creek 7 ") R14 Firebag River T99 Eymundson Creek Asphalt Creek R12 ") R5 ") R13 ") R4 ") R3 ") Creek T98 Tar River Calumet River R8 R2 ") ") Pierre Ri ve r R7 ") R6 ") McClelland Lake Noise Receptor T97 ") Trapper Cabin ") Local Study Area Boundary ") Other Noise Contour >70 dba >65 dba >60 dba >55 dba Calumet >50 dba Lake >45 dba >40 dba >35 dba >30 dba Lillian Lake Acoustics Local Study Area Project Area PRM Township Defined Watercourse Undefined Watercourse Waterbody I.R. Fort Creek Fort McKay Indian Reserve 174C ") Fort McKay I.R KILOMETRES Date: File ID: :300,000 UTM Zone 12 NAD 83 Author: CS Checked: JC (Original page size: 8.5X11) Acknowledgements: Base data: AltaLIS, Hydrology ground truthed by Golder (2009). Figure 72c-1: Modelled Noise Contours (Project Only) Frontier Project Response to Supplemental Information Request: Round 3 ESRD/CEAA

330 T103 R13 W4 R12 R11 Ronald Lake R10 R9 ³ Chipewyan I.R. Unnamed Waterbody 20 Unnamed Waterbody 19 Unnamed Waterbody 14 R1 ") Chipewyan Indian Reserve 201G ") T102 Unnam ed Cre ek 18 R10 ") Unnamed Creek 17 Unnamed Creek 16 Unnamed Creek 19 Athabasca River T101 Unnamed Waterbody 29 R15 ") Unnamed Waterbody 12 Redclay Creek Unnamed Waterbody 13 ") R14 T100 Unnamed Waterbody 16 R11 ") Unnamed Creek 7 Firebag River T99 Eymundson Creek Asphalt Creek R12 ") R5 ") R13 ") R4 ") R3 ") Joslyn Creek T98 Tar River Calumet River R8 R2 ") ") Pierre Ri ve r R7 ") R6 ") McClelland Lake Noise T97Receptor ") Trapper Cabin ") Local Study Area Boundary ") Other Maximum sound level exceeding 35 dba Lillian Lake Acoustics Local Study Area Project Area Calumet Lake PRM Township Defined Watercourse Undefined Watercourse Waterbody I.R. Fort Creek Fort McKay Indian Reserve 174C ") Fort McKay I.R KILOMETRES Date: File ID: :300,000 UTM Zone 12 NAD 83 Author: CS Checked: JC (Original page size: 8.5X11) Acknowledgements: Base data: AltaLIS, Hydrology ground truthed by Golder (2009). Figure 72c-2: Modelled Bird Cannon Noise Frontier Project Response to Supplemental Information Request: Round 3 ESRD/CEAA

331 T103 R13 W4 R12 R11 Unnamed Waterbody 20 Unnamed Waterbody 19 Unnamed Waterbody 14 R10 Chipewyan I.R. R1 ") Chipewyan Indian Reserve 201G ") R9 ³ T102 Unn am ed C reek 18 R10 ") Unnamed C reek 17 Unnamed Creek 16 Unnamed Cr eek 19 Athabasca River T101 Unnamed Waterbody 29 R15 ") Unnamed Waterbody 12 Redclay Creek Unnamed Waterbody 13 ") R14 T100 Unnamed Waterbody 16 R11 ") Unnamed Creek 7 Firebag River T99 Eymundson Creek Asphalt Creek R12 ") R5 ") R13 ") R4 ") R3 ") Joslyn Creek T98 Tar River Calumet River R8 R2 ") ") Pierre River Pierre River Mine R7 ") R6 ") McClelland Lake Lillian Lake T97 Noise Receptor ") Trapper Cabin ") Local Study Area Boundary ") Other Acoustics Local Study Area 3 km Buffer around Frontier, PRM, Fort Hills Projects Project Area Calumet Lake PRM Fort Hills Project Township Defined Watercourse Undefined Watercourse Waterbody I.R. Fort Creek Fort Hills Fort McKay Indian Reserve 174C ") Fort McKay I.R KILOMETRES Date: File ID: :300,000 UTM Zone 12 NAD 83 Author: CES Checked: JC (Original page size: 8.5X11) Acknowledgements: Base data: AltaLIS, Hydrology ground truthed by Golder (2009). Figure 72c-3: Perceptible Noise Boundary (3 km around Frontier, PRM and Fort Hills Projects) Frontier Project Response to Supplemental Information Request: Round 3 ESRD/CEAA

332 ESRD and CEAA Responses Approvals Frontier Oil Sands Mine Project Figure 72c-1 shows the nighttime equivalent sound level (L eq ) noise contour for the Project. The contour represents the continuous noise effect of the Project without the intermittent noise contribution from the bird cannons. In Figure 72c-1, the 35 dba contour line represents the outer limit where the Project noise effect is the same as the nighttime ASL. The Project continuous noise effect is considered just perceptible outside the 35 dba contour line (see Figure 72c-1). As a result, land users at the 35 dba contour line might hear the continuous sounds of Project operation depending on where mine-related activity is occurring. The magnitude of the predicted continuous Project noise effect will decrease with increasing distance from noise sources. It is important to note that if the baseline sound level is greater than the ASL of 35 dba (i.e., because of cumulative noise effects), the perceptibility of the Project noise effect will be less. Bird cannons around the external tailings area (ETA) and other Project ponds are expected to fire intermittently and one at a time (at a rate of 15 blasts per minute). The firing of multiple bird cannons simultaneously is not expected; however, a worst-case scenario of five bird cannons firing all at once has been assessed at the ETA. The maximum sound level (L max ) is an acoustic parameter that represents the maximum sound level during the duration of an event. Figure 72c-2 includes a hatched green area, which is where the predicted L max is 35 dba or greater during the simultaneous firing of five bird cannons. This worst-case bird cannon noise effect is considered just perceptible outside the 35 dba contour line (see Figure 72c-2). Therefore, land users might hear the intermittent sounds of bird cannons at this 35 dba contour line. This area includes an approximately 12 km portion of the Athabasca River as well as regions northeast of the Project that have been identified as preferred traditional land use areas by Aboriginal communities. Regarding cumulative noise effects, the Project has the potential to act in combination with noise effects from the PRM and the Fort Hills project. Assuming each of these three developments meet Directive 038 requirements at 1.5 km, a 3 km buffer would represent a boundary where cumulative noise from these projects would be less than the 35 dba ASL. At 3 km, cumulative noise effects may be just perceptible to a land user. Figure 72c-3 identifies the 3 km cumulative effects buffer. d. See the response to part i. e. References relevant to the acoustics assessment include: Candler et al. (2013a) Candler et al. (2013b) Fort McKay Industry Relations Corporation (2010) Fort McKay Tribal Administration (1983) Fort McKay Sustainability Department (2011) Labour et al. (2012) MacDonald (2012) As indicated in response to parts a and c, no references are available that quantitatively assess the acoustic environment in terms of remoteness and solitude. ESRD/CEAA Page 330 October 2014

333 Frontier Oil Sands Mine Project ESRD and CEAA Responses Approvals MCFN has told Teck that it has concerns with the degree and manner with which MCFN s traditional knowledge and Aboriginal perspectives have been considered and incorporated by Teck, particularly in the assessment of impacts to MCFN s rights and culture. This response does not incorporate traditional knowledge. To this end, Teck acknowledges the need for further engagement regarding this SIR and Teck will revisit this SIR and conclusions contained in it once the parties have pursued the collaborative process that Teck and MCFN are working to develop and as additional information is gathered. ACFN has clearly stated that it has concerns with the degree and manner with which ACFN s traditional knowledge and Aboriginal perspectives have been considered and incorporated by Teck, particularly in the assessment of impacts to ACFN s rights and culture. Recognizing that additional work needs to be done, Teck has requested to meet with ACFN to co-create a process to address outstanding concerns, to revisit certain conclusions made by Teck in the, and to work toward understanding and incorporating ACFN s traditional land use and traditional knowledge into the assessment in a meaningful way. Teck will update regulators on a regular basis about the progress of these discussions. Teck will not be filing responses to Round 3 SIRs that pertain to traditional knowledge or the assessment of impacts to ACFN s rights and culture with regulators until the parties have pursued the collaborative process referred to above, or until Teck and ACFN agree otherwise. f. A copy of the memo regarding acoustic, air quality and odour modelling at the cabin belonging to a Fort McKay member and trapper is provided in Appendix 72f.1. g. Teck is in discussion with Fort McKay, ACFN, MCFN, Métis Local 125 and Métis Local 1935 regarding community-led, Project-specific cultural impact assessments for the Project. Upon completion of these assessments, Teck intends to work with each community to develop a process to meaningfully incorporate the additional information into the Project assessment and planning. Accordingly, Teck is not providing a response to this SIR at this time. h. Teck has requested to meet with Métis Nation of Alberta Region 1 (MNA R1) to continue to discuss its concerns and interests with respect to the Frontier Project, but no meeting dates have been successful for MNA R1. Teck is undertaking traditional use studies and cultural impact assessments with the Métis Locals represented by this organization. MNA R1 has informed Teck that they represent Métis peoples in the region who do not belong to a Métis Local and who may undertake traditional pursuits in the Frontier Project area. Teck has offered to meet with these members of MNA R1 to discuss interests and concerns with respect to the Frontier Project, including impacts to traditional land use. Teck will continue to engage MNA R1 with respect to the Project to better understand concerns, interests and potential effects. Teck looks forward to meeting with MNA R1 to discuss concerns that have been resolved, those that remain outstanding, and ways in which Teck can work with MNA R1 in a manner that supports issue resolution. October 2014 ESRD/CEAA Page 331

334 ESRD and CEAA Responses Approvals Frontier Oil Sands Mine Project i. Teck recognizes that commercial rights to a Registered Fur Management Area (RFMA) are not the same as collectively held Aboriginal rights. Teck consults with potentially affected Aboriginal communities, including those whose Aboriginal rights are associated with the use of the areas with affected traplines. To understand the potential effects of the Frontier Project on rights associated with affected traplines, Teck needs to understand the traditional land use associated with the traplines. Teck has received several TLU reports and is now in a position to integrate this information into the assessment. Teck and MCFN have agreed to work together to: co-create a process to address outstanding interests and concerns revisit certain conclusions made by Teck in the assessment help Teck understand and incorporate their Aboriginal perspectives, including indigenous knowledge and values, into Project planning in a meaningful way Teck has invited ACFN to co-create a process to meaningfully address ACFN concerns and further consider the ACFN traditional use study (TUS) in the Frontier Project assessment and planning. At the time of drafting this response, Teck and ACFN are in discussions about ACFN s participation in such a process. Teck is hopeful that outcomes of such a process, if pursued, could provide additional information to this SIR and other related SIRs and SOCs. Teck and Fort McKay have agreed to work collaboratively in parallel to the regulatory process to develop a common understanding of effects to Fort McKay rights and traditional land use, including identifying if there are mitigation measures that would be culturally appropriate and supported by Fort McKay. Teck and Fort McKay do not anticipate that this process will affect regulatory timelines. However, information might emerge that Fort McKay or Teck believes is critical to inform the Joint Review Panel report. If so, we will update the future panel. Teck intends to work with Métis Local 125 and Métis Local 1935 to discuss development of a similar process to meaningfully incorporate additional information into Project assessment and planning once TUS information is available. REFERENCES Bies, D.A. and C.H. Hansen Engineering Noise Control Theory and Practice, Third Edition. New York, United States of America. Candler, C., the Firelight Group Research Cooperative, with the Athabasca Chipewyan First Nation. 2013a. Athabasca Chipewyan First Nation Knowledge and Use Report and Assessment for Teck Resources Limited Proposed Frontier Oil Sands Mine Project. November 20, Candler C., R. Olson, the Firelight Group Research Cooperative, with the Mikisew Cree First Nation. 2013b. Mikisew Cree First Nation Indigenous Knowledge and Use Report and Assessment for Teck Resources Limited s Proposed Frontier Oil Sands Mine Project. November 15, ESRD/CEAA Page 332 October 2014

335 Frontier Oil Sands Mine Project ESRD and CEAA Responses Approvals Fort McKay Industry Relations Corporation Cultural Heritage Assessment Baseline: Pre-development (1960s) to Current (2008). March Fort McKay Sustainability Department Traditional Land Use Study for the Teck and SilverBirch Frontier Project. August 9, Fort McKay Tribal Administration From Where We Stand. Fort McKay, Alberta. Labour, S., B. Dickson and Management and Solutions in Environmental Science Cumulative Impacts to FMFN #468 Traditional Lands & Lifeways: Shell Jackpine Mine Expansion and Pierre River Mine. Report for Regulatory Hearings. Prepared for Fort McMurray First Nation #468. September 4, MacDonald, A Athabasca Chipewyan First Nation Supplemental Social, Economic and Cultural Effects Submission for Shell Canada s Proposed Jackpine Mine Expansion. Prepared on behalf of Athabasca Chipewyan First Nation. September 29, Ontario Ministry of Natural Resources (2001). Management Guidelines for Forestry and Resource-Based Tourism. Forest Management Branch, Tourism Guidelines Working Group, Toronto, Ontario. July 19, Question 73 Volume 1, ESRD/CEAA SIR 138 b, Page 397 It is recognised that the MCFN and ACFN submissions referred to in SIR 138 b are related to Teck s winter drilling program. It is also recognised that Teck s exploration activities are not a component of the Frontier Oil Sands Mine Project, and are regulated and permitted by Alberta Environment and Sustainable Resource Development (ESRD) and the Alberta Energy Regulator (AER). However, the Canadian Environmental Assessment Agency s Operational Policy Statement on Assessing Cumulative Environmental Effects under the Canadian Environmental Assessment Act, 2012, requires that: each EA of a designated Project take into account any cumulative environmental effects that are likely to result from the designated Project in combination with the environmental effects of other physical activities that have been or will be carried out. The cumulative effects assessment should include not only the effects of the Frontier Project but also the cumulative effects of past, existing and foreseeable future activities and Projects. The assessment should include the effects of Teck s exploration activities in the vicinity of the proposed Frontier Project. This is especially the case for the assessment of effects to the Ronald Lake bison herd. October 2014 ESRD/CEAA Page 333

336 ESRD and CEAA Responses Approvals Frontier Oil Sands Mine Project a. Amend the cumulative effects assessment for the Frontier Oil Sands Mine Project to include the potential adverse effects of the Project on traditional land use in the vicinity of the Frontier Project footprint as described in the December 21, 2012 submission from MCFN to Alberta, and the November 2, 2012 submission from ACFN to Alberta and Teck. b. Discuss how Teck proposes to mitigate these potential adverse effects. Response 73 a. Teck is committed to engaging potentially affected Aboriginal communities, including ACFN and MCFN, in a discussion about cumulative effects related to the Frontier Project and other activities, including exploration work, especially as it relates to potential effects on the Ronald Lake bison herd. ACFN has expressed dissatisfaction with many of Teck s responses to ACFN s issues and concerns, including those related to bison. Teck has heard that ACFN would like Teck to address issues with the aim of resolving them rather than responding to issues without clear resolution. Teck is open to working on such an effort with ACFN in good faith. To this end, Teck has invited ACFN to co-create a process to meaningfully address ACFN concerns and further consider ACFN traditional knowledge and land use in the Project assessment and planning, including exploration work. At the time of drafting this response, Teck and ACFN are in discussions about ACFN s participation in such a process. Teck is hopeful that outcomes of such a process, if pursued, could provide additional information to this SIR and other related SIRs and SOCs. MCFN have stated that they have concerns with the degree and manner with which their traditional knowledge and Aboriginal perspectives have been considered and incorporated by Teck, particularly in assessing impacts to MCFN s rights and culture. Recognizing that additional work needs to be done, Teck and MCFN have agreed to work together to co-create a process to address outstanding interests and concerns and to revisit certain conclusions made by Teck in the assessment. MCFN has agreed to work with Teck to understand and incorporate their Aboriginal perspectives, including traditional knowledge and values, into the assessment in a meaningful way. The December 22, 2012 submission from MCFN to Alberta and the November 2, 2012 submission from ACFN to Alberta and Teck were both related to the winter drilling program that Teck proposed. Concerns raised by MCFN and ACFN focused on: proximity of the winter drilling program to traditional use sites direct and adverse effects experienced by bison, bison habitat and the ability for MCFN and ACFN to harvest bison effects on other traditionally harvested wildlife species and their habitats, including caribou and moose effects on sound levels, air and water from the winter drilling program in relation to wildlife movement and the ability for MCFN and ACFN to harvest wildlife ESRD/CEAA Page 334 October 2014

337 Frontier Oil Sands Mine Project ESRD and CEAA Responses Approvals effects on water crossings and working near the Athabasca River, Big Creek and Redclay Creek cumulative effects and the pace of development, particularly in the Point Brule and Poplar Point Homeland Zones and the area north of the Firebag River, including the Richardson backcountry b. Teck is engaged in two consultation efforts that focus on mitigating potential adverse effects on traditional land use: The first involves conducting a cultural impact assessment with ACFN and MCFN. In addition to ACFN and MCFN traditional use studies, the cultural impact assessment should, in part, assess effects on traditional practices and the transmission of traditional knowledge. The second focuses on engaging in deeper consultation with ACFN and MCFN about future winter drilling programs and the Frontier Project. At the time of writing, Teck, ACFN and MCFN are in the early stages of these conversations. As part of the winter drilling program application and regulatory approval process, Teck has worked with ESRD to develop mitigation measures to limit effects on the environment and on wildlife. For mitigation plans from the winter drilling program, see Appendix 73b.1. Going forward, mitigation and management plans aimed at eliminating, reducing, offsetting and monitoring the effects on traditional land use (including direct effects to wildlife and indirect effects to ability to hunt) will be developed with direct input from potentially affected Aboriginal communities. Supplemental information included in the cultural impact assessment, traditional use studies and wildlife studies (e.g., those related to bison and other workplans planned for 2014) will contribute to the development of mitigation measures and related monitoring plans for winter drilling. Teck looks forward to further engaging ACFN, MCFN and other potentially affected Aboriginal communities in developing additional mitigation measures to address Aboriginal concerns with Teck s exploration activities. Question 74 Volume 1, ESRD/CEAA SIR 139, Page 436 Volume 1, ESRD/CEAA SIR 155, Page 450 An assessment of the effects of the Project on traditional resources is not an assessment of the effect of the Project on the current use of land and resources for traditional purposes (commonly referred to as Traditional Land Use (TLU)). A recent Joint Review Panel report (Jackpine Mine Expansion Panel Report par. 1268) in the oil sands region found that assessing the effects of that Project on traditional resources was not sufficient to assess the effects of the Project on TLU. The Jackpine Panel stated that a combination of the following factors may foster avoidance of traditional use: noise, perceived bad air quality and unpleasant odours, perceived contamination of surface water and country food or other resources, barriers to access, cultural factors, etc. October 2014 ESRD/CEAA Page 335

338 ESRD and CEAA Responses Approvals Frontier Oil Sands Mine Project a. Provide an assessment of the potential direct and cumulative effects of the Project on TLU, for example due to cultural or spiritual preferences, access, or patterns of traditional use. This assessment should include consideration of all available traditional knowledge regarding the effects of existing oil sands developments on noise, air quality, odour, water quality, country foods and other resources in the TLU Regional Study Area. b. Identify and justify the information sources, results of consultation, and professional judgement on which Teck has based this assessment. c. To allow an assessment of the potential effects of the Project on Aboriginal peoples under section 5(1)(c) of CEAA 2012, provide information on all potentially affected Aboriginal groups, including the Métis. Response 74 a. At this time, Teck Resources has received Project-specific TLU studies from Fort McKay (First Nation and Métis), ACFN and MCFN. Teck received the Fort McKay TLU study during finalization of the for the Frontier Project. At that time, Fort McKay requested that its TLU study be included in the Integrated Application. Accordingly, Teck provided the Fort McKay TLU study in Volume 8, Appendix 6A: Traditional Land Use Study for the Teck and SilverBirch Frontier Project (Fort McKay Sustainability Department 2011). The Fort McKay TLU was not fully integrated into the EIA and, as such, Fort McKay has expressed concerns to Teck about information gaps in Teck s TLU assessment for the Project. Teck and Fort McKay are currently working outside of the regulatory process to resolve outstanding concerns regarding TLU incorporation. Teck received a copy of MCFN s Indigenous Knowledge and Use Report and Assessment in November 2013 (Candler et al. 2013a) and a copy of ACFN s Knowledge and Use Report and Assessment in February 2014 (Candler et al. 2013b). As follow-up, Teck has invited MCFN and ACFN to participate in a collaborative discussion about the content of these TLU studies. Teck plans to work with each community to identify the most appropriate way to consider and incorporate traditional land use information into the assessment and future Project planning. Teck is currently funding Project-specific TLU studies by Métis Local 125 and Métis Local These studies are expected to be completed in fall 2014 or early Upon receipt of these studies, Teck will follow up with each community to co-create an ongoing process of engagement. This process will focus on understanding how Métis Local 125 and Métis Local 1935 might work with Teck to incorporate traditional land use information and traditional knowledge into Project planning and execution in a meaningful way. An updated TLU assessment, as requested in the SIR, will be provided following completion of the processes outlined above. ESRD/CEAA Page 336 October 2014

339 Frontier Oil Sands Mine Project ESRD and CEAA Responses Approvals b. The requested information (i.e., information sources, results of consultation and professional judgement used in the assessment) will be provided and explained as part of the updated TLU assessment. As indicated, the updated assessment will be provided once the processes outlined in the response to part a are complete. c. See the response to part a. REFERENCES Candler, C., Firelight Group Research Cooperative, with the Mikisew Cree First Nation. 2013a. Mikisew Cree First Nation Indigenous Knowledge and Use Report and Assessment for Teck Resources Limited s Proposed Frontier Oil Sands Mine Project. November 15, Submitted to the Mikisew Cree First Nation Government and Industry Relations. Candler, C., Firelight Group Research Cooperative, with the Athabasca Chipewyan First Nation. 2013b. Athabasca Chipewyan First Nation Knowledge and Use Report and Assessment for Teck Resources Limited Proposed Frontier Oil Sands Mine Project. November 20, Submitted to the Athabasca Chipewyan First Nation Industry Relations Corporation. Fort McKay Sustainability Department Traditional Land Use Study for the Teck and SilverBirch Frontier Project. August 9, Question 75 Volume 1, ESRD/CEAA SIR 141, Page 438 Volume 1, ESRD/CEAA SIR 142, Page 440 Volume 1, ESRD/CEAA SIR 146, Page 443 Volume 1, ESRD/CEAA SIR 154, Page 449 Volume 1, ESRD/CEAA SIR 157, Page Several of Teck s responses regarding traditional land use and impacts to Aboriginal groups rely on the Access Management Plan (AMP) as mitigation. However an AMP has not yet been provided and little detail is available as to what will be included in the AMP. The conceptual AMP will be reviewed not only by certain Aboriginal groups and ESRD, but by all Aboriginal groups, the Panel and all Government departments involved in the review. The final AMP will also be reviewed by all these parties. The AMP cannot be relied on to mitigate effects unless Government and the Panel (once appointed) have an opportunity to provide input on the plan. a. Provide a conceptual AMP as part of the environmental assessment which includes, at minimum, the following components. i. Explain who will be granted access under the management plan; ii. Explain the process through which individuals will be granted access under the AMP; October 2014 ESRD/CEAA Page 337

340 ESRD and CEAA Responses Approvals Frontier Oil Sands Mine Project iii. Describe the situations under which individuals would not be granted access under the AMP, and; iv. Identify locations within the Project area where Aboriginal persons will have access in order to conduct their traditional activities during each stage of the life of the mine. b. Summarize the updates to all of the responses to SIRs where the response relies on the AMP. c. Provide a description of the consultation activities undertaken with all potentially affected Aboriginal groups that occurred in development of the AMP. d. Discuss whether Teck has considered creating a working group with potentially affected Aboriginal groups, including Métis, to address the AMP. Response 75 a. Teck recognizes that access to traditional lands is a key aspect of the maintenance of traditional culture(s). A thoughtful and thorough access management plan (AMP) can facilitate access to traditional lands. It is Teck s position that the overall purpose of the land AMP is to safely manage all aspects of land access (including the type and quantity of access) through an area that is being developed. Access management plans are developed in collaboration with regulators, Aboriginal communities and stakeholders to consider all interests, including safety. Teck is in the early stages of consultation with Aboriginal communities on an AMP specific to the Frontier Project. Through conversations and the various traditional land use, traditional knowledge and use studies, and other studies provided by and with the Aboriginal communities, Teck is beginning to understand the interests and concerns these communities have about access. Furthermore, some issues raised by Aboriginal communities point specifically to concerns about access. Teck intends to discuss access to and through the Project area with potentially affected Aboriginal communities in a collaborative manner. These discussions will become more detailed and specific as information is available. Teck recognizes that engaging Aboriginal communities, regulators and future panel members to review the land AMP will be an important aspect of understanding residual (post-mitigation) effects to Aboriginal rights related to land use and access. MCFN has told Teck that it has concerns with the degree and manner with which MCFN s traditional knowledge and Aboriginal perspectives have been considered and incorporated by Teck, particularly in assessing impacts to MCFN s rights and culture. This response does not incorporate traditional knowledge. To this end, Teck acknowledges the need for further engagement regarding this SIR. Teck will revisit this SIR and conclusions contained in it once the parties have pursued the collaborative process that Teck and MCFN are working to develop and as additional information is gathered. ACFN has clearly stated that it has concerns with the degree and manner with which ACFN s traditional knowledge and Aboriginal perspectives have been considered and incorporated by Teck, ESRD/CEAA Page 338 October 2014

341 Frontier Oil Sands Mine Project ESRD and CEAA Responses Approvals particularly in the assessment of impacts to ACFN s rights and culture. Recognizing that additional work needs to be done, Teck has requested to meet with ACFN to co-create a process to address outstanding concerns, to revisit certain conclusions made by Teck in the, and to work toward understanding and incorporating ACFN s traditional land use and traditional knowledge into the assessment in a meaningful way. Teck will update regulators on a regular basis about the progress of these discussions. Teck will not be filing responses to Round 3 SIRs that pertain to traditional knowledge or the assessment of impacts to ACFN s rights and culture with regulators until the parties have pursued the collaborative process referred to above, or until Teck and ACFN agree otherwise. Teck has developed a draft table of contents for the conceptual AMP, which is provided in Appendix 75a.1. i. All individuals wanting to gain access to or through lands being actively developed, which is generally Teck s mineral surface lease (MSL), will be required to submit an access request. Access to and through the site may be granted to workers and non-workers, defined as follows: Workers include Teck employees or contractors. Non-workers include all other site visitors, including regulators and Teck employees visiting the site on a non-regular basis and all other non-employees. Traditional and other land users would be considered visitors in the land AMP, although their relationship with the land is more complex and meaningful than a typical visitor. Traditional and other lands users will also be granted access to and through the Project area according to the policy and processes set out in the AMP. Workers will be granted permanent site access, while visitors, traditional and other land users will be granted temporary site access. Workers will also have to meet certain site access requirements (e.g., safety training, drug and alcohol testing). Visitors, traditional and other land users will not have to meet worker site access requirements but will be escorted by someone who has permanent site access. Access to active zones of the Project area will typically be restricted to workers only; visitors, including most regulators, traditional and other land users would have no access or limited access to active areas of the site to ensure the safety of all. Access through the Project area will be possible and will not require an access request form be submitted. Individuals will be required to contact the site s security office and provide adequate notice about when they plan to be in the area, who will be present, and the intended activities and general location(s) as they relate to Teck leases. All individuals passing through the Project area will have to check in at the security office and will be escorted by a Teck worker. Teck understands that Aboriginal communities desire that the advance notice period be as short as possible and expects that this issue will be discussed during future consultation for the AMP. October 2014 ESRD/CEAA Page 339

342 ESRD and CEAA Responses Approvals Frontier Oil Sands Mine Project ii. There are two types of access: 1) access to areas within the MSL 2) access through the MSL Both will be managed by a site access procedure. The site access procedure will be developed before on-site activity begins and will manage the people, vehicles and materials entering the Project area. Teck has broad experience developing land AMPs that include consideration and inclusion of Aboriginal communities' interests, in Alberta and around the world. The site access procedure will include a step-by-step process for workers and visitors (e.g., traditional land users wanting to access the site for hunting purposes) and would include: providing contact information for anyone entering the site (i.e., names, phone numbers and addresses or emergency contact information) completing forms to describe the purpose, areas and dates access is required, and any materials, vehicles or equipment that would be brought on (including through) the site Anyone accessing the Project area or wanting to pass through the Project area will have to pass through a security office. Advance notice will be required to ensure that security office staff is present at the requested time. All visitors will be escorted by an individual that has permanent site access (i.e., a worker). iii. Access might not be granted if there are unusual operating conditions that could potentially affect the safety of anyone on or around the Project area. In addition, anyone suspected of being under the influence of drugs or alcohol, or travelling in vehicles that are deemed unsafe will not be granted site access. The land AMP will outline the types of activities or actions that might require a person to be removed from the site (e.g., repeatedly not abiding by the Teck escort directions and causing a safety concern to themselves or others). These details will be drafted based on Teck s experience with similar AMPs at Teck sites in other jurisdictions, and other AMPs in the Athabasca oil sands region. iv. Throughout the life of the mine, access to locations in the Project area by Aboriginal communities members will be based on mine advance (see Figures 75a-1 to 75a-5). Additional traditional use areas and options for accessing these locations will be determined during consultation with ESRD and potentially affected Aboriginal communities. For safety reasons, harvesting and use of firearms would not be permitted in areas being actively mined or within and around facilities associated with the mine. b. A summary of revisions to all SIR responses (Rounds 1 and 2) that rely on the AMP is provided in Table 75b-1. ESRD/CEAA Page 340 October 2014

343 750 T102 R12 W4 R11 Unnamed Creek 18 Unnamed Creek 17 Unnamed Creek 16 R10 R9 Unnamed Cree k 19 ³ 600 T101 Unnamed Waterbody 12 Redclay Creek Unnamed Waterbody 13 Redclay Creek Athabasca River T100 Unnamed Creek 7 Unnamed Lake 1 U n na med Creek 2 Big Creek Unnamed Creek 6 Eymundson Creek T99 Asphalt Creek First Creek Unnamed Waterbody 15 Unnamed Waterbody 8 T98 Unnamed Waterbody 10 Pierre River Project Area (Mine Year 0) Traditional Trail Defined Watercourse Undefined Watercourse Waterbody McClelland Lake T97 KILOMETRES 1:200,000 UTM Zone 12 NAD 83 Acknowledgements: Base data: AltaLIS, Hydrology ground truthed by Golder (2009), Lillian Lake Figure 75a-1: Traditional Trails and Project Area at Mine Year 0 Frontier Project Response to Supplemental Information Request: Round 3 ESRD/CEAA Date: File ID: Author: CS Checked: SL (Original page size: 8.5X11)

344 750 T102 R12 W4 R11 Unnamed Creek 18 Unnamed Creek 17 Unnamed Creek 16 R10 R9 Unnamed Cree k 19 ³ 600 T101 Unnamed Waterbody 12 Redclay Creek Unnamed Waterbody 13 Redclay Creek Athabasca River T100 Unnamed Creek 7 Unnamed Lake 1 U n na med Creek 2 Big Creek Unnamed Creek 6 Eymundson Creek T99 Asphalt Creek First Creek Unnamed Waterbody 15 Unnamed Waterbody 8 T98 Unnamed Waterbody 10 Pierre River Project Area (Mine Year 5) Traditional Trail Defined Watercourse Undefined Watercourse Waterbody McClelland Lake T97 KILOMETRES 1:200,000 UTM Zone 12 NAD 83 Acknowledgements: Base data: AltaLIS, Hydrology ground truthed by Golder (2009), Lillian Lake Figure 75a-2: Traditional Trails and Project Area at Mine Year 5 Frontier Project Response to Supplemental Information Request: Round 3 ESRD/CEAA Date: File ID: Author: CS Checked: SL (Original page size: 8.5X11)

345 750 T102 R12 W4 R11 Unnamed Creek 18 Unnamed Creek 17 Unnamed Creek 16 R10 R9 Unnamed Cree k 19 ³ 600 T101 Unnamed Waterbody 12 Redclay Creek Unnamed Waterbody 13 Redclay Creek Athabasca River T100 Unnamed Creek 7 Unnamed Lake 1 U n na med Creek 2 Big Creek Unnamed Creek 6 Eymundson Creek T99 Asphalt Creek First Creek Unnamed Waterbody 15 Unnamed Waterbody 8 T98 Unnamed Waterbody 10 Pierre River Project Area (Mine Year 16) Traditional Trail Defined Watercourse Undefined Watercourse Waterbody McClelland Lake T97 KILOMETRES 1:200,000 UTM Zone 12 NAD 83 Acknowledgements: Base data: AltaLIS, Hydrology ground truthed by Golder (2009), Lillian Lake Figure 75a-3: Traditional Trails and Project Area at Mine Year 16 Frontier Project Response to Supplemental Information Request: Round 3 ESRD/CEAA Date: File ID: Author: CS Checked: SL (Original page size: 8.5X11)

346 750 T102 R12 W4 R11 Unnamed Creek 18 Unnamed Creek 17 Unnamed Creek 16 R10 R9 Unnamed Cree k 19 ³ 600 T101 Unnamed Waterbody 12 Redclay Creek Unnamed Waterbody 13 Redclay Creek Athabasca River T100 Unnamed Creek 7 Unnamed Lake 1 U n na med Creek 2 Big Creek Unnamed Creek 6 Eymundson Creek T99 Asphalt Creek First Creek Unnamed Waterbody 15 Unnamed Waterbody 8 T98 Unnamed Waterbody 10 Pierre River Project Area (Mine Year 31) Traditional Trail Defined Watercourse Undefined Watercourse Waterbody McClelland Lake T97 KILOMETRES 1:200,000 UTM Zone 12 NAD 83 Acknowledgements: Base data: AltaLIS, Hydrology ground truthed by Golder (2009), Lillian Lake Figure 75a-4: Traditional Trails and Project Area at Mine Year 31 Frontier Project Response to Supplemental Information Request: Round 3 ESRD/CEAA Date: File ID: Author: CS Checked: SL (Original page size: 8.5X11)

347 750 T102 R12 W4 R11 Unnamed Creek 18 Unnamed Creek 17 Unnamed Creek 16 R10 R9 Unnamed Cree k 19 ³ 600 T101 Unnamed Waterbody 12 Redclay Creek Unnamed Waterbody 13 Redclay Creek Athabasca River T100 Unnamed Creek 7 Unnamed Lake 1 U n na med Creek 2 Big Creek Unnamed Creek 6 Eymundson Creek T99 Asphalt Creek First Creek Unnamed Waterbody 15 Unnamed Waterbody 8 T98 Unnamed Waterbody 10 Pierre River Project Area (Mine Year 37) Traditional Trail Defined Watercourse Undefined Watercourse Waterbody McClelland Lake T97 KILOMETRES 1:200,000 UTM Zone 12 NAD 83 Acknowledgements: Base data: AltaLIS, Hydrology ground truthed by Golder (2009), Lillian Lake Figure 75a-5: Traditional Trails and Project Area at Mine Year 37 Frontier Project Response to Supplemental Information Request: Round 3 ESRD/CEAA Date: File ID: Author: CS Checked: SL (Original page size: 8.5X11)

348 ESRD and CEAA Responses Approvals Frontier Oil Sands Mine Project Table 75b-1 Revisions to SIR Responses (Rounds 1 and 2) Regarding the AMP SIR Excerpt or Summary of SIR Summary of Response Round 3 SIR Revision ESRD/CEAA Round 1 SIR 8a ESRD/CEAA Round 1 SIR 8b ESRD/CEAA Round 1 SIR 8c How will Teck ensure traditional users will be able to practice their treaty rights and traditional uses during different phases of the project? What strategies and recommendations are planned to allow traditional users into the area? Discuss whether Teck has any plans to limit non-aboriginal users from utilizing these same resources. Round 1 SIRs General AMP development discussion, in collaboration with Aboriginal communities, other land users and ESRD. Continued access through the PDA and associated traditional land use LSA (see Volume 8, Section , Page 6-19) to areas identified by Aboriginal communities and other land users. A summary of key mitigation measures to reduce effects of the Project on traditional land use are provided in Volume 1, Section , Table , Pages to Where practical, provide sequenced access, both before areas are disturbed and once they are progressively reclaimed, through the AMP. Strategies and recommendations to enable traditional users to continue their use of the PDA will be outlined in the AMP, which will be developed in consultation with potentially affected Aboriginal communities, other land users and ESRD. Teck does not plan to limit non-aboriginal users from using these same resources. Teck will impose firearm restrictions for recreational purposes and restrict on-site hunting and fishing by Project personnel. Project personnel will not generally have access to vehicles with which to travel off-site as the Project is a fly-in/fly-out operation. Teck will consult with potentially affected Aboriginal communities in developing an AMP for the Project. Teck will consult with First Nation and Métis communities for the AMP in a manner that meets Aboriginal community needs and expectations. This might include the creation of a working group specific to the development of the Frontier Project AMP. Teck is not in a position to pre-suppose the form of these consultations. Teck is in the early stages of consultation with Aboriginal communities with regard to an AMP specific to the Project. Teck attended a two-day workshop with Fort McKay and industry to discuss access concerns. These consultation activities will continue to ensure that concerns expressed by potentially affected Aboriginal communities regarding access are identified and captured in the AMP. For safety reasons, harvesting and use of firearms would not be permitted in areas being actively mined or within and around facilities associated with the mine. Hunting and harvesting will be permitted in areas that are not active. ESRD/CEAA Page 346 October 2014

349 Frontier Oil Sands Mine Project ESRD and CEAA Responses Approvals Table 75b-1 Revisions to SIR Responses (Rounds 1 and 2) Regarding the AMP (cont d) SIR Excerpt or Summary of SIR Summary of Response Round 3 SIR Revision ESRD/CEAA Round 1 SIR 316c ESRD/CEAA Round 1 SIR 316c Table 316c-1 addresses potential impacts to identified Aboriginal and treaty rights, including the right to: hunt, fish, trap and harvest natural resources within Fort McKay s Traditional Territory pursue their way of life the use, enjoyment and control of lands reserved for them a livelihood from their traditional lands Treaty rights, including the right to: hunt, fish, trap and harvest natural resources within Fort McKay s traditional territory pursue their way of life the use, enjoyment and control of lands reserved for them a livelihood from their traditional lands Round 1 SIRs (cont d) Consultation to ensure identified effects, and the duration of these effects, are minimized to support identified concerns. A key AMP objective is to maintain access to and along existing roads in the PDA that provide access to important recreational areas outside the PDA (such as Namur and Moose lakes; see Volume 1, Section , Table , Page 17-38). Where practical, provide sequenced access, both before areas are disturbed and once they are progressively reclaimed, through the development of the AMP (see Volume 1, Section , Table , Page 17-39). Access to and along existing roads will be maintained unless they intersect with the Project. In the event of removing an existing road, alternate routes may be identified and considered during consultation. Teck has committed to developing a Reclamation Working Group and inviting potentially affected Aboriginal communities to attend to ensure their concerns are captured. October 2014 ESRD/CEAA Page 347

350 ESRD and CEAA Responses Approvals Frontier Oil Sands Mine Project Table 75b-1 Revisions to SIR Responses (Rounds 1 and 2) Regarding the AMP (cont d) SIR Excerpt or Summary of SIR Summary of Response Round 3 SIR Revision ESRD/CEAA Round 1 SIR 316c ESRD/CEAA Round 1 SIR 316c Although Alberta has the ability to take up lands for mining and other purposes pursuant to Treaty 8, this right is limited by Fort McKay s right to sufficient lands, and access to them, within their traditional territory, of a quality and nature sufficient to support the meaningful exercise of their treaty rights. Aboriginal rights; which include the harvesting rights of the Métis, and the right to site-specific cultural practices and features Round 1 SIRs (cont d) The AMP will ensure that identified impacts, and the duration of these impacts, are minimized to support hunting, fishing, gathering, and trapping while maintaining public safety. One of the primary objectives of the AMP will be to maintain access to and along existing roads in the PDA, such as the Birch Mountain Forestry Road in the southern portion of the PDA, that provide access to important recreational areas outside the PDA (such as Namur and Moose lakes; see Volume 1, Section , Table , Page 17-38). The AMP will be developed so that Fort McKay and other Aboriginal community members can retain access to sites and features of cultural significance, outside of the active mine site, to undertake sitespecific cultural practices. See Volume 8, Section 6 for an outline of traditional land use mitigation measures. Teck recognizes that Aboriginal communities have a right to sufficient lands, and access to them, within their traditional territory. These lands must be of a quality and nature sufficient to support the meaningful exercise of rights. Development of an AMP, in consultation with potentially affected Aboriginal communities, is expected to contribute to the mitigation of impacts specific to access. Teck intends to approach potentially affected Aboriginal communities to co-create a process to address outstanding interests and concerns and work with Teck to understand and incorporate their Aboriginal perspectives, including indigenous knowledge and values, into the assessment in a meaningful way. We expect this process of addressing issues and concerns will also include addressing issues related to land access and land use including an understanding of the quality and nature of resources required to ensure Aboriginal rights can be exercised in a meaningful way. Access to these areas will depend on mine progression. ESRD/CEAA Page 348 October 2014

351 Frontier Oil Sands Mine Project ESRD and CEAA Responses Approvals Table 75b-1 Revisions to SIR Responses (Rounds 1 and 2) Regarding the AMP (cont d) SIR Excerpt or Summary of SIR Summary of Response Round 3 SIR Revision ESRD/CEAA Round 1 SIR 316c ESRD/CEAA Round 1 SIR 316c ESRD/CEAA Round 1 SIR 316c The right to hunt for food in all seasons pursuant to the Natural Resources Transfer Agreement (being schedule 2 of the Constitution Act, 1930). The right to commercial fur harvesting by community members who hold Registered Fur Management Areas (RFMAs) pursuant to the Wildlife Regulation, Alta Reg. 143/1997. Routes of access and transportation Round 1 SIRs (cont d) Consultations will continue with Fort McKay and other potentially affected Aboriginal communities regarding, providing sequenced access, where practical. This would apply before areas are disturbed and once they are progressively reclaimed through the development of the AMP (see Volume 1, Section , Table , Page 17-39). The AMP would include the provision for allseason access for hunting. Teck will work with the trapline holder to understand how Teck can support access to and use and enjoyment of the RFMA. The AMP developed for the Project will support access to traplines that may be reached through the PDA. Access management concerns will be addressed through development of an AMP, in cooperation with ESRD, potentially affected Aboriginal communities, public stakeholders and industry, for the Project area. The purpose of this AMP will be to manage access in and through the Project area as much as possible while maintaining public safety. Among the objectives of the AMP will be to: support hunting opportunities for Aboriginal community members provide access through the PDA to Moose Lake and the Moose Lake trial, the larger Birch Mountain area, a burial ground along the Athabasca River and access to lease land and lands adjacent to the Project for traditional use. Access to and along existing roads will be maintained unless they intersect with the Project area. In the event of removing an existing road, alternate routes will be proposed during consultation. No revision. No revision. October 2014 ESRD/CEAA Page 349

352 ESRD and CEAA Responses Approvals Frontier Oil Sands Mine Project Table 75b-1 Revisions to SIR Responses (Rounds 1 and 2) Regarding the AMP (cont d) SIR Excerpt or Summary of SIR Summary of Response Round 3 SIR Revision ESRD/CEAA Round 1 SIR 316c ESRD/CEAA Round 1 SIR 316c Cultural and spiritual relationships with the land. Abundant berry crops in preferred harvesting areas. Round 1 SIRs (cont d) Teck will actively consult with the ACFN and, when the traditional use study becomes available, Teck will discuss potential effects of the Project, including cultural avoidance of particular areas, with the ACFN. Teck will work with the ACFN to identify opportunities to develop and implement culturally appropriate avoidance or mitigation measures. See Volume 8, Section 6 for an outline of traditional land use mitigation measures. Teck will work with potentially affected Aboriginal communities to ensure that species of traditional importance are incorporated into reclamation planning, as feasible, to monitor reclamation activities, and adapt reclamation plans to incorporate community feedback as well as new techniques arising from research completed in the region (see Volume 1, Section , Table , Page 17-40). Teck will continue to consult with the ACFN as more detailed conservation and reclamation plans are developed for the Project. Teck has received and reviewed ACFN s Knowledge and Use Report and Assessment, dated November 2013 (received February 2014). The work to incorporate ACFN s traditional knowledge, use and values into the land management plans, including access management, will be most successful if done in consultation with ACFN. To this end, Teck invited ACFN to cocreate a process to address outstanding interests and concerns and work with Teck to understand and incorporate their Aboriginal perspectives, including indigenous knowledge and values, into the assessment in a meaningful way. We expect this process of addressing issues and concerns will also include addressing issues related to land access and land use. Teck has committed to developing a Reclamation Working Group and inviting Aboriginal communities to attend to ensure their concerns are captured and considered in reclamation planning. ESRD/CEAA Page 350 October 2014

353 Frontier Oil Sands Mine Project ESRD and CEAA Responses Approvals Table 75b-1 Revisions to SIR Responses (Rounds 1 and 2) Regarding the AMP (cont d) SIR Excerpt or Summary of SIR Summary of Response Round 3 SIR Revision ESRD/CEAA Round 1 SIR 316c ESRD/CEAA Round 1 SIR 316c Lands and resources accessible within constraints of time and cost; Quality and quantity of plants or other things gathered Round 1 SIRs (cont d) Teck has committed to develop an AMP in cooperation with ESRD and potentially affected Aboriginal communities to ensure that identified effects, and the duration of these effects, are minimized to support hunting, fishing, and trapping (see Volume 1, Section 13.8, Page ). Also see the response to part d (316) for an assessment of the environmental consequences of changes in traditional access, wildlife and plant harvesting and fishing. Consultation will continue with the MCFN and other potentially affected Aboriginal communities regarding the progressive reclamation of landscapes that will support sequenced access, both before areas are disturbed and once they are progressively reclaimed, through the development of an AMP (see Volume 1, Section , Table , Page 17-39). Teck recognizes that there remains a difference of views on the potential effect and consequences of the Project on Aboriginal valued components, including traditional plants, wildlife and traditional access. Teck is working with potentially affected Aboriginal communities to co-create processes for including traditional knowledge and Aboriginal values and perspectives into the assessment of consequences from changes to traditional access, wildlife, and plant harvesting. Teck expects this collaborative work and inclusion of traditional knowledge will inform and contribute to an AMP. Teck has committed to developing a Reclamation Working Group and inviting potentially affected Aboriginal communities to attend to ensure their concerns are captured and considered in reclamation planning. October 2014 ESRD/CEAA Page 351

354 ESRD and CEAA Responses Approvals Frontier Oil Sands Mine Project Table 75b-1 Revisions to SIR Responses (Rounds 1 and 2) Regarding the AMP (cont d) SIR Excerpt or Summary of SIR Summary of Response Round 3 SIR Revision ESRD/CEAA Round 1 SIR 316c ESRD/CEAA Round 1 SIR 319a ESRD/CEAA Round 1 SIR 319b Use of lands for hunting, trapping and gathering How will traditional land use activities be mitigated for locations in the Project area during construction and operation that will only re-instate full access in 2068? Provide a summary of the acceptability of the proposed mitigation to each potentially affected First Nation. Round 1 SIRs (cont d) Teck has committed to develop an AMP in consultation with ESRD and potentially affected Aboriginal communities to ensure that identified impacts, and the duration of these impacts, are reasonably minimized to support hunting, fishing, gathering, and trapping while maintaining public safety. One of the primary objectives of the AMP will be to maintain access to and along existing roads in the PDA, such as the Birch Mountain Forestry Road in the southern portion of the PDA, that provide access to important recreational areas outside the PDA (such as Namur and Moose Lakes). The AMP will be designed to address identified effects and the duration of these effects, to support hunting, fishing, and trapping. Consultation efforts will inform the AMP, particularly the identification of key areas of traditional use for Aboriginal communities, to target land accessibility, and to reach agreements with potentially affected Aboriginal communities. Teck agrees that access management concerns will be addressed through the development of an AMP with ESRD and in consultation with Fort McKay, other potentially affected Aboriginal communities and stakeholders. However, Teck will follow the direction of ESRD in the development of the draft plan but will work to advance that activity in consultation with all parties. Teck is in the early stages of consultation with Aboriginal communities with regard to an AMP specific to the Project. Among other considerations, consultation on a Frontier AMP will consider how access to sites of traditional land use value can be maintained, where feasible. Teck is in the early stages of consultation with Aboriginal communities about an AMP specific to the Project. Among other considerations, consultation on a Projectspecific AMP will consider how access to sites of traditional land use value can be maintained, where feasible. Teck recognizes that there remains a difference of views on the potential effect and consequences of the Project on Aboriginal valued components, including traditional plants, wildlife, and traditional access. Teck is working with potentially affected Aboriginal communities to co-create processes for including traditional knowledge and Aboriginal values and perspectives into the assessment of consequences from changes to traditional access, wildlife, and plant harvesting. Teck expects this collaborative work and inclusion of traditional knowledge will inform and contribute to an AMP. ESRD/CEAA Page 352 October 2014

355 Frontier Oil Sands Mine Project ESRD and CEAA Responses Approvals Table 75b-1 Revisions to SIR Responses (Rounds 1 and 2) Regarding the AMP (cont d) SIR Excerpt or Summary of SIR Summary of Response Round 3 SIR Revision ESRD/CEAA Round 1 SIR 454c ESRD/CEAA Round 1 SIR 471 Regarding protecting wildlife from harassment: Because the Project will result in increased access to a previously remote and largely inaccessible area, how will Teck ensure no harassment (and increased mortality) of wildlife by Project and non-project personnel, including in WBNP. Provide a draft of the access management plan as part of the EA Round 1 SIRs (cont d) The AMP will control access in and through PDA. The AMP may be able to control access to areas outside the PDA, which could otherwise be made more accessible because of roads associated with the Project. However, in general, Teck cannot address access to other areas, such as WBNP. It is unlikely that an AMP will be finalized by ESRD until it is clear that Project will receive approval. Steps for developing AMP draft: 1. Receive remaining First Nation TLU studies. 2. Meet with ESRD to discuss access concerns. 3. Meet with potentially affected Aboriginal communities to develop a draft AMP. 4. Meet with ESRD to communicate the proposed AMP for their approval process. Discussion of some elements that the AMP will include (i.e., public safety; hunters, trappers, key land user access through PDA; access to not mined leased land and through PDA; maintenance of existing roads in PDA). No revision. See the response to parts a and b; see also Appendix 75a.1 for a draft outline of an AMP. October 2014 ESRD/CEAA Page 353

356 ESRD and CEAA Responses Approvals Frontier Oil Sands Mine Project Table 75b-1 Revisions to SIR Responses (Rounds 1 and 2) Regarding the AMP (cont d) SIR Excerpt or Summary of SIR Summary of Response Round 3 SIR Revision ESRD/CEAA Round 2 SIR 56b ESRD/CEAA Round 2 SIR 71 Teck indicates that they will not discourage access to the lakes, but will prohibit motorized traffic and hunting. It appears that Teck is assuming that these lakes will become a recreational opportunity primarily for residents of the camp. Confirm where the security gate will be placed for the mine and discuss if it will be placed in an area that would prohibit the public from accessing these unnamed lakes. Provide areas with access restrictions over life of mine and options for alternative access around the restricted areas. Round 2 SIRs The security gate for the Project will likely be at the plant site. This location would not directly prevent public access to Unnamed Lakes 1 and 2. Access will be managed to ensure safe mining and will be informed by the AMP. a) An outline of anticipated restricted access areas was provided. Among these locations are the aerodrome; lodge; plant site and associated infrastructure. b) The AMP will identify alternate access around restricted areas. Irrespective of the location of the site s security gate, Teck will implement a number of measures to prevent workers from accessing and undertaking recreational pursuits near the Project area. These areas are within the Project site and access to these areas will be managed through a site access procedure. The procedure will be developed before operation begins. Access to active areas of the Project site will likely be restricted to workers only; visitors and traditional land users would have no access or limited access to active areas of the Project site to ensure the safety of all. ESRD/CEAA Page 354 October 2014

357 Frontier Oil Sands Mine Project ESRD and CEAA Responses Approvals Table 75b-1 Revisions to SIR Responses (Rounds 1 and 2) Regarding the AMP (cont d) SIR Excerpt or Summary of SIR Summary of Response Round 3 SIR Revision ESRD/CEAA Round 2 SIR 138 Provide further detail to supplement the response to Question 311, Part 'a': The information needs to be separated out for each Aboriginal group. Round 2 SIRs (cont d) Table 138a-1 includes discussion of access throughout mine life, and the development of an AMP. Teck is in the early stages of consultation with Aboriginal communities with regard to an AMP specific to the Project. Among other considerations, consultation on the Frontier Project AMP will consider how access to sites of traditional land use value can be maintained, where feasible Maps showing when traditional trails will be no longer available are provided in Figures 75a-1 to Teck has committed to developing a Reclamation Working Group and potentially affected Aboriginal communities will be asked to participate. Access during and after reclamation will be discussed during the Reclamation Working Group sessions. Teck is open to creating a Project-specific access management working group (similar to the reclamation working group) as a venue to consult on an AMP for the Project and monitor the success of the AMP through the life of the Project. For safety reasons, harvesting and use of firearms would not be permitted in areas being actively mined or within and around facilities associated with the mine. Hunting and harvesting will be permitted in areas that are not active. October 2014 ESRD/CEAA Page 355

358 ESRD and CEAA Responses Approvals Frontier Oil Sands Mine Project Table 75b-1 Revisions to SIR Responses (Rounds 1 and 2) Regarding the AMP (cont d) SIR Excerpt or Summary of SIR Summary of Response Round 3 SIR Revision ESRD/CEAA Round 2 SIR 142 ESRD/CEAA Round 2 SIR 146 For all affected First Nations and Métis, provide detail on the features and practices, and concrete details (including quantifiable examples) on how the effects will be mitigated beyond having management plans. Provide detail and examples of how ACFN members will retain access to sites to undertake site-specific cultural practices Round 2 SIRs (cont d) Access management planning is an important mitigation measure to manage effects on traditional land use. Teck will initiate discussions about access management with potentially affected Aboriginal communities starting in Where possible, Teck will ensure that access to sites and features of cultural significance is retained. This will be accomplished through a comprehensive AMP. Teck is in the early stages of consultation with Aboriginal communities with regard to an AMP specific to the Project. Among other considerations, consultation on an AMP for the Project will consider how access to sites of traditional land use value can be maintained, where feasible Teck has received the ACFN and MCFN TLU studies and plans to discuss the information presented in the report with ACFN and MCFN. A table of specific concerns and practices, and how Teck will address those concerns through access management, will be provided when results are available. Teck has received the ACFN traditional land use study and plans to discuss the information presented in the report with ACFN. Consultation with ACFN will focus on protection, mitigation and other methods of enabling access to site and on understanding site-specific cultural practices. A more detailed report or table of concerns and examples and associated mitigations will be an outcome of this consultation process. ESRD/CEAA Page 356 October 2014

359 Frontier Oil Sands Mine Project ESRD and CEAA Responses Approvals Table 75b-1 Revisions to SIR Responses (Rounds 1 and 2) Regarding the AMP (cont d) SIR Excerpt or Summary of SIR Summary of Response Round 3 SIR Revision ESRD/CEAA Round 2 SIR 147 ESRD/CEAA Round 2 SIR 148 ESRD/CEAA Round 2 SIR 154 Explain how Teck has engaged with each First Nation or Métis group when assessing the potential impact their project may have on these groups ability to experience remoteness and solitude, and feelings of safety and security. a) Provide mitigation in consideration of impacts to lands and resources within time and cost constraints. b) How will the success of access management be measured? Provide a full assessment of effects due to changes in access. a) increased access by non-aboriginal hunters b) places and related species not accessible during construction and operation Round 2 SIRs (cont d) Teck is open to discussing ways it can support Aboriginal communities in feeling safe, secure and having the opportunity to experience remoteness and solitude on the land. These discussions could occur in the context of planning access management during the life of the Project. a) Teck is not in a position to provide specific details at this time to address concerns about constraints of time and cost. Teck plans to consider these potential constraints when developing the AMP during additional consultation with potentially affected Aboriginal communities. b) Teck has developed a feedback mechanism that includes an account and number. Teck is open to continual improvement of access across the Project. a) Teck will be legally obligated to provide access to all citizens. b) Traditional land uses in the PAA were qualitatively and quantitatively assessed in the (see Volume 8, Section 6). Teck recognizes that access to the land is only one aspect of the continuance of traditional land use. Cultural impact assessments and collaborative work around the inclusion of traditional knowledge and land use into the Project (design, mitigation and management) is an important and specific undertaking that Teck has committed to conducting. Teck expects to undertake discussions with Aboriginal communities about their concerns with the ability of their members to experience remoteness and solitude while the Frontier Project is in operation. Maps showing when traditional trails will be no longer available are provided in Figures 75a-1 to Teck will continue to consult with Aboriginal communities in developing an AMP for the Project. Site access will be managed by a site access procedure. Additionally, the AMP will include a section on hunting and firearms. October 2014 ESRD/CEAA Page 357

360 ESRD and CEAA Responses Approvals Frontier Oil Sands Mine Project Table 75b-1 Revisions to SIR Responses (Rounds 1 and 2) Regarding the AMP (cont d) SIR Excerpt or Summary of SIR Summary of Response Round 3 SIR Revision ESRD/CEAA Round 2 SIR 157 In order to understand whether the mitigation is adequate, information is needed within the environmental assessment about how access will be managed. c) Provide a map of open trails and waterways at different project phases that will be open to access by Aboriginal persons d) Provide how the success of mitigation will be measured e) Explain how Teck has engaged each First Nation or Métis group during AMP development. Round 2 SIRs (cont d) c) Terrestrial trails occurring in the PDA will be unavailable during the timeframes outlined in the. Teck will develop an AMP in consultation with potentially affected Aboriginal communities to address concerns regarding access to areas where traditional pursuits are undertaken. e) Teck will engage potentially affected Aboriginal communities through meetings and written correspondence. Teck is in the early stages of consultation with Aboriginal communities with regard to an AMP specific to the Project. Among other considerations, consultation on an AMP will consider how access to sites of traditional land use value can be maintained, where feasible. Teck will also seek to understand how success can be measured, especially from an Aboriginal community perspective. Teck is open to creating a Project-specific access management working group (similar to the reclamation working group) as a venue to consult on an AMP and monitor the success of the AMP through the life of the Project. Maps showing when traditional trails will be no longer available are provided in Figures 75a-1 to ESRD/CEAA Page 358 October 2014

361 Frontier Oil Sands Mine Project ESRD and CEAA Responses Approvals c. As outlined in response to part a, Teck is in the early stages of consultation with Aboriginal communities regarding an AMP specific to the Project. Aboriginal communities have expressed concerns about access to areas traditionally used. Teck plans to continue to discuss these concerns with Aboriginal communities, including how a Project-specific AMP could mitigate access concerns. Teck is also learning from local Aboriginal communities about the challenges they face related to access and other developments in the region. These learnings will support Project-specific consultation and planning regarding access. Fort McKay invited Teck to participate in a series of workshops with operators on the east side of the Athabasca River and Fort McKay traditional land users. The goals were to discuss Fort McKay east-side access challenges and collaboratively develop solutions to Fort McKay access challenges. Although Teck does not consider its participation in these workshops to constitute consultations for the Frontier Project AMP, Teck participants gained insight into: specific access challenges experienced by Fort McKay traditional land users operator constraints opportunities to provide access and find solutions to some of these challenges Teck will consider concerns, constraints and opportunities discussed at these workshops when developing a detailed AMP for the Project. To this end, Teck acknowledges the need for further engagement with Aboriginal communities and stakeholders about the AMP. d. The concept of an access management working group fits with Teck s desire to work more collaboratively with Aboriginal communities towards solutions. Teck will explore the concept of a working group with potentially affected Aboriginal communities and will consult with First Nation and Métis communities about the Frontier Project AMP in a manner that meets Aboriginal community needs and expectations. Question 76 Volume 1, ESRD/CEAA SIR 141, Page 438 Volume 1, ESRD/CEAA SIR 142, Page, 440 Volume 1, ESRD/CEAA SIR 146, Page 443 Volume 1, ESRD/CEAA SIR 154, Page 449 Volume 1, ESRD/CEAA SIR 157, Pages 450 to 454 In addition to federal SIR # 2.6 of December 23, 2013, the conceptual Access Management Plan (AMP) that is provided, include: a. An explanation of how the AMP will incorporate cultural and spiritual values, b. An explanation of how the AMP will address avoidance reactions, c. An explanation of how the AMP will facilitate preferred TLU activities, October 2014 ESRD/CEAA Page 359

362 ESRD and CEAA Responses Approvals Frontier Oil Sands Mine Project d. In addition to the description of the consultation activities requested in part (c) of SIR #2.6, after Teck has consulted on a draft conceptual AMP, a summary of Aboriginal comments received on the draft AMP and description of how Teck has addressed those concerns, e. An explanation of how Teck will incorporate traditional knowledge into the AMP. Response 76 a. Teck has previously stated that it will consult with potentially affected Aboriginal communities to understand the areas and sites important to these communities (see the response to ESRD/CEAA Round 1 SIR 316). Discussion about the cultural and spiritual values of these areas will be part of the meetings with potentially affected Aboriginal communities to discuss the AMP. These meetings will take place before the AMP is finalized. b. Teck understands that avoidance reactions can occur and reflect land users views that land near an industrial development, and the animals living off that land are unsafe. Access management plans aim to manage access to and through an active site and may not be the most appropriate place to address avoidance reactions. Teck will continue to consult with Aboriginal communities about avoidance reactions and how these reactions might be addressed. c. Preferred traditional land use activities in the Project area will be identified before the AMP is finalized. This will include identifying specific sites or areas in which these activities occur and access opportunities or limitations. During consultations and development of a detailed AMP for the Project, Teck will identify how the AMP can maintain access to these areas. Teck is committed to maintaining access to these sites, when possible. d. As stated in the response to ESRD/CEAA Round 3 SIR 75, Teck has not begun consultations specific to the AMP. Teck representatives attended a series of workshops in May and June 2014 where Fort McKay traditional land users and operators east of the Athabasca River discussed and worked to resolve concerns regarding access (for details, see the response to ESRD/CEAA Round 3 SIR 75c). Teck will consider concerns expressed during these workshops in developing an AMP for the Project. e. Teck has received traditional use studies from Fort McKay, ACFN and MCFN. Teck and Fort McKay are currently working outside the regulatory process to address outstanding concerns, including concerns about traditional land use. Teck has invited ACFN and MCFN to co-create a process to address outstanding concerns and meaningfully include traditional knowledge in Project planning. Teck intends to engage ACFN and MCFN in AMP consultations, including a discussion of how traditional knowledge can inform the AMP. ESRD/CEAA Page 360 October 2014

363 Frontier Oil Sands Mine Project ESRD and CEAA Responses Approvals Question 77 Volume 1, ESRD/CEAA SIR 141, Page 438 Volume 1, ESRD/CEAA SIR 142, Page 440 In the response to ESRD/CEAA SIR 141, Teck stated that the reclaimed land would support vegetation suitable for traditional land use, but have not assessed the effects resulting from the changes in the landscape. a. Provide details on the fraction of each eco-type that will be reclaimed. b. Explain the effects of these changes on the potential for traditional use. The success of the mitigation measures for the effects of the Project on Traditional Land Use in the Project area is uncertain. c. Provide a follow-up and monitoring program for Traditional Land Use, including Métis use, in the vicinity of the Project and the Regional Study Area. d. Describe the additional mitigation measures that Teck will implement if the monitoring program indicates that the currently proposed mitigation measures are not successful. e. Explain how Teck will involve potentially affected Aboriginal groups in this follow up and monitoring program, including discussing methodology and results. Response 77 a. For the amount of each ecosite phase and wetland class in the revised PDA, see Table 77a-1. b. MCFN has told Teck that it has concerns with the degree and manner with which MCFN s traditional knowledge and Aboriginal perspectives have been considered and incorporated by Teck, particularly in the assessment of impacts to MCFN s rights and culture. This response does not incorporate traditional knowledge. To this end, Teck acknowledges the need for further engagement regarding this SIR and Teck will revisit this SIR and conclusions contained in it once the parties have pursued the collaborative process that Teck and MCFN are working to develop and as additional information is gathered. ACFN has clearly stated that it has concerns with the degree and manner with which their traditional knowledge and Aboriginal perspectives have been considered and incorporated by Teck, particularly in the assessment of impacts to ACFN s rights and culture. Recognizing that additional work needs to be done, Teck has requested to meet with ACFN to co-create a process to address outstanding concerns, to revisit certain conclusions made by Teck in the, and to work toward understanding and incorporating ACFN s traditional land use and traditional knowledge into the assessment in a meaningful way. October 2014 ESRD/CEAA Page 361

364 ESRD and CEAA Responses Approvals Frontier Oil Sands Mine Project Teck will update regulators on a regular basis about the progress of these discussions. Teck will not be filing responses to Round 3 SIRs that pertain to traditional knowledge or the assessment of impacts to ACFN s rights and culture with regulators until the parties have pursued the collaborative process referred to above, or until Teck and ACFN agree otherwise. c. During consultations, some Aboriginal communities have expressed an interest in forming a Reclamation Working Group. A Reclamation Working Group could guide reclamation planning so that the reclaimed landscape supports traditional land uses (i.e., use of traditional use plants, vegetation and landforms that support culturally significant species). Teck expects that a Reclamation Working Group could develop an appropriate follow-up and monitoring program to evaluate the potential for the reclamation landscape to support traditional land uses. However, Teck considers it premature at this time to advance such a plan without additional input from and consultation with potentially affected Aboriginal communities. Therefore, Teck is not providing a follow-up or monitoring program in this response, but will provide details on such a program following further consultation with potentially affected Aboriginal communities. d. If monitoring results indicate that proposed mitigation measures are not successful (e.g., certain traditional use plants are not growing as expected), Teck (potentially through a Reclamation Working Group) will develop adaptive management strategies to reassess the mitigation measures and pursue alternative measures. Teck has more than 40 years of reclamation experience from across Canada and the world (for examples from western Canada, see the response to ESRD/CEAA Round 2 SIR 78a). Teck is confident that it understands the challenges inherent to mined land reclamation and that it is well prepared to address these challenges in collaboration with potentially affected Aboriginal communities. It is Teck s opinion that a viable reclamation landscape can support the potential for traditional land uses. e. As described in the responses to parts a, b and c, Teck is open to forming a Reclamation Working Group that will include potentially affected Aboriginal communities, representatives from Teck and technical experts. The Reclamation Working Group could provide a forum in which to jointly develop reclamation methodology, desired outcomes and a monitoring program that would meet the objectives of the group as well as regulators. ESRD/CEAA Page 362 October 2014

365 Frontier Oil Sands Mine Project ESRD and CEAA Responses Approvals Table 77a-1 Predisturbance and Conceptual Closure Ecosite Phases and Wetland Class Distributions in the PDA Upland Ecosite Phase and Lowland Wetland Class Traditional Use Potential Ranking Uplands Existing Area Closure Area Change (ha) (%) (ha) (%) (ha) (%) a1: Jack pine/lichen Moderate b1: Jack pine aspen/blueberry Moderate 1, , b2: aspen white birch /blueberry High b3: aspen white spruce/blueberry High 58 < ,351.7 b4: white spruce Jack pine/blueberry High 15 < ,273.3 c1: mesic Jack pine black spruce/labrador tea Moderate 62 <1 1, ,083 1,746.8 d1: aspen/low-bush cranberry High 3, , , d2: aspen-white spruce/low-bush cranberry High , , d3: white spruce-aspen/low bush cranberry High e1: balsam poplar aspen/dogwood High 1, , e2: balsam poplar white spruce/dogwood High , , e3: white spruce/dogwood High f1: balsam poplar-aspen/horsetail High f2: balsam poplar-white spruce/horsetail High f3: white spruce/horsetail High 13 < g1:subhygric black spruce Jack pine/labrador tea Moderate 141 <1 1, , h1: white spruce-black spruce/labrador tea High 140 <1 1, Upland graminoid Moderate 1 < Upland shrubland Moderate Subtotal Upland 10, , , October 2014 ESRD/CEAA Page 363

366 ESRD and CEAA Responses Approvals Frontier Oil Sands Mine Project Table 77a-1 Predisturbance and Conceptual Closure Ecosite Phases and Wetland Class Distributions in the PDA (cont d) Upland Ecosite Phase and Lowland Wetland Class Traditional Use Potential Ranking Wetlands Existing Area Closure Area Change (ha) (%) (ha) (%) (ha) (%) Forested bogs without internal lawns (BFNN) Low Wooded bogs without internal lawns (BTNN) Low Nonpatterned, open, graminoid-dominated fens (FONG) Low Nonpatterned, open, shrub-dominated fens (FONS) Low 1, , Nonpatterned, wooded fens with no internal lawns (FTNN) Low Marshes (MONG) Low Shrubby swamps (SONS) Moderate 1, , , Forested swamps- (SFNNcs, SFNNhs and SFNNms) Moderate Wooded swamps- (STNNcs, STNNhs and STNNms) Low 6, , Shallow open water (WONN) Moderate Littoral Low Subtotal Wetlands 12, , , Water Not ranked 2 0 2, , ,550.0 Disturbed Not ranked NOTE: Percentage totals might not add up to 100% because of rounding. Total 24, , ESRD/CEAA Page 364 October 2014

367 Frontier Oil Sands Mine Project ESRD and CEAA Responses Approvals Question 78 Volume 1, ESRD/CEAA SIR 141, Page 438 Volume 1, ESRD/CEAA SIR 142, Page 440 In addition to federal SIR # 2.7 of December 23, 2013, provide the following information: a. Examples of successful reclamation of vegetation suitable for traditional land use, b. A summary of Aboriginal comments received to date, and a description of how Teck has addressed those concerns. Response 78 a. In developing the CC&R plan for the Frontier Project, Teck considered: a variety of Acts, regulations, guidance documents, regional plans, industry best practices and peer-reviewed literature (see Volume 1, Section , Pages 13-5 to 13-7) traditional land uses and concerns expressed by potentially affected Aboriginal communities (see Volume 1, Section , Page 13-8; Section , Pages 13-8 to 13-9 and Section 13.8, Pages to ) research focused specifically on reclamation of traditional use species (Smrecui and Gould 2010) Native vegetation, including plants used by Aboriginal communities and wildlife, has been included in planting mixes at Teck mines since the 1970s (O Brien and Straker 2010). These plants have become a priority in many recent mine reclamation projects (Stantec 2012). A large number of plant species (both native and introduced) have been identified as used by Aboriginal peoples in western Canada for traditional purposes (i.e., edible, medicinal, ritual or otherwise useful) (Marles et al. 2000; Moerman 1998; Ritch-Krc 1992; Turner 1997, 1998). In the, effects on traditional use species were evaluated based on available species information in reports prepared for previous environmental assessments in the Athabasca Oil Sands Region (e.g., Cardinal 2009; Fort McKay IRC 2009; Fort McKay 1995). For details, see Volume 8, Section 6.6, Pages 6-23 to 6-45 and the response to ESRD/CEAA Round 1 SIR 474c. As part of a COSIA-led initiative to outline state-of-the-art mining reclamation practices, Teck has contributed knowledge from its 40 years of mine reclamation experience at its steel-making coal mines in western Canada (Cranston and Leskiw 2014). Teck s reclamation experience and knowledge transfer relates to three areas of operation: the Cheviot and Luscar mines (collectively referred to as Cardinal River Operations [CRO]), in southwest Alberta Elk Valley, in southeast British Columbia the northeast coal block, in British Columbia October 2014 ESRD/CEAA Page 365

368 ESRD and CEAA Responses Approvals Frontier Oil Sands Mine Project The reports Teck provided to COSIA, specifically O Brien and Straker (2010) and Straker et al. (2012), are included as appendices to this response (see Appendices 78a.1 and 78a.2). This response summarizes findings from these reports as well as additional published materials and research related to operational reclamation of native species and their use by Aboriginal communities. Together, these studies demonstrate the effectiveness of native plant establishment, natural ingress of native vegetation on reclaimed lands, and research trials in improving reclamation practices and restoring ecosystems that can support traditional land use. RECLAMATION AS MITIGATION TO EFFECTS OF MINING Research into factors that affect plant establishment on reclaimed mine sites has been completed by Teck and others since the 1970s (O Brien and Straker 2010; Straker et al [Appendices 78a.1 and 78a.2]). Key factors that contribute to successful establishment of native vegetation on reclaimed landscapes include: suitable soil properties (i.e., soil nutrients [fertilization], ph and soil texture) proper surface preparation reducing the risk of metal and other trace element uptake in vegetation appropriate revegetation treatments (i.e., species selected for reclamation including the proportions of woody, non-woody and agronomic species) These factors are identified in Walker (2005); Arregoces et al. (2008); Polster (2011); Klassen (1974); and Smyth (1995) and discussed in the context of Teck s steel-making coal mine properties in British Columbia and Alberta. A summary (by factor and mine location) is provided in Table 78a-1. SOIL PROPERTIES Soil properties such as available nutrients, ph and coarse-fragment content affect the establishment and growth of native vegetation on reclaimed lands (Sharman and Smyth 2002; Walker 2005; Arregoces et al. 2008). Research has shown that baseline studies can help identify soil-limiting factors to vegetation re-establishment prior to mine construction (O Brien and Straker 2010); referring to these studies during replanting can guide fertilization or soil amendment requirements. Accounting for known deficiencies in growth medium at the time of replanting or reseeding can expedite the establishment and growth of native vegetation communities. Research has shown that soil salvage leads to improved vegetation establishment when used for capping disturbed areas (Przeczek and Ryder 2011; Strong 1994). Other growth medium (such as amended or augmented soil and subsoil [regolith]) can also successfully support native vegetation reestablishment provided that adequate soil nutrients occur (naturally or through fertilization) (Walker 2005). Coal spoil (waste rock) has also been proven to provide adequate substrate for plant growth, including conifers and agronomics species (especially legumes) in certain situations (O Brien and Straker 2010; Knapik et al. 1995). ESRD/CEAA Page 366 October 2014

369 Frontier Oil Sands Mine Project ESRD and CEAA Responses Approvals Growth medium ph is a critical factor for native vegetation re-establishment (Walker 2005; Arregoces et al. 2008) and to a lesser extent, growth medium texture. Growth-inhibiting ph values are common in subsoil/regolith material (Walker 2005; Arregoces et al. 2008). Fertilization and augmentation can be used to amend the ph of reclamation growth medium to successfully support the reestablishment of native vegetation on the site. Table 78a-1 summarizes results of studies conducted on Teck properties that focus on soil properties of reclaimed landscapes. The Project s conceptual CC&R plan recognized the importance of soil properties and incorporated eight different soil prescriptions to provide a range of substrate conditions and associated site types on the reclaimed landscape (see Volume 1, Section , Pages to 13-69). SURFACE PREPARATION Land surface preparation can play a key role in native plant establishment, particularly in northern environments. Research that has been ongoing since the 1970s at Teck s Cardinal River Operations (including the Luscar and Cheviot Mines) has shown that decompacted, rough soils support greater germination and establishment of native vegetation species than compacted or smooth surfaces (O Brien and Straker 2010; Smyth 2002). Microsites created by rough-mounding soils or creating a hummocky landscape protect seeds and seedlings from extreme weather conditions (e.g., wind and very low temperatures) (Polster 2011). Although some species, such as legumes, can thrive in smooth-graded soils, rough-graded soils tend to support higher vegetation establishment overall (Klassen 1974; Strong 1999; Polster 2011). Placement of large stumps and various sizes of coarse woody debris can help create microsites and a slow-addition nutrient supply (Paquin and Brinker 2011; Polster 2013). Decompaction is also a critical component to successful revegetation of sites (Westar 1986). Studies that describe the relationship between surface preparation techniques and native plant establishment are summarized in Table 78a-1. The Project s conceptual CC&R plan recognized the importance of surface preparation in reclamation outcomes, including the incorporation of coarse woody debris to maximize microsites (see Volume 6, Section , Pages 3-55 to 3-57). This approach is supported by innovations from oil sands specific research. TRACE ELEMENT UPTAKE The uptake of trace metals and elements by vegetation on reclaimed landscapes is of special concern when discussing plants that might be used for consumption by people or animals (Swaine 2000). Studies conducted on this aspect of land reclamation include O Brien and Straker (2010) and Smyth (2002) and results are site specific (see Table 78a-1). Research from northeastern British Columbia demonstrates the importance of comprehensive baseline studies of trace metal and element uptake prior to construction. Elevated levels of trace metals and elements can occur naturally and are not always a function of development. October 2014 ESRD/CEAA Page 367

370 ESRD and CEAA Responses Approvals Frontier Oil Sands Mine Project For the Frontier Project, background concentrations of total metals in watercourses located in the revised LSA were relatively high for waters in the oil sands region, especially in Redclay Creek. Values above chronic water quality guidelines were observed for aluminum, arsenic, chromium, lead, iron, copper, chromium, nickel, selenium, silver, zinc and mercury. Manganese concentrations routinely are greater than the Health Canada drinking water guidelines and Canadian Council of Ministers of the Environment (CCME) agricultural water use guidelines (see Volume 2, Section , Pages 5-61 to 5-62). Elevated values represent natural background levels of these metals likely resulting from erosion of polymetallic black shales in the Birch Mountain region. REVEGETATION: NATIVE PLANT SPECIES ESTABLISHMENT AND INGRESS Reestablishment of native vegetation, including traditional use plants, on disturbed mine sites is undertaken to support end land use objectives identified in reclamation plans. Studies conducted on the establishment, growth and natural ingress of native species has been ongoing in mining since at least the 1970s (Lesko et al. 1975; Horstmann and Bachmann 1975; Smyth 1995; Smyth and Kovak 2002; Longman 2010; Lister 2010; Polster 2013). These studies have provided extensive information that can be used to inform future reclamation species selection and refine planting prescriptions and predicted reclamation timelines. Native vegetation reestablishment includes both non-woody (grasses and forbs) and woody (trees and shrubs) species. Native species may be established in reclaimed areas through reclamation seeding or planting activities or due to ingress of native species through a number of natural processes (i.e., seed drop, dispersal by wind, water, animals or birds). Smyth and Kovak (2002) monitored reclamation performance at the Line Creek mine in the Elk Valley of British Columbia. Revegetation programs have been ongoing at the site since 1980, and permanent monitoring plots (including undisturbed reference sites) were established at that time. Natural ingress of native species, particularly grasses and forbs, was found to be increasing over time (Smyth and Kovak 2002). Other studies conducted from 1975 to the present have also demonstrated success in reestablishing native vegetation on reclaimed northern mine sites (Lesko 1975; Smyth 1995; Smyth 2002; Lister 2010). However, O Brien and Straker (2010) conclude that native species colonization of reclaimed sites is low and indicated by a lack of native species in most sampled reclaimed sites where planting has not occurred. Results of studies that considered native plant ingress onto disturbed or reclaimed lands at British Columbia mines are discussed in Table 78a-1. REVEGETATION: WOODY SPECIES ESTABLISHMENT Studies conducted on woody species (trees and shrubs) establishment (either by direct seeding or planting) indicate that appropriate species selection is critical (Polster 2013; O Brien and Straker 2010; Smyth 1995, 2000). Plant species selected for revegetation must also meet end land use ESRD/CEAA Page 368 October 2014

371 Frontier Oil Sands Mine Project ESRD and CEAA Responses Approvals objectives identified in the planning process. Species should be selected based on available substrate, appropriate ecosystem type and successional appropriateness, and should have a proven or suspected propensity to establish in disturbed areas (Smyth 2000; Polster 2013). Research on native woody vegetation establishment on reclaimed sites has identified candidate sitespecific species that are able to establish and grow on reclamation sites after seeding or planting (O Brien and Straker 2010; Smyth 1995). Research completed at Teck s steel-making coal mines (see Table 78a-1) indicates that inoculating certain plant species with symbionts before planting supports revegetation because certain reclamation materials or nursery growth material lack the required organisms for successful establishment or growth (O Brien and Straker 2010). REVEGETATION: NON-WOODY SPECIES ESTABLISHMENT Studies conducted on non-woody native vegetation establishment (either by direct seeding or planting) indicate that appropriate species selection is critical (Polster 2013; O Brien and Straker 2010; Smyth 1995, 2000). Species should be selected based on available substrate, appropriate ecosystem type and successional appropriateness, and have a proven or suspected propensity to establish in disturbed areas (Smyth 2000; Polster 2013). They must also meet end land use goals. Research on native non-woody vegetation establishment on reclaimed sites (see Table 78a-1) has identified candidate site-specific species that are able to establish and grow on reclamation sites after seeding and planting (O Brien and Straker 2010; Smyth 1995). REVEGETATION: SUMMARY Based on the information summarized above, and in Table 78a-1, Teck has indicated that it is willing to explore various options with regulators and potentially affected Aboriginal communities to improve timing of native plant colonization and diversity. Planting a wider range of species in addition to those outlined in the Guidelines for Reclamation to Forest Vegetation in the Athabasca Oil Sands Region (2nd Edition) (AENV 2010) is a potential option. KNOWLEDGE GAPS AND CHALLENGES To date, reclamation research has focused on the establishment of native species on reclaimed mines sites to meet end land use objectives that include traditional land use. Reclamation efforts at mines in western Canada have focused on identifying and selecting trees, shrubs, forbs and grasses that are locally common and suitable for use at an operational reclamation scale. In areas planted or seeded with native species, the objective is generally to establish vegetation cover that will initiate development of self-sustaining ecosystems that will meet site-specific end land use objectives. Little information was found that focused on identifying native species that would fulfill specific traditional use requirements; however, many native species would also be considered traditional use species. October 2014 ESRD/CEAA Page 369

372 ESRD and CEAA Responses Approvals Frontier Oil Sands Mine Project The following information is required to fill gaps related to establishment of species with traditional use value: Many native plant species have been evaluated for reclamation use at the research or operational level. The relationship of these species to traditional uses is generally not presented and can only be inferred through a review of literature on traditional plant use. Teck expects that, through continued consultation, species of importance to Aboriginal communities will continue to be identified and subsequently incorporated into reclamation planning as feasible. The literature generally indicates that establishment of native vegetation through natural processes is relatively slow (Sharman and Smyth 2002; Bittman 1995; Brinker 1992). The timeframe required to restore native vegetation to a condition approximately equivalent to predevelopment conditions is unknown, especially in climates where coniferous forest are the dominant land cover (Strong 2000). Monitoring is required to establish trends in native plant establishment and ingress and plant community development (i.e., succession) on reclaimed mine sites. Teck has committed to developing a monitoring program to examine reclamation success in conjunction with regulators and potentially affected Aboriginal communities. Several studies indicate that acquiring an adequate supply of seed can be a limiting factor to using native species in reclamation (Macyk 2002; C.E. Jones & Associates 1996). The Oil Sands Vegetation Cooperative (OSVC) is a COSIA collaborative effort to collect and bank seeds from a wide variety of species (currently over 30), many of which would not normally be considered commercially viable but are important for ecological diversity. Currently, the program includes harvesting, extraction, registration and banking of seed at the Alberta Tree Improvement and Seed Centre in Smoky Lake, which provides seed storage in a temperature-stable underground bunker. As a member of COSIA, Teck is funding the OSCV and expects to benefit from the seed bank in the future. For species that cannot be established through seeding, knowledge of greenhouse propagation and transplanting techniques often need to be developed or improved (Baig 1992). Teck has conducted numerous research trials and studies over a 30 year period to identify candidate native species for use in reclamation (Smyth 1995; C.E. Jones & Associates 1996; Keefer and Moody 2009) and to develop propagation techniques (McKenzie and Fitzpatrick 1985). Research into the selection of native species is ongoing. Recently, Keefer and Moody (2009) identified a total of 67 native species with high reclamation potential (some of which were presently used) for Teck s steel-making coal mine operations in southeast British Columbia. A recent partnership between First Nations communities and private industry in northeastern British Columbia resulted in the creation of the Three Sisters Nursery to grow native and culturally important species that are suitable for use on reclaimed sites at the Walter Energy mines (Keefer et. al. 2013). A native species reclamation research trial that includes plants with traditional use values was initiated at Teck s Highland Valley Operations in 2013 (Terraforma Environmental 2013). Further testing of propagation and establishment techniques for potential native plant species that have traditional ESRD/CEAA Page 370 October 2014

373 Frontier Oil Sands Mine Project ESRD and CEAA Responses Approvals use values is required to develop practices that can be used at the operational scale. Teck included results of oil sands specific work in developing the Project s conceptual CC&R plan (Smrecui and Gould 2010). It is anticipated that future research, including research undertaken by COSIA, will inform more detailed reclamation planning. Reclamation on mine sites is most commonly achieved by creating upland ecosystems on mesic to dry sites (with poor to medium nutrient regimes) and locating wetlands along drainage areas of closure landscapes. Although use of wetlands as treatment systems is well established, further research is required to identify opportunities to develop different types of wetlands with a diverse set of functions. Teck has recognized this knowledge gap and has committed to evaluate results and incorporating recommendations into the Project s detailed reclamation planning as appropriate. Further research is also needed that focus on evolving technologies associated with oil sands mining, including reclamation of soft tailings and overall watershed reclamation planning and ecosystem component integration (Cranston and Leskiw 2014). Although gaps in knowledge exist, Teck expects that specific research in these areas, along with ongoing and future regional initiatives and continued consultation with Aboriginal communities, will help to close knowledge gaps, resolve challenges and inform future research. As knowledge is gained and improvements are made to reclamation methods and techniques, Teck has committed to incorporate such findings into more detailed reclamation planning. MCFN has told Teck that it has concerns with the degree and manner with which MCFN s traditional knowledge and Aboriginal perspectives have been considered and incorporated by Teck, particularly in the assessment of impacts to MCFN s rights and culture. This response does not incorporate traditional knowledge. To this end, Teck acknowledges the need for further engagement regarding this SIR and Teck will revisit this SIR and conclusions contained in it once the parties have pursued the collaborative process that Teck and MCFN are working to develop and as additional information is gathered. ACFN has clearly stated that it has concerns with the degree and manner with which ACFN s traditional knowledge and Aboriginal perspectives have been considered and incorporated by Teck, particularly in the assessment of impacts to ACFN s rights and culture. Recognizing that additional work needs to be done, Teck has requested a meeting with ACFN to co-create a process to address outstanding concerns, to revisit certain conclusions made by Teck in the, and to work toward understanding and incorporating ACFN s traditional land use and traditional knowledge into the assessment in a meaningful way Teck will update regulators on a regular basis about the progress of these discussions. Teck will not be filing responses to Round 3 SIRs that pertain to traditional knowledge or the assessment of impacts to ACFN s rights and culture with regulators until the parties have pursued the collaborative process referred to above, or until Teck and ACFN agree otherwise. October 2014 ESRD/CEAA Page 371

374 ESRD and CEAA Responses Approvals Frontier Oil Sands Mine Project Table 78a-1 Location Soil Properties Southwest Alberta Southeast British Columbia Northeast British Columbia Reclamation at Teck Mines Summary Long-term reclamation monitoring studies conducted in southwest Alberta comparing vegetation reestablishment in topsoil versus regolith show that the topsoil at Luscar mine has maintained equivalent soil nutrient levels over more than 20 years (O Brien and Straker 2010), indicating cycling of nutrients and a return to self-sustaining native ecosystems. O Brien and Straker (2010) synthesize studies from the Luscar and Cheviot mines that show plant cover is generally greater on areas treated with topsoil versus regolith (subsoil) for the first 20 years (Walker 2005; Arregoces et al. 2008). Trees and shrubs preferred topsoil, and floristic richness was also greater on areas treated with topsoil. However, after 20 years, higher biomass was produced on regolith compared to topsoil. It is thought that this response was because of legume germination on regolith, and improved soil nutrient content over time (with legumes producing greater biomass). Legumes fix nitrogen in the soil and over time increase nitrogen availability for other plant species. Numerous trials have been conducted to compare vegetation establishment on various materials (i.e., overburden, cover soil, overburden-sand mixes, limestone, coal reject fines) used for capping (or incorporating into) waste rock. Physical and chemical comparisons of overburden (primarily glacial till) and waste rock have shown that waste rock generally has higher organic matter content but lower nutrient levels (particularly phosphorous and potassium). Results generally show that growth of grasses and legumes, as measured by cover and biomass, is similar between the capped sites and waste rock sites. In addition, soil development over 20 years at the Line Creek Mine in the Elk Valley was found to be equivalent to that of surrounding undisturbed reference sites with comparable rock cover component, humus cover and organic layers (Smyth 2002). Soil development prior to mining was classified as Orthic Regosols or Orthic Eutric Regosols, and after 20 years soils were classified as Orthic Regosols (Smyth 2002). Studies at the Sullivan mine in British Columbia indicate that between 30 cm and 60 cm of soil cover (till) on mine wastes aids vegetation establishment (Przeczek and Ryder 2011). Fertilization trials on mine sites have been ongoing since the 1980s and refinement of fertilizer application rates has followed. Polster and Redgate (1982) found that response by vegetation to fertilization was most pronounced in xeric (very dry) sites and that heavy fertilization reduced legume establishment. Fertilization studies at Bullmoose Operating Corporation and the northeast coal block indicate that multiple applications each year are required for vegetation establishment and continued growth on sites comprised on regolith growing material (O Brien and Straker 2010). However, Smyth (1995) found that fertilization using an inorganic granular fertilizer was required once every other year. Annual monitoring of growth medium nutrient levels was used to determine when fertilization applications could be reduced and finally stopped. Other studies in the northeast coal block indicate that native vegetation responds relatively slowly to fertilization; as such, longer timelines for native vegetation establishment might be considered (Sharman and Smyth 2002). Issues with soil ph can also be addressed at the time of planting using dolomite lime (Sharman and Smyth 2002), though this might not be a long-term solution. ESRD/CEAA Page 372 October 2014

375 Frontier Oil Sands Mine Project ESRD and CEAA Responses Approvals Table 78a-1 Reclamation at Teck Mines (cont d) Location Surface Preparation Southwest Alberta Northeast British Columbia Trace Element Uptake Southeast British Columbia Summary Forty years of research at Teck s Cardinal River Operations (including Luscar and Cheviot mines) has shown that revegetation success is greater with rough mounding surface preparation (i.e., uncompacted mounds and woody material) compared to compacted, smoothed soils (Lesko et al. 1975; Knapik et. al. 1995; O Brien and Straker 2010; Strong 1999). Microsites created by mounding increase native plant (tree and shrub) survival by creating sheltered areas, reducing competition, creating barriers to strong winds, and protecting from very low temperatures. Many studies show greater vegetation cover on protected slopes and decreased cover on exposed areas (O Brien and Straker 2010; Paquin and Brinker 2011). Klassen (1975) found that very steep slopes did not germinate well after seeding and generally required seeding for several years for vegetation cover to establish. Surfacing roughing has been shown to reduce erosion on sites, particularly when used with course woody debris, which encourages vegetation establishment (Paquin and Brinker 2011). Site practices such as harrowing, ripping and shaping were developed for each mine (Bullmoose Operating Corporation and Quintette Operating Corporation). Studies found that surface crusting or hardening can reduce seedling establishment and usually occurs if sites are prepared too far in advance of seeding (O Brien and Straker 2010; Smyth 1995 and 1996). Resloping studies show that vegetation cover was greatest on crests of slopes and on level gradients (O Brien and Straker 2010; Smyth 1995 and 1996). Polster (2011) describes abiotic conditions that prevent the vegetative recovery of sites; these include steep slopes, inhospitable texture (either too coarse or too fine) and compaction. Reclamation treatments for these abiotic reclamation constraints include surfacing roughening and regrading steep slopes to a diversity of slope configurations (Polster 2009, 2011). Studies at Elk Valley coal mines show that the uptake of metals and elements in vegetation on reclaimed sites is the same, or marginally different, than levels found in adjacent, undisturbed reference sites for most metals tested (O Brien and Straker 2010; Pryzm Environmental 2007). Reclamation monitoring and research at Elk Valley mines has included foliar nutrient analysis of conifers. Conifer foliage on reclaimed stands commonly show visual symptoms of nutrient deficiencies such as chlorosis. Although analysis of foliar nutrient levels indicates that nutrients, particularly nitrogen, would be classified as deficient by British Columbia standards, the nutrient concentrations are comparable to levels measured in trees from off-site reference stands. The mean foliar nitrogen concentration in conifer foliage from reclaimed coal waste across all monitored sites on Elk Valley mines is greater than in samples from off-site reference stands (Pryzm Environmental 2007). These results, along with measured growth rates, indicate that nutrient levels are sufficient to sustain growth rates typical of off-site forests at similar elevations, and that nutrient cycling is occurring on reclaimed sites. October 2014 ESRD/CEAA Page 373

376 ESRD and CEAA Responses Approvals Frontier Oil Sands Mine Project Table 78a-1 Reclamation at Teck Mines (cont d) Location Trace Element Uptake (cont d) Northeast British Columbia Summary Studies of metal uptake by native vegetation species on disturbed and replanted areas at the northeast coal block show elevated levels of cadmium, chromium, nickel and selenium (O Brien and Straker 2010). The study also showed elevated levels of cadmium and nickel in native woody species which indicates that elevated levels of these trace metals occur in the undisturbed vegetation in the area (O Brien and Straker 2010; Smyth 2002). This research stresses the importance of baseline studies of trace metal and element content in native undisturbed vegetation prior to construction. The research by Smyth (2002) showed a correlation between some native woody species and elevated metal concentrations. This information can be helpful when determining planting prescriptions for sites with the potential for elevated trace metal content. Smyth s (2002) study was conducted using three available growth substrates (waster rock, regolith and topsoil) and found that coarse waste rock appeared to result in elevated metal uptake in foliar samples. A similar study conducted on the Bullmoose mine showed elevated levels of selenium in both reclamation species (herbs and woody species) and in native, undisturbed test plots (O Brien and Straker 2010). Native Plant Species Establishment and Ingress Southwest Alberta Southeast British Columbia Monitoring ( ) within the Coal Valley Mine detected a total of 123 plant taxa on reclaimed land seeded between 1979 and 1994 (Strong 2000). Of this total, 18 were introduced as part of the reclamation program; the remainder were considered to be indigenous species that colonized naturally. Many of these species were also classified as members of local plant communities. Four plant communities were classified on the monitored sites. However, while a relatively large number of species were recorded, the cover of native species as a proportion of the total cover was considered low in three of the four communities when trees were excluded from calculations. Species detected which may have traditional use values (besides conifers) include: low bilberry (Vaccinium caespitosum), prickly rose (Rosa acicularis), wild red raspberry (Rubus idaeus), yarrow (Achillea millefolium), Acorus americanus (sweet flag/ratroot), willows (Salix spp.), trembling aspen (Populus tremuloides), and balsam poplar (Populus balsamifera). Presence of four species associated with very moist to wet sites (e.g., Acorus americanus) could not be attributed to nearby plant communities. No significant associations were detected between the abundance of native species and their distance to undisturbed site or to other parameters. Strong (2000) suggests that a dense tree canopy is required to accelerate the establishment of native species and development of a forest floor understory. Permanent reclamation monitoring plots established on the Line Creek mine site in 1980 have shown that 20 years after planting and monitoring began there was a significant increase in the percent cover of native vegetation in the plots. Native vegetation includes 3 species of rush, 20 grasses, 88 forbs, 2 fern allies, 6 mosses, 1 leafy liverwort and 11 lichens (Smyth and Kovak 2002). Almost all of the species constitute natural ingress from nearby undisturbed areas. Smyth and Kovach (2002) also found that native species ingress appeared to be increasing as agronomic species from historical reclamation projects decreased, or died off. ESRD/CEAA Page 374 October 2014

377 Frontier Oil Sands Mine Project ESRD and CEAA Responses Approvals Table 78a-1 Reclamation at Teck Mines (cont d) Location Native Plant Species Establishment and Ingress (cont d) Northeast British Columbia Yukon Summary Quintette Operating Corporation established native species islands within operationally reclaimed sites between 1992 and 2004 in subalpine and alpine elevations. In 2007, monitoring was completed at 255 of these islands to assess their rate of expansion (if any) and ecological functions. Previous reports and papers (e.g., Bittman 1995; Smyth 1995, 2002) describe species used in establishing these islands and previous monitoring results. A suite of 30 natives species (from a prospective list of 80 candidate species) were identified for use in Quintette reclamation programs (Sharman and Smyth 2002). These included grasses (6), sedges (2), forbs (9), shrubs (12) and trees (5). Results of the 2007 assessment indicated the following: Some of the islands are expanding in size, but most are not. Factors which affect expansion appear to include good initial establishment (e.g., site conditions, survivorship) and recruitment of species with high expansion capacity. Seedlings that survive the initial planting shock appear to persist. Most native plant species established by seeding or planting are persisting. Species that were most successful at expanding their ranges included grass (3) and forbs (5). Signs of nutrient stress do not appear in the natives species present in the islands. Several species, especially those expanding their ranges, at thought to be producing viable seed. Lister (2010) measured recolonization of disturbed sites by native plant species, largely material borrow areas and reclaimed surfaces of closed mines in Yukon. The purpose was to determine factors affecting recolonization and native species most prevalent on disturbances. Soil moisture and ground cover (in the form of grass cover established by seeding) were determined to be the factors most influencing natural recolonization and succession. A thick sward of seeded grasses generally seems to reduce native recolonization. Native plant species most commonly found on the disturbed sites included: trees balsam poplar (Populus balsamifera), trembling aspen (Populus tremuloides) and white spruce (PIcea glauca) shrubs willow (Salix sp.) were the most commonly observed shrubs, followed by kinnikinnick (Arctostaphylos uva-ursi) and soapberry (Shepherdia canadensis) forbs species most often observed included fireweed (Chamerion angustifolium), yarrow (Achillea millefolium), Arctic lupine (Lupinus arcticus) and Drummond s mountain avens (Dryas drummondii) Grasses were not systematically identified. October 2014 ESRD/CEAA Page 375

378 ESRD and CEAA Responses Approvals Frontier Oil Sands Mine Project Table 78a-1 Reclamation at Teck Mines (cont d) Location Establishment of Woody Native Species Southwest Alberta Southeast British Columbia Summary The high elevation of the Luscar mine has made establishment of woody vegetation species challenging (O Brien and Straker 2010). Lesko et al. (1975) began reclamation efforts on the Luscar mine in 1971 and had limited success reestablishing silverberry (Elaeagnus commutata) from seed. The research concluded that direct seeding of woody species was not successful. Brinker (1992) found that tree and shrub success, both planted and natural ingress, was greatest in protected sites and when planted into topsoil. This study also recorded a variety of woody shrubs and deciduous trees on the reclamation site including: blueberry (Vaccinium sp.), willow (Salix sp.), rose (Rosa sp.), Labrador tea (Rhododendron groenlandicum), buffaloberry (Shepherdia canadensis) and aspen (Populus tremuloides). O Brien and Straker (2010) synthesize that lodgepole pine were found to be more sensitive to exposure and grazing than spruce, and that ground cover provides protection to woody species when not comprised by overly competitive species. Macyk (2002) reports that trees and shrubs have been established and thrive in reclaimed areas initially seeded to grasses and legumes on No. 8 mine near Grande Cache, Alberta. The cover provided by the herbaceous ground cover is reported as beneficial for this geographic area since it provides shelter and holds snow during the winter months. Trees and shrubs were planted on reclaimed sites within two to four years of seeding at Coal Valley Mine. Tree densities derived from monitoring indicate reduces stocking rates and open canopy conditions (Strong 2000). Poor survival of planted stock was attributed to poor site conditions and wildlife browsing while poor initial growth was associated with difficult growing conditions (moisture or nutrient deficits or competition with ground cover). However, the monitoring data indicate that tree height of the surviving trees was adequate to meet local reforestation standards. Numerous studies of revegetation using woody native species have focused on the use of conifers. Survival of planted conifers was generally low (e.g., <30%) during early trials and operational reclamation undertaken at southeast coal mines (pre-mid-1980s). Among the primary reasons for low conifer survival rates was competition from agronomic ground cover (Prseczek 2000). During these early years, conifers or shrubs were typically planted into areas were ground cover was previously established or co-established at the time of planting. Ground cover was often established because of concerns with erosion. Subsequent trials indicate that conifer survival was much higher in bare waste rock than waste rock, and survival rates increased when decompaction activities were conducted (Westar 1986). Research trials were conducted to evaluate methods to improve conifer establishment (C.E. Jones & Associates 1996; Teck 1996). Trials indicate that conifer survival could be improved if seeding of ground cover was delayed (two to five years). Various legumes and grasses were tested for the ground cover, but evaluation indicated that legumes were preferred since they provide greater biomass and enhance soils properties (i.e., through nitrogen fixation and addition of organic matter). As a result, an operational prescription was developed where birdsfoot trefoil (Lotus corniculatus) is interseeded two springs after conifer planting with broadcast fertilization (birdsfoot trefoil is much less competitive than other legumes). Long-term conifer survival has increased substantially (>90% on trials). Research indicates that planting of conifers in spring or fall provides best survival. ESRD/CEAA Page 376 October 2014

379 Frontier Oil Sands Mine Project ESRD and CEAA Responses Approvals Table 78a-1 Reclamation at Teck Mines (cont d) Location Establishment of Woody Native Species (cont d) Southeast British Columbia (cont d) Northeast British Columbia Summary Monitoring of conifers indicates that growth is improved on sites where the interseeding of legumes is delayed in addition to significantly increased rates of survival. This growth is demonstrated by increased height of interseeded conifers compared to non-seeded controls. Monitoring, up to 20 years after establishment, has shown that the total height of pine and spruce is significantly greater compared to noninterseeded trees; total height of interseeded conifers after 20 years ranges from about 3.2 to 4.2 m while height of non-interseeded conifers ranges from 2.5 m to 3.2 m. The growth response largely occurs in the early years of establishment (i.e., trees reach breast height sooner at interseeded sites). Monitoring of reclaimed sites planted with conifers, conducted at the five Elk Valley mines during the first two growing seasons and every five years thereafter, shows that most planted sites have stocking (stems/ha) and diversity that should allow development into coniferous or mixedwood forest. Free-to-Grow surveys are conducted on all stands that include a forestry end land use objective. These stands have all been treated using the delayed interseeding approach described above. About 70% of the land area surveyed (120 ha) with the forestry objective has meet the Free-to-Grow requirements for presence of acceptable species, stocking and minimum height. Site indices ranges for pine (Pinus sp.) and spruce (Picea sp.) on reclaimed sites with a forestry objective are similar to ranges for the same species on adjacent post-harvest regeneration (i.e., off-mine) at similar elevations. This indicates close equivalency in growth rates. A study using paired coal waste and forestsoils plots have shown that the coal waste plots meet Free-to-Grow standards and that spruce growth is slightly better or equivalent on coal waste compared to forest soil. It also shows that pine growth is less than that of forest soil. To date, there is no indication of degradation of site indices over time for monitored conifer plantations (i.e., growth is sustained over the long-term) (O Brien and Straker 2010). Research in the Elk Valley mines has evaluated the establishment of various conifers as a component of wildlife habitat (at high elevation). These included hybrid spruce (Picea sp.), lodgepole pine (Pinus contorta), subalpine larch (Larix lyallii), subalpine (Abies lasiocarpa) and Douglas fir (Pseudotsuga menziesii). Results after 10 years indicate that locally propagated and grown, fall-planted spruce seedlings are most successful, followed by lodgepole pine. Research has also demonstrated that conifer survival is enhanced by creating and selecting microsites for planting. Most of the research associated with establishment of non-coniferous woody species has focused on shrubs suitable for wildlife (elk) browse. However, many of these species may also have potential traditional use. The following species have successfully established on Elk Valley mines: aspen (Populus tremuloides), balsam poplar (Populus balsamifera), Saskatoon (Amelanchier alnifolia), red osier dogwood (Cornus stolonifera), willow (Salix sp.), rose (Rosa sp.), chokecherry (Prunus virginiana), kinnikinnick (Arctostaphylos uva-ursi), Douglas maple (Acer glabrum), snowberry (Symphoricarpos albus), wolf-willow (Elaeagnus commutata), buffaloberry (soopolallie) (Shepherdia canadensis) and spirea (Spiraea sp.). Many years of research were conducted at Quintette Operating Corporation to identify native species suitable for reclamation, test site preparation, seeding and planting rates and methods, and fertilizer rates (Smyth 1995). This research helped identify candidate reclamation species and methods of establishment at the operational level. October 2014 ESRD/CEAA Page 377

380 ESRD and CEAA Responses Approvals Frontier Oil Sands Mine Project Table 78a-1 Reclamation at Teck Mines (cont d) Location Establishment of Woody Native Species (cont d) Northeast British Columbia Southern Interior British Columbia Summary Several native woody species trials (Smyth 1995) have been conducted at Bullmoose Operating Corporation and the northeast coal block. Some shrub species, when planted as seedlings, performed well. Examples include: kinnikinnick (Arctostaphylos uva-ursi), scrub birch (Betula nana syn. glandulosa), mountain-avens (Dryas sp.) and arctic willow (Salix arctica). Seedlings should be at least one year old prior to planting and require inoculation during planting. Except for tailings and coarse reject studies, earlier operational conifer establishment at the northeast coal block was poor; at Bullmoose Operating Corporation, conifer establishment was more favourable (O Brien and Straker 2010). Results from later studies at the northeast coal block were somewhat more favourable; in these studies, seed was collected from areas adjacent to the mine site, propagated on site, inoculated and planted with fertilizer packs (Sharman and Smyth 2002). Mean densities (50 to 1,025 stems/hectare) were recorded during post-closure monitoring at these mines. These densities indicate reestablishment of open forest or forest patches that will provide species and structural diversity to reclaimed sites (O Brien and Straker 2010). Research trials and planting of native conifers and shrubs patches as a component of operational reclamation has been undertaken at Teck s Highland Valley Operations since the mid-1980s. Planted areas are monitored at establishment to determine stocking densities by species and assessed two and seven years after planting. Data collected includes species, stems/hectare, condition and height. Conifer stocking density and growth are compared to standards to determine if the areas will meet British Columbia Ministry of Forest minimum stocking standards for establishment of conifer stands in the Kamloops Forest Region (Teck 2013). Results of the monitoring conducted for areas scheduled for assessment in each year are reported in Highland Valley Copper Annual Reports. In 2012, 15 sites were assessed; six sites received first assessments while nine underwent second assessment. All of the first assessment sites met the minimum stocking standards, while five of the nine sites undergoing second assessment met the standard (Teck 2013). Sites not meeting the stocking standard are considered for additional treatment. Results of tree and shrub assessment from recent years include the following: 17 operationally planted areas were surveyed in 2010; 8 of 9 sites met or were above the stocking standards at first assessment, while 3 of 8 sites receiving a second assessment met the standards (Teck 2011) 8 operationally planted areas were surveyed in 2009; 4 of 6 sites met the stocking standard at first assessment, and both sites receiving the second assessment met the standard (Teck 2010) 21 operationally planted sites were surveyed in 2008; 9 of 14 sites met the stocking standard at first assessment, while 6 of 7 sites undergoing a second assessment met the standard (Teck 2009) Competition with ground cover, wildlife browse and moisture deficiencies are cited as causes for reclaimed sites not meeting the stocking standards (Teck 2009, 2013). A comprehensive review of tree and shrub planting monitoring results from the past 20 years on Highland Valley Copper would be required to determine long-term success rates in establishing tree and shrub plantings that meet the mine land use objective. However, monitoring results from recent years indicate that most planted sites are meeting the stocking standard and mine objective for establishing forest patches containing native trees and shrubs. ESRD/CEAA Page 378 October 2014

381 Frontier Oil Sands Mine Project ESRD and CEAA Responses Approvals Table 78a-1 Reclamation at Teck Mines (cont d) Location Establishment of Non-Woody Native Species Southwest Alberta Summary Revegetation studies conducted by Lesko et. al. (1975) at the Luscar mine (CRO) began in 1971 and included seeding waste rock dumps with a variety of grasses including native species such as blue grass (Poa pratensis) and wheat grasses (Agropyron sp.). The study concludes that native species established as readily as agronomic species in the test plots. Horstmann and Bachmann (1975) found that, on the same mine, native grass species establishment was largely restricted to aspects protected from high winds and low temperatures. Baig (1992) studied natural revegetation of 10 coal mine waste spoil areas in the Rocky Mountains to evaluate potential of native species for reclamation. Coal spoil characteristics and potential relationships to plant establishment were examined. The number of species present in an area was found to be related to spoil age, mine area, and moisture and nutrient conditions of the spoil. Fifty-nine frequently occurring native species were found to occur frequently on the sites and these were identified as having potential for reclamation. Smyth (1995) synthesized research programs specific to reclamation of native species in the northeast coal block. These include: seed collection programs from 1987 to 1994 nursery production of native species seed mix trials, seeding rates application methods fertilization application The studies found that a large number of native vegetation species, including yarrow (Achillea millefolium), southern milk-vetch (Astragalus aboriginum), Alaska wildrye (Elymus alaskanus subsp. latiglumis syn. Agropyron caninum), Alpine fescue (Festuca brachyphylla), arctic poppy (Papaver radicatum syn. kluanensis), northern bluegrass (Poa abreviatta syn. Pattersonii) and others have demonstrated the ability to establish and persist (Smyth 1995). The studies refined seeding rates to 75 kg/ha to allow erosion control as well as biological space for natural ingression of vegetation. Through annual monitoring of the northeast coal block reclamation sites, Bittman (1995) conducted a seed dissemination study that resulted in transplanted seedlings setting viable seed and new plants establishing up to 15 m away (p. 32). Colonizers most successful in this trial included: northern fairy-candelabra (Androsace septentrionalis) hair bent grass (Agrostis scabra), dwarf alpine hawksbeard (Crepis nana), boreal sandwort (Minuartia rubella), alpine bluegrass (Poa alpina), arctic bluegrass (Poa arctica), northern bluegrass (Poa abreviatta) and spike trisetum (Trisetum spicatum). Reclamation of native non-woody species in the northeast coal block show benefits to growth and establishment using grass-legume mixes with increased overall rates of germination using intermixed seeding prescriptions (Smyth 1995). Overall, the successful establishment of native non-woody vegetation on reclaimed sites appears to be site specific and depends on species selection. Early succession and disturbance-loving species are good candidates based on several studies in northeastern British Columbia (Polster 2013; Smyth 1995). October 2014 ESRD/CEAA Page 379

382 ESRD and CEAA Responses Approvals Frontier Oil Sands Mine Project Table 78a-1 Reclamation at Teck Mines (cont d) Location Establishment of Non-Woody Native Species (cont d) Southeast British Columbia Summary Much less research has focused on the use of non-woody native species in revegetation on Elk Valley mines (compared to woody species). O Brien and Straker (2010) indicate a low success rate using non-woody native species in trials conducted to date. These trials have focused on the use of native grasses, legumes and sedges. Notable success include: the use of sedges, including beaked sedge (Carex utriculata), in reclamation of seasonally flooded riparian areas associated with Henreta Creek at Fording River Operations a trial to evaluate the establishment of nitrogen-fixing species on waste rock; this trial included some native species that survived for two growing seasons. The study concluded that more efficient seed collection and propagation programs are required to make revegetation using native species feasible on an operational scale. the use of five native grass species and subspecies (developed to commercial availability by the Alberta Research Council)for reclamation of high-elevation ungulate habitat. Four of the five species demonstrated successful establishment and persistence. Established species had biomass production in a range comparable to grass biomass in native reference site grasslands. Further work is being conducted to identify native species that will be commercially available and to identify candidate species for propagation and trials. Some research has also been conducted into the use of non-woody native species at higher elevations on Elk Valley mines. Several native grass species (slender wheatgrass (Elymus trachycaulus), sheep fescue (Festuca ovina), spike trisetum (Trisetum spicatum), bluebunch wheatgrass (Pseudoroegneria spicata), hairy wildrye (Elymus innovatus), alpine bluegrass (Poa alpina), northern awnless brome (Bromus pumpellianus), fowl bluegrass (Poa palustris) and blue wildrye (Elymus glaucus) along with the herbs fireweed (Chamerion angustifolium) and yarrow (Achillea millefolium) have been found to have potential for reclamation use. ESRD/CEAA Page 380 October 2014

383 Frontier Oil Sands Mine Project ESRD and CEAA Responses Approvals b. As indicated in the response to ESRD/CEAA Round 2 SIR 141c, general concerns have been expressed about the reclaimed landscape, the incorporation of traditional knowledge and use, and the ability to pass on traditional knowledge to future generations. These concerns were communicated by potentially affected Aboriginal communities directly to Teck as well as to terrestrial discipline experts that attended Frontier Project open houses and workshops. Teck considered concerns about the reclamation landscape as part of the. As well, Aboriginal community concerns specific to each key issue were considered as part of the assessment. Sections titled Responses to Aboriginal Community Concerns were included for each key issue and describe how Teck has considered, or plans to address, these concerns following a western science approach. Since filing the, and responding to Round 1 and 2 SIRs and statements of concern (SOCs) related to the, Teck has received additional reports and correspondence from potentially affected Aboriginal communities that express concerns about the Project, including reclamation. Teck s response to these concerns is summarized below. FORT MCKAY (FIRST NATION AND MÉTIS LOCAL 63) Since filing the and responding to Round 1 and 2 SIRs and SOCs, Teck and Fort McKay have agreed to work together outside of the regulatory process to resolve outstanding concerns including reclamation. MIKISEW CREE FIRST NATION Teck received a copy of the Mikisew Cree First Nation Indigenous Knowledge and Use Report and Assessment for Teck Resources Limited s Proposed Frontier Oil Sands Mine Project (Candler et al. 2013a) in November The March 27, 2014 letter that MCFN (and ACFN) sent to the Canadian Environmental Assessment Agency, the Government of Alberta and Teck identified several questions and concerns relating to reclamation. These included: that Teck provide evidence that marshes and swamps will initiate peat accumulation, and salinity will decrease over time, allowing peatlands to develop in the reclaimed landscape in the long term that Teck demonstrate how MCFN recommendations will be incorporated in detailed revegetation planning concerns about the use of equivalent capability for forestry instead of metrics such as value, amount and function the need to define reclamation targets based on species composition, diversity and plant cover to determine success following a reference approach for monitoring October 2014 ESRD/CEAA Page 381

384 ESRD and CEAA Responses Approvals Frontier Oil Sands Mine Project Recognizing that additional work needs to be done, Teck and MCFN have agreed to work together to co-create a process to address outstanding interests and concerns and revisit certain conclusions made in the EIA. MCFN has agreed to work with Teck to understand and incorporate their Aboriginal perspectives, including traditional knowledge and values, into the assessment in a meaningful way, including reclamation planning. To this end, Teck acknowledges the need for further engagement regarding this SIR. Teck will revisit this SIR and conclusions contained in it once the parties have pursued the collaborative process that Teck and MCFN are working to develop and as additional information is gathered. ATHABASCA CHIPEWYAN FIRST NATION Teck received a copy of the Athabasca Chipewyan First Nation Knowledge and Use Report and Assessment for Teck Resources Limited s Proposed Frontier Oil Sands Mine Project (Candler et al. 2013b) in February The March 27, 2014 letter that ACFN (and MCFN) sent to the Canadian Environmental Assessment Agency, the Government of Alberta and Teck identified several questions and concerns relating to reclamation (as above). ACFN has clearly stated that it has concerns with the degree and manner with which ACFN s traditional knowledge and Aboriginal perspectives have been considered and incorporated by Teck, particularly in the assessment of impacts to ACFN s rights and culture. Recognizing that additional work needs to be done, Teck has requested to meet with ACFN to co-create a process to address outstanding concerns, to revisit certain conclusions made by Teck in the, and to work toward understanding and incorporating ACFN s traditional land use and traditional knowledge into the assessment in a meaningful way. FORT CHIPEWYAN MÉTIS (MÉTIS LOCAL 125) Teck has not received new traditional land use information from Métis Local 125 (FCM); however, Teck has committed to funding a Project-specific TLU study with the community. FCM has raised several concerns with respect to reclamation, including: consideration of Métis in the CC&R planning consideration of traditional land use as well as traditional environmental knowledge assurance that disturbed lands be reclaimed to a state where Métis valued resources and species are re-established so that FCM cultural and livelihood practices can be resumed Teck will continue to consult with FCM, seeking to collaboratively develop a process with FCM to integrate its Project-specific TLU study, along with other documents relevant to FCM, into more detailed Project planning, including reclamation planning. ESRD/CEAA Page 382 October 2014

385 Frontier Oil Sands Mine Project ESRD and CEAA Responses Approvals FORT MCMURRAY MÉTIS (MÉTIS LOCAL 1935) Teck has not received any new traditional land use information from (Métis Local 1935). Teck has committed to funding a Project-specific TLU study with the community and contributing to Métis Local 1935 s Mark of the Métis study. Métis Local 1935 has raised specific concerns about how Teck plans to work with the community to establish criteria to determine reclamation success. Teck will continue to consult with the Métis Local 1935, seeking to collaboratively develop a process to integrate its Project-specific TUS, along with other documents relevant to Métis Local 1935, into more detailed Project planning, including reclamation planning. OTHER ABORIGINAL COMMUNITIES Teck has also responded to concerns raised by other potentially affected Aboriginal communities, including the Métis Local 1909 and MNA R1. To date, no specific concerns relating to reclamation have been formally identified by these communities. REFERENCES AENV (Alberta Environment) Guidelines for Reclamation to Forest Vegetation in the Athabasca Oil Sands Region, 2nd Edition. Prepared by the Terrestrial Subgroup of the Reclamation Working Group of the Cumulative Environmental Management Association, Fort McMurray, Alberta. Arregoces, C., N. Craig and L. Leskiw Long-Term Soil and Vegetation Monitoring Plots Program at Cardinal River Operations. First Year (2007) Results. Prepared by Paragon Soil and Environmental Consulting Inc. Edmonton, Alberta. Baig, M.N Natural revegetation of coal mine spoils in the Rocky Mountains of Alberta and its significance for species selection in land restoration. Mountain Research and Development 12(3): Bittman, K Innovative Reclamation at Quintette: High Elevation/High Latitude Challenges. Quintette Operating Corporation. Tumbler Ridge. British Columbia. Brinker, C An Assessment of Woody Species Plant Establishment and Growth at the Cardinal River Mine. C.E. Jones and Associates Ltd Field Inspection of Conifer Nutrient Status at Fording River Operations. November Candler, C., R. Olson and the Firelight Group. 2013a. Mikisew Cree First Nation Indigenous Knowledge and Use Report and Assessment for Teck Resources Limited s Proposed Frontier Oil Sands Mine Project. Submitted to Mikisew Cree First Nation (MCFN) Government of Industry Relations (GIR). November 15, October 2014 ESRD/CEAA Page 383

386 ESRD and CEAA Responses Approvals Frontier Oil Sands Mine Project Candler, C. and the Firelight Group. 2013b. Athabasca Chipewyan First Nation Knowledge and Use Report and Assessment for Teck Resources Limited s Proposed Frontier Oil Sands Mine Project. Submitted to Athabasca Chipewyan First Nation Industry Relations Corporation. November 20, Cardinal, R Affidavit #1 of Raymond Cardinal. In the Court of Queen s Bench of Alberta Judicial District of Edmonton Between Athabasca Chipewyan First Nation (Applicant) and Minister of Energy, Canadian Coastal Resources Ltd., Standard Land Company Inc., and Shell Canada Ltd. (Respondents). Action No Edmonton Registry. Sworn January 30, Cranston, B. and L. Leskiw Summary and Evaluation of Existing Work and Future Reclamation Research Priorities. Canadian Land Reclamation Association Annual Meeting. Red Deer, Alberta. Fort McKay (Fort McKay Environment Services Ltd.) The Community of Fort McKay Traditional Uses of Renewable Resources on the Proposed Suncor Steepbank Mine Site. Report for Suncor Inc., Oil Sands Group. Fort McKay IRC (Fort McKay Industry Relations Corporation) Fort McKay Specific Assessment: Vegetation. Fort McKay Industry Relations Corporation. November Fort McKay Sustainability Department Traditional Land Use Study for the Teck and SilverBirch Frontier Project. Submitted to Teck and SilverBirch. August 9, Horstmann, K. and P. Bachmann Principles of Surface Coal Mine Reclamation: A Study of Initial Activities at Luscar, Alberta. Keefer, M.E., R. Moody and P. Gibeau Comparative Inventory of Vegetation and Soils Surrounding Teck Coal Ltd. s Coal Mountain Operations. Keefer, M.E., N. Owens, C. Marshall and C.R. Mellott Twin Sisters Native Plant Nursery: Integrating research, training, and outreach for the propagation of native and culturally significant plant species in northeastern British Columbia. Overcoming Northern Challenges. Proceedings of the 2013 Northern Latitudes Mining Reclamation Workshop and 38 th Annual Meeting of the Canadian Land Reclamation Association. Whitehorse, Yukon. Klassen, W Surface Reclamation Procedures Employed by Cardinal River Coals Ltd. at Luscar, Alberta, Canada. Knapik, L.J., A.M. Hammermeister and D.G. Walker Characteristics and Quality of Minesoil Landscapes and Minesoil Profiles at the Luscar Mine. Prepared for Cardinal River Coals. File Ref Lesko, G.L., H.M. Etter and T.M. Dillion Species Selection, Seedling Establishment and Early Growth on Coal Mine Spoils at Luscar, Alberta. Information Report NOR -X Northern Forest Research Center Canadian Forestry Service, Environment Canada. Edmonton, Alberta. ESRD/CEAA Page 384 October 2014

387 Frontier Oil Sands Mine Project ESRD and CEAA Responses Approvals Lister, D An Evaluation of Factors Influencing Spontaneous Vegetation Succession in Northern Latitude Disturbances: Assessment of Natural Recolonization of Disturbances in Yukon. Altura Environmental Consulting. Marsh Lake, Yukon. Longman, P Vegetation Development and Native Species Establishment in Reclaimed Coal Mine Lands in Alberta: Directions for Reclamation Planning. Macyk, T.M Thirty Years of Reclamation Research in the Alpine and Subalpine Regions near Grande Cache, AB. Alberta Research Council. Edmonton, Alberta. Marles, R.J., C. Clavelle, L. Monteleone, N. Tays and D. Burns Aboriginal Plant Use in Canada s Boreal Forest. Natural Resource Canada, Canadian Forest Survey. UBC Press, Vancouver, British Columbia. McKenzie, E. and J. Fitzpatrick A Guide to Propagating Some Native Plants Species Suitable for Reclamation at the Line Creek Mine. Environmental Department. Crows Nest Resources Ltd. Moerman, D.E Native Island Assessment. For Quintette Operations. O Brien, B and J. Straker Teck Coal Limited Reclamation Research Summary What We Have Learned What We Need to Know Calgary, Alberta. Paquin, L.D. and C. Brinker Soil Salvage and Placement: Breaking New Ground at Teck s Cheviot Open Pit Coal Mine. Polster, D.F Natural processes: The application of natural systems for the reclamation of drastically disturbed sites. Paper presented at the British Columbia Technical and Research Committee on Reclamation, British Columbia Mine Reclamation Symposium. Cranbrook, British Columbia. September 14 17, Polster, D Understanding the Ecology of Recovery. Polster Environmental, Duncan, British Columbia. Polster, D Processes and Functions: A New Approach for Mine Reclamation. Polster Environmental, Duncan, British Columbia. Polster, D. and R.M. Redgate Revegetation trials at Sukunka Coal Mine. Proceedings for the 6 th Annual British Columbia Mine Reclamation Symposium, Vernon, British Columbia. Pryzm Environmental Trace Elements in Vegetation and Soils: Elk Valley Coal Corp., Coal Mountain Operations. Przeczek, J.E Vegetation Monitoring Report. Fording Coal Ltd. Coal Mountain Operations. Przeczek, J.E. and D. Ryder Revegetation at the Sullivan Mine research to closure a case study. In Fourie, A., M. Tibbett and A. Beersing [eds.]. Proceedings of the Sixth International Conference on Mine Closure. September 18 21, 2011, Lake Louise, Alberta, Canada. Published by Australian Centre for Geomechanics. October 2014 ESRD/CEAA Page 385

388 ESRD and CEAA Responses Approvals Frontier Oil Sands Mine Project Ritch-Krc, E.M A Selection of Traditional Medicinal Remedies Important to Contemporary Carrier People in their Treatment of Disease. University of British Columbia, Vancouver, British Columbia. Sharman, K. and C. Smyth The Progression of Native Species Island Establishment and Monitoring Practices on High-Elevation Waste Rock Dumps at Quintette Operating Corporation. Smreciu, A. and K. Gould Priority Shrub Species: Propagation and Establishment Final Report Prepared for Cumulative Environmental Management Association, Fort McMurray, Alberta. Smyth, C Reclamation Research at Quintette Operating Corporation. Quintette Operating Corporation, Tumbler Ridge, British Columbia. Smyth, C.R and Quintette Operating Corporation ( ) and Shikano Agronomic Species Fertilizer Mix Trial (QCL-RP ). Smyth, C.R Assessment of the Native Species List at Quintette Operating Corporation. Quintette Operating Corporation. Tumbler Ridge, British Columbia. Smyth, C.R Vegetation Metals Uptake Assessment. Quintette Operating Corporation. Tumbler Ridge, British Columbia. Smyth, C.R. and W. Kovach Long-Term Monitoring of Permanent Reclamation Plots on High- Elevation Disturbances at the Line Creek Mine. Sparwood, British Columbia. Stantec (Stantec Consulting Ltd.) Joint Application for Authorizations under the Mines Act, Environmental Management Act, Water Act, Forest Act, Coal Act and Land Act. Volume 2: Mines Act Application. Prepared for Teck Coal Limited by Stantec Consulting Ltd., Teck Resources Ltd., Quintette Coal Operation, Lions Gate Consulting Inc., Klohn Crippen Berger Ltd., Clearwater Consultants Ltd., Lorax Environmental Services Ltd., SRK Consulting and Golder Associates. Victoria, British Columbia. Straker, J., B. O'Brien and R. Jones Teck Coal s Reclamation Research Program A Synthesis of 40 Years of Experience in Mountain Mine Reclamation. Teck Coal Ltd. Calgary, Alberta. Strong, W.L Review of Vegetation on Reclaimed Rock Dumps at Luscar, Alberta. Prepared for Cardinal River Coals Ltd. January Strong, W.L Vegetation Analysis of Recently Reclaimed Sites on the Luscar Mine. Prepared for Cardinal River Coals Ltd. April Strong, W.L Micro-Hummocky Topography as a Reclamation Technique for Enhancing Botanical Diversity in Forested Landscapes. Calgary, Alberta. Swaine, D Why trace elements are important. Fuel Processing Technology 65-66: Sydney, NSW, Australia. ESRD/CEAA Page 386 October 2014

389 Frontier Oil Sands Mine Project ESRD and CEAA Responses Approvals Teck (Teck Resources Limited) Reclamation research on the West Line Creek Dump: Biomass, cover, and species diversity. Environmental Insight, March 1996 Teck Annual Reclamation Report. Volume I. Reclamation Permit Number M-11. Teck Highland Valley Copper. March Teck Annual Reclamation Report. Volume I. Teck Highland Valley Partnership. March Teck Annual Reclamation Report. Volume I. Teck Highland Valley Partnership. March Teck Annual Reclamation Report Volume II Report 2, Highland Valley Copper Tree Planting and Assessment Report. Teck Highland Valley Partnership. March Terraforma Environmental Ltd Native Species Reclamation Research Trial Proposal Outline. Highland Valley Copper (unpublished). Turner, N.J Food Plants of Interior First Peoples. Royal BC Museum Handbook. Royal BC Museum, Victoria, British Columbia. Turner, N.J Plant Technology of First Peoples in British Columbia. Royal BC Museum Handbook. Royal BC Museum, Victoria, British Columbia. Walker, D Project Summary Soil Reconstruction & Revegetation Demonstration Trials: Cheviot Mine Project. Westar Mining Ltd Annual Report and Proposed Program for 1986 and High Elevation Tree and Shrub Outplanting. Question 79 Volume 1, ESRD/CEAA SIR 152 Page 448 The Jackpine Mine Expansion Project Joint Review Panel recognized in their report that not all participants in that environmental assessment agreed on the appropriate methodology for assessing impacts to potential or established Aboriginal or Treaty rights. Notwithstanding this lack of consensus, that Panel assessed and reached conclusions regarding impacts to these rights. a. Describe the methods used by Teck to assess potential impacts of the proposed Project to potential or established Aboriginal or treaty rights. Response 79 a. Assessing potential adverse impacts of the Project to potential or established Aboriginal or treaty rights requires reliable and current information about: the Aboriginal communities traditional use of the Project area whether the Aboriginal communities have expressed interest or concerns about the Project to regulators (provincial or federal) or the proponent October 2014 ESRD/CEAA Page 387

390 ESRD and CEAA Responses Approvals Frontier Oil Sands Mine Project In the and subsequent SIR responses, Teck used existing, publically available traditional land use information, records of past regulatory proceedings, and information gathered through consultation activities and open houses to assess potential effects of the Project on potentially affected Aboriginal communities. This assessment was based on methodology that considered potential impacts of the Project on traditional uses and rights, including the: duration, frequency and timing of potential impacts to Aboriginal or treaty rights severity, nature and risk of exposure of potential Project impacts to Aboriginal or treaty rights geographic extent of Project impacts Since filing the in November 2011, Teck has funded traditional use studies for Aboriginal communities that are potentially affected by the Frontier Project. In response to AER Round 3 SIR 2, Teck describes consultation activities undertaken since filing the Round 2 SIR responses, including issues identified, issues resolved and how Teck plans to resolve outstanding issues, including impacts on Aboriginal rights and culture and meaningful inclusion of TUS into Project assessment and planning. See Teck s response to AER Round 3 SIR 2 for a discussion of plans to assess potential impacts to potential or established Aboriginal or treaty rights. To this end, Teck acknowledges the need for further engagement regarding this SIR. Teck will revisit this SIR and conclusions contained in it once Teck and MCFN have pursued the collaborative process both parties are working to develop and as additional information is gathered. ACFN has clearly stated that it has concerns with the degree and manner with which ACFN s traditional knowledge and Aboriginal perspectives have been considered and incorporated by Teck, particularly in the assessment of impacts to ACFN s rights and culture. Recognizing that additional work needs to be done, Teck has requested to meet with ACFN to co-create a process to address outstanding concerns, to revisit certain conclusions made by Teck in the, and to work toward understanding and incorporating ACFN s traditional land use and traditional knowledge into the assessment in a meaningful way. Question 80 Volume 1, ESRD/CEAA SIR 153 Page 448 ESRD/CEAA SIR 153 specifically requested that Teck provide new information in addition to what was provided in the application. Teck s response merely refers to the original application. a. Provide additional information that clearly describes and explains the methodology used to consider traditional knowledge in all aspects of the environmental assessment. ESRD/CEAA Page 388 October 2014

391 Frontier Oil Sands Mine Project ESRD and CEAA Responses Approvals Response 80 a. MCFN has told Teck that it has concerns with the degree and manner with which MCFN s traditional knowledge and Aboriginal perspectives have been considered and incorporated by Teck, particularly in assessing impacts to MCFN s rights and culture. This response does not incorporate traditional knowledge. To this end, Teck acknowledges the need for further engagement regarding this SIR. Teck will revisit this SIR and conclusions contained in it once the parties have pursued the collaborative process that Teck and MCFN are working to develop and as additional information is gathered. ACFN has clearly stated that it has concerns with the degree and manner with which ACFN s traditional knowledge and Aboriginal perspectives have been considered and incorporated by Teck, particularly in the assessment of impacts to ACFN s rights and culture. Recognizing that additional work needs to be done, Teck has requested to meet with ACFN to co-create a process to address outstanding concerns, to revisit certain conclusions made by Teck in the, and to work toward understanding and incorporating ACFN s traditional land use and traditional knowledge into the assessment in a meaningful way. Teck will update regulators on a regular basis about the progress of these discussions. Teck will not be filing responses to SIRs that pertain to traditional knowledge or the assessment of impacts to ACFN s rights and culture with regulators until the parties have pursued the collaborative process referred to above, or until Teck and ACFN agree otherwise. Question 81 Volume 1, ESRD/CEAA SIR 188 Page In order to understand the effects of the Project on Aboriginal people under section 5(1)(c) of CEAA 2012, information is required regarding the resources identified by Aboriginal groups as key for their current use of lands and resources for traditional purposes, including the Ronald Lake bison herd. a. Provide a full assessment of the impacts of the Project on the traditional use of Bison by Aboriginal people. This assessment should include not only the effects of the Frontier Project but also the cumulative effects of past, existing and foreseeable future activities and Projects, including Teck s exploration activities in the vicinity of the proposed Frontier Project. Given that Teck already has a large amount of information on bison available in the form of traditional knowledge, including information available from the Alberta Energy Regulator hearing on their winter drilling program, it is expected that this traditional knowledge regarding bison will be thoroughly reported in the response. Traditional knowledge should be fully incorporated in the assessment. October 2014 ESRD/CEAA Page 389

392 ESRD and CEAA Responses Approvals Frontier Oil Sands Mine Project b. Discuss whether Teck has considered creating a working group with potentially affected Aboriginal groups, including Métis, to ensure that current aboriginal concerns, knowledge and views regarding the Ronald Lake wood bison herd are adequately incorporated into the response. c. Provide a record of engagement. d. Since the RSA for bison represents the area where there is a potential for cumulative effects, assess the effects on TLU, especially harvesting of bison, north of the current TLU-RSA. In SIR response #188a, Teck states that There might be a change in the location of the herd; however, the population is not expected to be threatened as a result of direct effects (i.e., loss of habitat in the Project assessment area [PAA]). e. Clarify what Teck means by threatened and elaborate on whether Teck expects the Ronald Lake bison population to decrease in size or remain the same during Project construction and operations. Although Teck predicts that habitat loss in the PAA will not threaten the Ronald Lake wood bison herd, at full Project built-out (prior to reclamation) approximately 26.7% of high quality habitat in the entire herd s known range will be removed by the Project relative to baseline conditions. This loss is considered a high magnitude effect, which has a high environmental consequence (prior to reclamation). However, Teck indicates these effects will have a moderate environmental consequence on the herd (pg. 531). f. Provide an explanation of this conclusion given the extent of habitat loss for the herd. In SIR responses #188a and #196a, Teck outlines predicted changes to the Ronald Lake herd population. However, in SIR response #196b, Teck states that it is beyond the scope of the to determine changes in actual population levels and corresponding potential effects on ecosystem processes. g. Explain how Teck was able to predict changes to the Ronald Lake herd population and h. Provide evidence to support these predictions. In SIR responses #188a and #196a, Teck indicates that the results of research and monitoring will inform mitigation to reduce Project effects on the Ronald Lake bison herd. It is not clear what type of mitigation Teck would use to mitigate Project effects on bison. Project effects will include longterm habitat loss for bison, displacement and disturbance of individuals, loss of hunting opportunities for Aboriginal peoples and communities, potential increased disturbance and mortality of bison by non-aboriginal hunters north of the PAA, and potential movement of bison further into Wood Buffalo National Park and subsequent contact with diseased bison. i. Identify specific mitigation measures Teck will use to avoid, lessen, or otherwise mitigate each of these likely or potential Project effects during Project construction and operations (i.e., prior to reclamation). ESRD/CEAA Page 390 October 2014

393 Frontier Oil Sands Mine Project ESRD and CEAA Responses Approvals j. Identify, specifically, how Teck will address impacts to critical habitat for wood bison if it is identified in the Project development area. In SIR response 188a, Teck indicates that, when use of the Ronald Lake bison herd by potentially affected Aboriginal communities is considered, the environmental consequence for Aboriginal peoples who prefer to hunt wood bison north of the revised PAA is considered moderate. Teck does not explain how it came to this conclusion. k. Justify this prediction, including scientific rationale and traditional knowledge. l. In addition, in order to understand the ecological context in which the Project is being developed (as per CEAA guidelines) and existing effects on Aboriginal traditional use of bison, provide a discussion on the impact of current and proposed exploration activities on Aboriginal use of the herd, the potential for increased non-aboriginal harvest resulting from increased access opportunities within the PAA, and potential effects of exploration activities on the distribution, abundance and movement of the herd. Response 81 a. Two Project-specific traditional land use reports have been prepared for the Frontier Project and submitted to Teck on behalf of ACFN (Candler et al. 2013a) and MCFN (Candler et al. 2013b). Both reports contain traditional knowledge and traditional land use information pertaining to bison and bison harvesting. Traditional knowledge and TLU information pertaining to Aboriginal harvesting of bison has been compiled from the ACFN and MCFN Project-specific studies (Candler et al. 2013a; 2013b). Information relating to MCFN and ACFN bison harvesting has also been compiled from publicly available sources. MCFN has told Teck that it has concerns with the degree and manner with which MCFN s traditional knowledge and Aboriginal perspectives have been considered and incorporated by Teck, particularly in assessing impacts to MCFN s rights and culture. This response does not incorporate traditional knowledge. To this end, Teck acknowledges the need for further engagement regarding this SIR. Teck will revisit this SIR and conclusions contained in it once the parties have pursued the collaborative process that Teck and MCFN are working to develop and as additional information is gathered. As a result, at this time, Teck is not providing an assessment of impacts to MCFN as requested in this SIR; however, Teck will do so once Teck and MCFN have pursued the collaborative process referred to above. ACFN has clearly stated that it has concerns with the degree and manner with which ACFN s traditional knowledge and Aboriginal perspectives have been considered and incorporated by Teck, particularly in the assessment of impacts to ACFN s rights and culture. Recognizing that additional work needs to be done, Teck has requested to meet with ACFN to co-create a process to address outstanding concerns, to revisit certain conclusions made by Teck in the and to October 2014 ESRD/CEAA Page 391

394 ESRD and CEAA Responses Approvals Frontier Oil Sands Mine Project work toward understanding and incorporating ACFN s traditional land use and traditional knowledge into the assessment in a meaningful way. Teck will update regulators on a regular basis about the progress of these discussions. Teck will not be filing responses to Round 3 SIRs that pertain to traditional knowledge or the assessment of impacts to ACFN s rights and culture with regulators until the parties have pursued the collaborative process referred to above, or until Teck and ACFN agree otherwise. b. Teck is participating and contributing funding to an ESRD-led Technical Working Group on the Ronald Lake bison herd. The team currently comprises: provincial and federal government (ESRD, Parks Canada, Environment Canada) potentially affected Aboriginal communities (Fort McKay Métis Local 1935, Métis Local 125, ACFN, MCFN) industry representatives (Shell, SilverWillow and Teck) The Technical Working Group will guide the analysis of ESRD-collected data and will plan further studies to better understand the herd. Teck is hopeful that the Technical Working Group will become the primary vehicle for ensuring that Aboriginal concerns and traditional knowledge are fully integrated into future planning for the Ronald Lake bison herd. MCFN has told Teck and ESRD that it has a number of concerns about this technical team and asked Teck to present these concerns in this response. MCFN concerns include: exclusion from designing and carrying out these studies the role of indigenous knowledge in the work of the technical team a lack of transparency with the team other concerns relating to the draft terms of reference Teck understands that the draft terms of reference do not incorporate assessment of impacts to MCFN s rights. MCFN has also raised concerns about Alberta s unwillingness to provide bison data to MCFN. In addition to the ESRD-led work, Teck is funding an MCFN-led documentary that captures a traditional bison hunt and a species-specific MCFN indigenous knowledge and use report on bison for the Frontier Project. MCFN and Teck expect the outcomes of the documentary and report to inform discussion between MCFN, Teck and regulators regarding bison. The bison documentary and study are expected to be completed in However, at the time of drafting this response, neither the documentary nor the indigenous knowledge report were available to inform Teck s response to Round 3 SIRs. MCFN has told Teck that it has concerns with the degree and manner with which MCFN s traditional knowledge and Aboriginal perspectives have been considered and incorporated by Teck, particularly in assessing impacts to MCFN s rights and culture. This response does not incorporate traditional knowledge. To this end, Teck acknowledges the need for further engagement regarding this SIR. Teck will revisit this SIR and conclusions contained in it ESRD/CEAA Page 392 October 2014

395 Frontier Oil Sands Mine Project ESRD and CEAA Responses Approvals once the parties have pursued the collaborative process that Teck and MCFN are working to develop and as additional information is gathered. MCFN and Teck have jointly identified gaps in available information about the Ronald Lake bison herd and areas where Teck might need to reassess certain conclusions regarding potential effects on the Ronald Lake bison herd. These conclusions will be revisited as part of the Project Update following further engagement with MCFN. c. Minutes taken during the February 2014 meeting of the ESRD Technical Working Group are provided in Appendix 81c.1. Minutes from the June 2014 meeting were not final at the time this response was drafted. An additional record of engagement includes a letter that MCFN wrote to Teck on May 2, 2014 raising concerns with Teck s proposal to create a bison forum (see Appendix 81c.2). d. See the response to part a. With respect to this SIR and Teck s responses to the remaining subquestions (i.e., parts e to l), MCFN and ACFN have expressed concerns about the degree and manner with which their traditional knowledge and Aboriginal perspectives have been considered and incorporated by Teck, particularly in the assessment of impacts to Aboriginal rights and culture. To this end, Teck acknowledges the need for further engagement with MCFN and ACFN regarding bison, potential effects of the Project on bison, and development of the mitigation and monitoring plan for the Ronald Lake bison herd. Teck will revisit conclusions made in response to this SIR once the parties have pursued the collaborative processes that Teck, MCFN and ACFN are working to develop and as additional information is gathered. In the interim, Teck has provided current information that is based on western science and is relevant to each of the bison issues discussed in the response to this SIR. Teck expects that this information will be reviewed in more detail with potentially affected Aboriginal communities and that additional information provided by Aboriginal communities will be integrated into the bison-specific mitigation and monitoring plan that will be developed for the Project. e. For the purposes of the assessment, based on the habitat availability results from ESRD/CEAA Round 1 SIR 219 and ESRD/CEAA Round 2 SIR 136, Teck assumed that the remainder of the Ronald Lake bison herd range and surrounding habitat would be sufficient to maintain the current number of individuals in the herd. Therefore, it was assumed that there would be enough habitat inside the herd s range and in the surrounding area to provide suitable habitat to maintain the current population during the life of the mine. Therefore, the Project is assumed to not threaten the viability of the herd. This was supported by Shell (2014) which provided the following empirical evidence on the existence of spare habitat for bison that supports their ability to relocate. At the outset, Shell notes that wood bison in general are a thoroughly-studied and well understood species across its range in northern Canada.... They are a resilient species that are capable of thriving in a wide range of ecosystems and climatic regimes (Gates et al. 2010). Historically, they were found across northern Alberta, an area considered by the National Wood October 2014 ESRD/CEAA Page 393

396 ESRD and CEAA Responses Approvals Frontier Oil Sands Mine Project Bison Recovery Team to be some of the highest quality habitat for the subspecies in its range (Gates et al. 2001). Much of that habitat remains unoccupied. Their resiliency is underscored by the success of several reintroductions into their former ranges, including the Hay-Zama herd in northwestern Alberta, the MacKenzie and Nahanni herds in the Northwest Territories and the Aishihik herd in the Yukon. The wood bison population in Canada has increased since 1987, mostly due to the establishment of new wild subpopulations within the original range. As a result, the Committee on the Status of Endangered Wildlife in Canada ( COSEWIC ) recently downlisted wood bison from Threatened to Special Concern. Although the preceding is positive, Teck acknowledges that western-science-based data on habitat and seasonal range use by the Ronald Lake wood bison herd are limited, although more data are becoming available through the research being completed by ESRD (see the response to ESRD/CEAA Round 3 SIR 85 for an update). Teck is contributing financial, technical and in-kind support to ESRD s study of the Ronald Lake bison herd. This ongoing, multi-year study aims to collect data related to gaps in knowledge about the Ronald Lake bison herd. The work includes aerial surveys, sample collection for disease and genetic testing, and bison collaring with GPS telemetry collars. Data from the collars will help establish the Ronald Lake bison herd range and to develop a resource-selection-function habitat suitability model. Funding provided by Teck supports work planned and conducted by ESRD from November 1, 2013 to March 31, As described in the response to ESRD/CEAA Round 3 SIR 85a, Appendix 85a.1, Teck is also investigating, from a western-science perspective, the extent of limiting winter feeding habitat for an expanded area that includes the southern part of WBNP. This study is being completed to better understand habitat availability in and around the area currently identified as the Ronald Lake bison herd range that has been defined based on known information (i.e., the range defined in the response to ESRD/CEAA Round 1 SIR 219c, Appendix 219c.1 and the minimum convex polygon defined by GOA [2013]). These incremental western-science-based studies will provide greater precision of the herd s possible range, availability of feeding habitat for winter use and carrying capacity. Once further details on bison movement patterns are available, Teck expects the information will inform future research and provide input to a wildlife mitigation and monitoring plan for the Project. f. In the, the definition of environmental consequence considered both the magnitude of change (i.e., TEMF Management Response Triggers; CEMA 2008) and its reversibility (see Volume 6, Section 4.3.6, Table 4-5, Page 4-24). Based on this, if an effect on a particular species has a high magnitude but the effect is considered reversible, it would have a moderate environmental consequence. This is how a change in habitat availability for wood bison was determined to be of moderate environmental consequence. Teck further clarified this conclusion in its response to ESRD/CEAA Round 2 SIR 188, explaining that this conclusion was predicated on the assumption that the Ronald Lake bison herd interacts with ESRD/CEAA Page 394 October 2014

397 Frontier Oil Sands Mine Project ESRD and CEAA Responses Approvals diseased bison in WBNP (ASRD 2010) and therefore has similar characteristics (e.g., carries disease and is not genetically pure wood bison). As stated in the response to ESRD/CEAA Round 2 SIR 188, recent research has indicated that the Ronald Lake bison herd do not appear to have a similar disease prevalence of TB [tuberculosis] or brucellosis to that occurring in WBNP and that tuberculosis and brucellosis was not detected at a rate of 12% of greater in the herd (GOA 2012). The Government of Alberta (GOA 2012) final progress report does note that these findings do not confirm that the herd is free of disease, but rather the results suggest that disease prevalence is less than 12%. During a recent meeting of the Ronald Lake Bison Herd Technical Studies Team (June 13, 2014), it was discussed that the results of the 2014 testing also came up negative and that the newly calculated disease prevalence was less than 5% (Skilnick 2014, pers. comm.). Genetic testing of the Ronald Lake bison herd indicates they are genetically similar to bison in WBNP, although the level of differentiation is strong, suggesting genetic exchange is negligible (Ball 2013). Because research has shown that the Ronald Lake bison herd is not infected with bovine tuberculosis or brucellosis to a large degree (i.e., less than 5% disease prevalence), displacing the herd north towards diseased bison in WBNP would be considered a high environmental consequence without mitigation following the western-science-based approach outlined in the. The high environmental consequence rating is based on the potential for a population decline of the herd that might result from shifting the herd northward and introducing disease that would potentially increase mortality rates (i.e., it represents a potential effect on the resource). This conclusion (i.e., high environmental consequence) is supported by the results of additional sampling completed in 2014 (Skilnick 2014, pers. comm.) and data indicating that members of the Ronald Lake bison herd currently enter WBNP (GOA 2013). Use of WBNP could introduce members of the Ronald Lake bison herd to disease if use of WBNP by the herd is a recent phenomenon. If the Ronald Lake bison herd has historically used WBNP, then disease risk would not likely differ. Although the Ronald Lake bison herd is considered genetically similar to bison in WBNP, there is a strong level of differentiation between the two herds, suggesting that genetic exchange is negligible (Ball 2013). Genetic testing further suggests that the Ronald Lake bison herd does not currently comprise genetically pure wood bison or pure plains bison. Rather, the results suggest that the herd shares a genetic association with both subspecies (Ball 2013). Therefore, it could be suggested that current and recent historic interaction has been minimal. It is also expected that conclusions about changes in habitat availability will be updated once the Ronald Lake bison herd range is determined. ESRD is currently collecting GPS telemetry data for this purpose (see the response to ESRD/CEAA Round 3 SIR 85). The assessment conclusions discussed in this response are based on western science and have not considered traditional knowledge, Aboriginal culture or rights. October 2014 ESRD/CEAA Page 395

398 ESRD and CEAA Responses Approvals Frontier Oil Sands Mine Project g. As discussed in the responses to previous SIRs (see the response to ESRD/CEAA Round 2 SIR 196 and ESRD/CEAA Round 1 SIRs 230 and 231), Teck believes that a habitat-based approach (as previously described in Volume 6, Section 4.8.2, Pages to 4-340) is a reasonable and reliable assessment method to assess effects on wildlife populations, particularly when supplemented with relative abundance indices derived from wildlife field surveys. Effects of the Project on relative abundance and distribution of the herd were not assessed because complete and accurate data on the herd was not available at the time of the or Round 1 and Round 2 SIRs. The ESRD-led research program underway for the Ronald Lake bison herd is planned for completion in spring Although this information is unlikely to be available to inform the Project Update (see the response to AER Round 3 SIR 1), Teck will incorporate the results into the development of future wildlife mitigation and monitoring programs for the Project. These programs will be developed with regulators and potentially affected Aboriginal communities. h. See the response to part g. i. Teck acknowledges that some effects on the Ronald Lake bison herd will be unavoidable. For example, during construction and operation, bison will be displaced from the PDA. Loss of bison habitat during operation can be mitigated through reclamation practices, including progressive reclamation and temporary reclamation that provides cover to mitigate erosion and topsoil loss. Teck plans to develop an access management plan for the Project that will address hunting access by Aboriginal people and non-aboriginal hunters (see the response to ESRD/CEAA Round 3 SIR 75 and SIR 76). Early results from the ESRD-led studies indicate that individuals from the Ronald Lake bison herd enter WBNP (Skilnick 2014, pers. comm.), likely because of forage and habitat availability. However, there are no previous data to confirm whether WBNP is part of the herd s traditional range or whether it represents a range expansion or shift resulting from some other factor. Because management of the bison is the responsibility of the Governments of Alberta and Canada, Teck cannot do anything to alter current use of WBNP by the Ronald Lake bison herd, particularly if it is a natural occurrence. j. Research conducted to date by GOA (2013) has confirmed that the Ronald Lake bison herd has a disease prevalence of less than 5% and is considered genetically distinct from herds in the WBNP. However, the herd is not currently considered wildlife as defined under the Alberta Wildlife Act and is not protected from hunting. Preliminary discussions have taken place between ESRD and other stakeholders, including potentially affected Aboriginal communities, to consider the implications of listing the herd as wildlife (see Appendix 81c.1). In Canada, wood bison are designated as Threatened (Schedule 1) under the Species at Risk Act (SARA). Environment Canada plans to release a draft Recovery Strategy for Wood Bison in Teck is hopeful that the Recovery Strategy will be developed in coordination with ESRD to ensure that it aligns with the province s plans for the Ronald Lake bison herd. Teck notes that the Committee ESRD/CEAA Page 396 October 2014

399 Frontier Oil Sands Mine Project ESRD and CEAA Responses Approvals on Status of Endangered Wildlife in Canada (COSEWIC) recently assessed the status of wood bison and has recommended down-listing them to Special Concern (COSEWIC 2014). If the recommended down-listing is accepted, a recovery strategy would not be required under SARA (only a management plan). As a result, Critical Habitat would not be identified. Genetic testing suggests that the Ronald Lake bison herd does not currently comprise genetically pure wood bison or pure plains bison. Rather, the results suggest that the herd shares a genetic association with both subspecies (Ball 2013). It is therefore unclear whether the Ronald Lake bison herd would be considered a species at risk under SARA and, as such, whether Critical Habitat for the herd would be defined. Teck is currently contributing financial, technical and in-kind support to ESRD s study of the Ronald Lake bison herd. This ongoing, multi-year study aims to collect data related to gaps in knowledge about the Ronald Lake bison herd, including those related to their genetic and disease status. The study includes aerial surveys, collection of samples for disease and genetic testing, and bison collaring with GPS telemetry collars. Data from the collars will help establish the Ronald Lake bison herd range and develop a resource-selection-function habitat suitability model. Funding provided by Teck supports work conducted and planned by ESRD from November 1, 2013 to March 31, Given that research is ongoing and the status of the herd is being evaluated, Teck is not currently able to identify, specifically, how impacts to Critical Habitat for wood bison (as defined by SARA) will be mitigated if Critical Habitat is identified in the PDA. k. Teck s conclusions about the cumulative effects on hunting of the Ronald Lake bison herd were based on a western-science approach that considered the environmental consequence of changes to habitat availability and mortality risk from vectors such as disease. The conclusions were not informed by a full traditional use study of bison habitat and kill sites in the PDA and surroundings. Teck hopes that the work identified in the response to parts a through j and the response to ESRD/CEAA Round 3 SIR 85 will be complete and available to inform the Project Update. l. Alberta Energy Regulator (AER), in its recent decision on Teck s 2013 application for oil sands evaluation well licenses (AER 2013), addressed the potential effects of: current and proposed exploration activities on Aboriginal use of the Ronald Lake bison herd the potential for increased non-aboriginal harvest resulting from increased access opportunities within the PDA potential effects of exploration activities on the distribution, abundance and movement of the herd In regards to Aboriginal use of the herd and potential effects of exploration activities on the distribution, abundance and movement of the herd, the panel stated that although there were conflicting views on the sensitivity of the RLBH [Ronald Lake bison herd] to direct habitat loss and sensory disturbance, the panel finds that the recent 2013 study s radio collar data and observations of wood bison during previous winter drilling programs, and the ongoing use of the area for bison hunting by MCFN and AFCN harvesters all indicate that the RLBH continues to October 2014 ESRD/CEAA Page 397

400 ESRD and CEAA Responses Approvals Frontier Oil Sands Mine Project use the project area despite previous winter drilling programs in the area. The panel therefore concludes that while members of the RLBH may move away from the immediate vicinity of areas of human activity or noise associated with the Corehole Program, the evidence does not support the view that the RLBH will travel large distances or permanently abandon the area as a result of the Corehole Program. Given the nature of Teck s proposed activities, the panel finds that the amount of direct habitat loss will be small and that any indirect habitat loss due to sensory disturbance will be localized and of short duration. (AER 2013, page 14) In regards to increased harvesting pressure on the herd, in particular concerns by ACFN and MCFN that increased access would increase non-aboriginal hunting, The panel acknowledges that creating new access to the RLBH has the potential to result in increased hunting of the herd. The panel also recognizes that disturbance caused by temporary exploration programs near the Corehole Program area can contribute to an increase in the effort, risk, and cost experienced by resource harvesters. The panel notes, however, that very little new access will be created as a direct result of the Corehole Program; most access disturbance already exists and was approved as part of previous exploration programs. The panel finds that any disturbance effects will be localized and temporary and that the mitigation measures proposed by Teck are appropriate. (AER 2013, page 19) In addition, the panel found that: the mitigation measures proposed by Teck for managing access and protecting the RLBH are appropriate. The panel finds that the proposed access mitigation measures adequately address concerns about enabling increased access for both non-aboriginal and aboriginal hunters that could adversely affect the RLBH. (AER 2013, page 15) Teck agrees that the effects of current and proposed exploration drilling program on the Ronald Lake bison herd, including its use by Aboriginal communities, are localized and temporary. However, as discussed in the response to part a, some Aboriginal communities have expressed different views. REFERENCES AER (Alberta Energy Regulator) Decision 2013 ABAER 017: Teck Resources Limited, Application for Oil Sands Evaluation Well Licenses, Undefined Field. Calgary, Alberta. ASRD (Alberta Sustainable Resource Development) Ronald Lake (Bison bison) Survey February Prepared by Todd Powell and Traci Morgan, ASRD, Fort McMurray, Alberta. November Ball, M.C Characterizing the Genetic Population Structure of Wild Bison in Alberta, Canada. Alberta Environment and Sustainable Resource Development. October ESRD/CEAA Page 398 October 2014

401 Frontier Oil Sands Mine Project ESRD and CEAA Responses Approvals Candler, C., Firelight Group Research Cooperative and the Athabasca Chipewyan First Nation. 2013a. Athabasca Chipewyan First Nation Indigenous Knowledge and Use Report and Assessment for Teck Resources Limited Proposed Frontier Oil Sands Mine Project. November 20, Candler, C., Olson, R., Firelight Group Research Cooperative and the Mikisew Cree First Nation. 2013b. Mikisew Cree First Nation Knowledge and Use Report and Assessment for Teck Resources Limited Proposed Frontier Oil Sands Mine Project. November 15, CEMA (Cumulative Environmental Management Association) Terrestrial Ecosystem Management Framework for the Regional Municipality of Wood Buffalo. Fort McMurray, Alberta. COSEWIC (Committee on the Status of Endangered Wildlife in Canada) Wildlife Species Search. Available at: Accessed: June Gates, C.C., R.O. Stephenson, H.W. Reynolds, C.G. van Zyll de Jong, H. Schwantjie, M. Hoefs, J. Nishi, N. Cool, J. Chisholm, A. Haes and B. Koon National Recovery Plan for the Wood Bison (Bison bison athabascae). National Recovery Plan No. 21. Recovery of Nationally Endangered Wildlife. Ottawa, Ontario. Gates, C.C., C.H. Freese, P.J.P. Gogan and M. Kotzman American Bison: Status Survey and Conservation Guidelines International Union for the Conservation of Nature Species Survival Commission (IUCN/SSC) American Bison Specialist Group, Gland, Switzerland. GOA (Government of Alberta) Managing Disease Risk in Alberta s Wood Bison with Special Focus on Bison to the West of Wood Buffalo National Park: Progress Report. Government of Alberta, Edmonton, Alberta. GOA Ronald Lake (Bison bison) Winter Activities Progress Report. Government of Alberta, Edmonton Alberta. Shell (Shell Canada Energy) Letter from Shell Canada Energy to the Joint Review Panel Chairman requesting a delay in the application process, February 11, Available at: Accessed March Skilnick, J Preliminary Activities Presented to the Ronald Lake Bison Herd Technical Studies Team. Senior Wildlife Biologist, Alberta Environment and Sustainable Resource Development. Fort McMurray, Alberta. Question 82 Volume 1, ESRD/CEAA SIR 188, Page To supplement the response to federal SIR # 2.10 of December 23, 2013, provide the following information: a. In the assessment of effects to bison requested in part (a), include the following: October 2014 ESRD/CEAA Page 399

402 ESRD and CEAA Responses Approvals Frontier Oil Sands Mine Project i. a pre-2006 baseline, ii. an assessment of avoidance reactions of the herd, and iii. seasonal habitat availability within home ranges, as determined by TEK, government and industry surveys, and current telemetry data on cow and bull bison. If adequate telemetry data are not available to accurately define seasonal ranges for cow or bull bison, identify when this data will be incorporated into the EIS to ensure a complete analysis of effects on the herd; b. In assessing the impacts of the Project on the traditional use of bison by Aboriginal people, describe how the Project and activities included in the cumulative effects assessment will affect the ability of Aboriginal peoples to access bison and how the Project and activities included in the cumulative effects assessment may affect the spiritual, cultural and economic value of bison to Aboriginal people. Response 82 a. i. It is Teck s understanding that CEAA is asking for an updated existing condition (baseline), prior to In the wildlife assessment submitted as part of the, existing conditions were defined as Most disturbance footprints present in the existing condition (i.e., baseline at 2008) were associated with exploratory drilling. Prior to 2006, there was little human disturbance in the PDA, and therefore, the pre-2006 PDA landscape was similar to the predevelopment reference condition. In response to ESRD/CEAA Round 2 SIR 136, Teck included a predevelopment reference condition for the Ronald Lake bison herd study area that did not include any human activities. The assessment was completed by comparing each of the assessment cases to predevelopment. ii. In developing the habitat suitability model for the Ronald Lake bison herd, zones of influence (ZOI) were applied to model results to account for potential sensory disturbance effects of disturbance footprints and human activities on bison habitat use (see Volume 6, Appendix 4A). It is Teck s understanding that ESRD s current research on the Ronald Lake bison herd will add to the existing information about bison habitat use and avoidance of disturbance footprints and human activities. Teck is currently gathering on-site data using wildlife sightings cards and remote cameras to understand whether individuals from the Ronald Lake bison herd were displaced by drilling activities. During the winter program, Project employees submitted 217 wildlife records, including 21 bison observations (see the response to ESRD/CEAA Round 3 SIR 61, Appendix 61a.1). The following year, more than twice as many wildlife records (523) were submitted as part of the winter program; however, this increase may not have been related to an increase in wildlife use, but rather an increased awareness by on-site staff. These records included 17 sightings of bison; each sighting ranged from a single bison to groups of five ESRD/CEAA Page 400 October 2014

403 Frontier Oil Sands Mine Project ESRD and CEAA Responses Approvals bison, for a total of 36 bison observations (see the response to ESRD/CEAA Round 3 SIR 61, Appendix 61a.1). Of the 36 bison observed, only two were observed to be running. Teck acknowledges that incidental wildlife sightings provide limited information; however, these sightings confirm the continued presence of bison in the area during the period that the drilling program was active and that most observed animals were not startled by the presence of machinery or human observers. The remote camera monitoring, which occurred from October 2013 to October 2014, was based on a before-after-control-impact (BACI) design, with 20 cameras in the PDA (i.e., impact cameras) and 20 in a control setting (i.e., control cameras) (see the response to ESRD/CEAA Round 3 SIR 61, Appendix 61a.2). The 20 control cameras were placed north of the PDA, in relatively undisturbed habitat. Interim results showed bison at 10 control cameras and nine impact cameras, with bison recorded at 16 of the 19 cameras (10 control; 6 impact) occurring in undisturbed sites (see the response to ESRD/CEAA Round 3 SIR 61, Appendix 61a.2). As with the sighting cards, impact cameras recorded bison during the drilling program, confirming that they continued to use the area during drilling. iii. Teck has used all available information to determine the range of the Ronald Lake bison herd, including ESRD (2010) and traditional knowledge from ACFN (Candler et al. 2013a; ACFN 2011) and MCFN (Candler et al. 2013b). The Ronald Lake bison study area defined in the and subsequent SIRs deviates slightly from ACFN accounts of the extent of bison habitat (ACFN 2011; Candler et al. 2013a). The difference relates to the Firebag River. ACFN (2011) and Candler et al. (2013a) show that there is observed core bison habitat on the east side of the Athabasca River along the Firebag River. However, ASRD (2010) and Candler et al. (2013b) both indicate that the Ronald Lake bison herd range is currently confined to the west side of the Athabasca River. Because information is still being collected and preliminary data indicate that collared bison are only on the west side of the Athabasca River (Skilnick 2014, pers. comm.), Teck decided not to include habitat on the east side of the Athabasca River in the Ronald Lake bison study area. Bison sightings in the Pierre River Mine LSA were limited to incidental observations (Shell 2007). Teck confirmed that Shell had no additional bison data for the proposed PRM that could be used to delineate the bison study area. As well, Teck has reviewed the draft Ronald Lake Bison (Bison bison) Winter Activities Progress Report (GOA 2013) and preliminary results for 2013 to 2014 presented to the Ronald Lake Bison Herd Technical Studies Team (Skilnick 2014, pers. comm.). These results indicate that individuals from the Ronald Lake bison herd use habitat within WBNP. However, because these results are still preliminary, they were not used to update the bison study area at this time. As described in the response to ESRD/CEAA Round 3 SIR 61, Teck is currently contributing financial, technical and in-kind support to ESRD s study of the Ronald Lake bison herd. This October 2014 ESRD/CEAA Page 401

404 ESRD and CEAA Responses Approvals Frontier Oil Sands Mine Project ongoing, multi-year study represents the first scientific study to collect data specifically on the Ronald Lake bison herd. The study includes aerial surveys, sample collection for disease and genetic testing, and bison collaring with GPS telemetry collars. Data from the collars will help establish the Ronald Lake bison herd range and develop a resource-selection-function habitat suitability model. Funding provided by Teck supports work planned and conducted by ESRD from November 1, 2013 to March 31, Teck is currently in communication with ESRD to determine when data from the research program will be made available. Once available, the results of the ESRD-led research will be used to inform Project-specific mitigation and monitoring programs for the Ronald Lake bison herd. b. MCFN has told Teck that it has concerns with the degree and manner with which MCFN s traditional knowledge and Aboriginal perspectives have been considered and incorporated by Teck, particularly in assessing impacts to MCFN s rights and culture. This response does not incorporate traditional knowledge. To this end, Teck acknowledges the need for further engagement regarding this SIR. Teck will revisit this SIR and conclusions contained in it once the parties have pursued the collaborative process that Teck and MCFN are working to develop and as additional information is gathered. ACFN has clearly stated that it has concerns with the degree and manner with which ACFN s traditional knowledge and Aboriginal perspectives have been considered and incorporated by Teck, particularly in the assessment of impacts to ACFN s rights and culture. Recognizing that additional work needs to be done, Teck has requested to meet with ACFN to co-create a process to address outstanding concerns, to revisit certain conclusions made by Teck in the, and to work toward understanding and incorporating ACFN s traditional land use and traditional knowledge into the assessment in a meaningful way. Teck will update regulators on a regular basis about the progress of these discussions. Teck will not be filing responses to Round 3 SIRs that pertain to traditional knowledge or the assessment of impacts to ACFN s rights and culture with regulators until the parties have pursued the collaborative process referred to above, or until Teck and ACFN agree otherwise. REFERENCES ACFN (Athabasca Chipewyan First Nation) Integrated Knowledge and Land Use Report and Assessment for Shell Canada s Proposed Jackpine Mine Expansion and Pierre River Mine. Submitted to Athabasca Chipewyan First Nation Industry Relations Corporation. ASRD (Alberta Sustainable Resource Development) Ronald Lake Bison (Bison bison) Survey February Prepared by Todd Powell and Traci Morgan, ASRD, Fort McMurray, Alberta. November Candler, C., Firelight Group Research Cooperative, with the Athabasca Chipewyan First Nation. 2013a. Athabasca Chipewyan First Nation Indigenous Knowledge and Use Report and Assessment for Teck Resources Limited Proposed Frontier Oil Sands Mine Project. November 20, ESRD/CEAA Page 402 October 2014

405 Frontier Oil Sands Mine Project ESRD and CEAA Responses Approvals Candler, C., Olson, R., Firelight Group Research Cooperative, with the Mikisew Cree First Nation. 2013b. Mikisew Cree First Nation Knowledge and Use Report and Assessment for Teck Resources Limited Proposed Frontier Oil Sands Mine Project. November 15, GOA (Government of Alberta) Ronald Lake Bison (Bison bison) Winter Activities Progress Report. Government of Alberta, Edmonton Alberta. Shell (Shell Canada Energy) Jackpine Mine Expansion and Pierre River Mine Project: Wildlife and Wildlife Habitat Environmental Setting. Volume 5, Section Submitted to Alberta Environment and the Alberta Energy and Utilities Board, December Skilnick, J Preliminary Activities Presented to the Ronald Lake Bison Herd Technical Studies Team. Senior Wildlife Biologist, Alberta Environment and Sustainable Resource Development. Fort McMurray, Alberta. Question 83 Volume 1, ESRD/CEAA SIR 188, Pages 530 to 533 To supplement the response to federal SIR # 2.10 of December 23, 2013, provide the following information: a. As part of the response to (f), identify information gaps for the Ronald Lake herd (e.g., seasonal ranges for cows and bulls, population size and trend, etc.), when this information will be collected, and how it will be incorporated into the environmental assessment. b. As part of the response to (k), explain what is meant as a moderate impact to Aboriginal people who prefer to hunt wood bison north of the PAA. Response 83 a. MCFN and ACFN have expressed concerns about the degree and manner with which their traditional knowledge and Aboriginal perspectives have been considered and incorporated by Teck, particularly in the assessment of impacts to Aboriginal rights and culture. To this end, Teck acknowledges the need for further engagement with MCFN and ACFN regarding bison, potential effects of the Project on bison, and development of a mitigation and monitoring plan for the Ronald Lake bison herd. Teck will revisit conclusions made in response to this SIR once the parties have pursued the collaborative process that Teck, MCFN and ACFN are working to develop and as additional information is gathered. In the interim, Teck has provided current information that is based on western science and that is relevant to each of these issues. Teck expects that this information will be reviewed in more detail with potentially affected Aboriginal communities, and that additional information provided by Aboriginal communities will be integrated into the bison-specific mitigation and monitoring plan that will be developed for the Project. October 2014 ESRD/CEAA Page 403

406 ESRD and CEAA Responses Approvals Frontier Oil Sands Mine Project As per Teck s agreement with ESRD with respect to the Ronald Lake bison herd, current studies have a research focus. These ongoing studies aim to: gather samples from the herd for disease and genetic testing fit bison with GPS telemetry collars to gather bison location data investigate bison habitat use and the effects of industrial development on use of their range (i.e., seasonal ranges for cows and bulls) use mark and resight aerial surveys to estimate herd populations The current program is expected to continue until March 31, 2015, and is likely to generate data that will inform herd management and identify future research needs. Information from this study will also be used to determine Project-specific mitigation that will be part of the wildlife mitigation and monitoring plan. When data are available from ESRD, Teck will incorporate this western-science-based information into the wildlife mitigation and monitoring plan that will be developed for the Project. It is Teck s hope that traditional knowledge and Aboriginal perspectives on bison will also be incorporated into the wildlife mitigation and monitoring plan. b. MCFN has told Teck that it has concerns with the degree and manner with which MCFN s traditional knowledge and Aboriginal perspectives have been considered and incorporated by Teck, particularly in the assessment of impacts to MCFN s rights and culture. This response does not incorporate traditional knowledge. To this end, Teck acknowledges the need for further engagement regarding this SIR. Teck will revisit this SIR and conclusions made in it once the parties have pursued the collaborative process that Teck and MCFN are working to develop and as additional information is gathered. ACFN has clearly stated that it has concerns with the degree and manner with which ACFN s traditional knowledge and Aboriginal perspectives have been considered and incorporated by Teck, particularly in the assessment of impacts to ACFN s rights and culture. Recognizing that additional work needs to be done, Teck has requested a meeting with ACFN to co-create a process to address outstanding concerns, to revisit certain conclusions made by Teck in the, and to work toward understanding and incorporating ACFN s traditional land use and traditional knowledge into the assessment in a meaningful way. Teck will update regulators on a regular basis about the progress of these discussions. Teck will not be filing responses to Round 3 SIRs that pertain to traditional knowledge or the assessment of impacts to ACFN s rights and culture with regulators until the parties have pursued the collaborative process referred to above, or until Teck and ACFN agree otherwise. ESRD/CEAA Page 404 October 2014

407 Frontier Oil Sands Mine Project ESRD and CEAA Responses Approvals Wildlife Question 84 Volume 1, ESRD/CEAA, Section 4, Terrestrial, Wildlife, Pages In its response, Teck states that there appears to be more highly suitable habitat for boreal caribou in the Red Earth boreal caribou range than for moose and deer. Therefore, it would appear unlikely that moose and deer and associated predators would occupy this range, if displaced from the PDS. Teck s response and land cover class habitat rankings do not consider known patterns of habitat use by moose and deer in northeastern Alberta. Several studies have reported high occurrence of moose and deer in lowland (peatland) habitats, and data suggests that moose may select lowland habitats at certain times of the year. For example, Hauge and Keith (1980) 2 reported relatively high use of lowland habitats (shrub and treed peatlands) by moose during winter (December and January) and spring (April and May) in northeastern Alberta and concluded that open lowland habitats may comprise the most critical element in the year-round habitat for moose. Latham and Boutin (2008) 3 also reported high numbers of white-tailed deer in a large fen complex in the West-side Athabasca caribou range, and reported that 39% of deer observations in winter occurred in peatlands. Furthermore, Latham and Boutin (2007) reported that white-tailed deer in northeastern Alberta browse on arboreal lichens, and suggested this may result in direct competition for food between deer and caribou in areas of spatial overlap. Given the known use of peatland habitats by moose and deer: a. Amend the response to SIR #92 or provide further justification, using available scientific information, to explain why moose and deer are unlikely to occupy caribou range if displaced from the Project development area (PDA). b. Incorporate aboriginal traditional knowledge (based on existing and ongoing studies) on the distribution, occurrence and habitat use of caribou, deer and moose in the RSA into the response, as appropriate. 2 Hauge, T.M. and L.B. Keith Dynamics of moose populations in northeastern Alberta. J. Wildl. Manage. 45(3) Latham, A.D and S. Boutin Evidence of arboreal lichen use in peatlands by White-tailed Deer, Odocoileus virginianus, in northeastern Alberta. Canadian Field-Naturalist 122(3): October 2014 ESRD/CEAA Page 405

408 ESRD and CEAA Responses Approvals Frontier Oil Sands Mine Project Response 84 a. As stated previously in the response to ESRD/CEAA Round 2 SIR 189c:... Precise predictions regarding overall population effects of the Project, if any, are difficult to make given the lack of information available on wolf [, deer] and moose displacement from development in northeastern Alberta. In particular, there is little information about where these species might be displaced to. Teck acknowledges that moose and, more recently, deer in northeastern Alberta have been documented in lowland habitat (Hauge and Keith 1981; Osko et al. 2004; Latham and Boutin 2008). However, we contend that well-drained upland regions provide more highly suitable habitat for these species. Recent literature supports this theory for northeastern Alberta (James et al. 2004; Wasser et al. 2011; Latham et al. 2011; Fisher et al. 2013; Latham et al. 2013) and elsewhere in boreal systems (Dussault et al. 2006; Poley et al. 2014). Peatlands generally provide low cover (i.e., security from predators) and browse value for moose and deer compared to adjacent uplands with deciduous understories. As such, bogs and fens are commonly referred to as unproductive habitat for moose (e.g., Dussault et al. 2006). Caribou and alternate prey species (e.g., moose and white-tailed deer) typically occupy opposing habitats (i.e., peatlands versus uplands and disturbed sites) year round in boreal regions (i.e., James et al. 2004; Latham et al. 2013; Poley et al. 2014). These patterns of habitat selection are fundamental to the widely supported theory of spatial separation, which explains coexistence among these species and their associated predators (Bergerud et al. 1984; Seip 1992). Recent evidence for northeastern Alberta suggests spatial separation of wolves and caribou still occurs even though the primary prey of wolves might have switched from moose (James et al. 2004) to white-tailed deer, particularly during winter (Latham et al. 2011, 2013). Latham et al. (2013) also noted that more than 70% of white-tailed deer sightings occurred in upland habitat, while around 80% of caribou observations were in peatlands. This observation was shared by Wasser et al. (2011) who described a strong negative correlation between caribou and deer habitat selection in northeastern Alberta. Similarly, Fisher et al. (2013) states that deer occurrence near the CLAWR was best explained by the percentage of upland deciduous habitat and the percent of human footprint. The study concludes that white-tailed deer selected early seral habitat associated with anthropogenic disturbance over all other habitat. Latham et al. (2013) suggests that increased spatiotemporal overlap between wolves and caribou during summer was explained not by movement of white-tailed deer or moose into peatlands, but by a shift in wolf prey selection towards beaver. Habitat in the Red Earth boreal caribou range, directly west of the Project, is primarily peatland bogs. Therefore, it is expected that moose and deer would not use that area as much as regions north of the PAA and along the Athabasca River where habitat is more suitable (i.e., upland). As a result, the likelihood of increased spatiotemporal overlap between boreal caribou and other ungulates because of Project activities is assumed to be minimal in the eastern portion of the Red Earth herd range. ESRD/CEAA Page 406 October 2014

409 Frontier Oil Sands Mine Project ESRD and CEAA Responses Approvals MCFN has told Teck that it has concerns with the degree and manner with which MCFN s traditional knowledge and Aboriginal perspectives have been considered and incorporated by Teck, particularly in the assessment of impacts to MCFN s rights and culture. This response does not incorporate traditional knowledge. To this end, Teck acknowledges the need for further engagement regarding this SIR. Teck will revisit this SIR and conclusions made in it once the parties have pursued the collaborative process that Teck and MCFN are working to develop and as additional information is gathered. ACFN has clearly stated that it has concerns with the degree and manner with which ACFN s traditional knowledge and Aboriginal perspectives have been considered and incorporated by Teck, particularly in the assessment of impacts to ACFN s rights and culture. Recognizing that additional work needs to be done, Teck has requested to meet with ACFN to co-create a process to address outstanding concerns, to revisit certain conclusions made by Teck in the, and to work toward understanding and incorporating ACFN s traditional land use and traditional knowledge into the assessment in a meaningful way. Teck will update regulators on a regular basis about the progress of these discussions. Teck will not be filing responses to Round 3 SIRs that pertain to traditional knowledge or the assessment of impacts to ACFN s rights and culture with regulators until the parties have pursued the collaborative process referred to above, or until Teck and ACFN agree otherwise. b. Aboriginal knowledge and use reports submitted by ACFN (Candler et al. 2013a) and MCFN (Candler et al. 2013b) were reviewed for any additional information about woodland caribou, moose and deer. These studies indicate that the terrestrial LSA is in an important area for moose (although their numbers were thought to be declining). Caribou have historically used this area as well, although they are now rarely seen within the revised terrestrial LSA (Candler et al. 2013a, 2013b). Members of the MCFN have indicated that more white-tailed deer have been observed in the region over the past few years (Candler et al. 2013b). The information provided in Candler et al. (2013a, 2013b) does not specifically address peatland use by moose and deer. Teck plans to further engage ACFN and MCFN in understanding how traditional knowledge and traditional land use information provided since Teck s response to Round 2 SIRs can be meaningfully incorporated into the assessment. MCFN has told Teck that it has concerns with the degree and manner with which MCFN s traditional knowledge and Aboriginal perspectives have been considered and incorporated by Teck, particularly in the assessment of impacts to MCFN s rights and culture. This response does not incorporate traditional knowledge. To this end, Teck acknowledges the need for further engagement regarding this SIR. Teck will revisit this SIR and conclusions made in it once the parties have pursued the collaborative process that Teck and MCFN are working to develop and as additional information is gathered. October 2014 ESRD/CEAA Page 407

410 ESRD and CEAA Responses Approvals Frontier Oil Sands Mine Project ACFN has clearly stated that it has concerns with the degree and manner with which ACFN s traditional knowledge and Aboriginal perspectives have been considered and incorporated by Teck, particularly in the assessment of impacts to ACFN s rights and culture. Recognizing that additional work needs to be done, Teck has requested to meet with ACFN to co-create a process to address outstanding concerns, to revisit certain conclusions made by Teck in the, and to work toward understanding and incorporating ACFN s traditional land use and traditional knowledge into the assessment in a meaningful way. Teck will update regulators on a regular basis about the progress of these discussions. Teck will not be filing responses to Round 3 SIRs that pertain to traditional knowledge or the assessment of impacts to ACFN s rights and culture with regulators until the parties have pursued the collaborative process referred to above, or until Teck and ACFN agree otherwise. REFERENCES Bergerud, A.T., H.E. Butler and D.R. Miller Antipredator tactics of calving caribou: dispersion in mountains. Canadian Journal of Zoology 62: Candler, C. and the Firelight Group Research Cooperative, with The Athabasca Chipewyan First Nation. 2013a. Athabasca Chipewyan First Nation Knowledge and Use Report and Assessment for Teck Resources Limited s Proposed Frontier Oil Sands Mine Project. Candler, C., R. Olson and the Firelight Group Research Cooperative, with The Mikisew Chipewyan First Nation. 2013b. Mikisew Cree First Nation Indigenous Knowledge and Use Report and Assessment for Teck Resources Limited s Proposed Frontier Oil Sands Mine Project. Dussault, C., R. Courtois and J.P. Ouellet A habitat suitability index model to assess moose habitat selection at multiple spatial scales. Canadian Journal of Forest Research 36: Fisher, J.T., M. Hiltz, L. Nolan and L.D. Roy Alberta Boreal Deer Project Fiscal Year Report. Alberta Innovates Technology Futures, Edmonton, Alberta. Hauge, T.M. and L.B. Keith Dynamics of moose populations in northeastern Alberta. Journal of Wildlife Management 45: James, A.R.C., S. Boutin, D.M. Hebert and A.B. Rippin Spatial separation of caribou from moose and its relation to predation by wolves. Journal of Wildlife Management 68: Latham, A.D.M. and S. Boutin Evidence of aboreal lichen use in peatland by white-tailed deer, Odocoileus virginianus, in northeastern Alberta. The Canadian Field Naturalist 122: Latham, A.D.M., M.C. Latham, N.A. McCutchen and S. Boutin Invading white-tailed deer change wolf-caribou dynamics in northeastern Alberta. Journal of Wildlife Management 75: Latham, A.D.M., M.C. Latham, K.H. Knopff, M. Hebblewhite and S. Boutin Wolves, white-tailed deer, and beaver: implications of seasonal prey switching for woodland caribou declines. Ecography 36: ESRD/CEAA Page 408 October 2014

411 Frontier Oil Sands Mine Project ESRD and CEAA Responses Approvals Osko, T.J., M.N. Hiltz, R.J. Hudson and S.M. Wasel Moose habitat preferences in response to changing availability. Journal of Wildlife Management 68: Poley, L.G., B.A. Pond, J.A. Schafer, G.S. Brown, J.C. Ray and D.S. Johnson Occupancy patterns of large mammals in the far north of Ontario under imperfect detection and spatial autocorrelation. Journal of Biogeography 41: Seip, D.R Factors limiting woodland caribou populations and their interrelationships with wolves and moose in southeastern British Columbia. Canadian Journal of Zoology 70: Wasser S.K., J.L. Keim, M.L. Taper and R.L. Subhash The influences of wolf predation, habitat loss, and human activity on caribou and moose in Alberta oil sands. Frontiers in Ecology and the Environment 9: Question 85 Volume 1, ESRD/CEAA, Section 6, Approvals, Federal, Aboriginal Consultation and Traditional Land Use, Pages In its response, Teck assumes that wood bison from the Ronald Lake herd will likely remain in their current range during Project operations. Teck provides no evidence to support this claim. Data from Wood Buffalo National Park (Joly ) and elsewhere indicate that bison are able to move considerable distances, thus raising the concern that some Ronald Lake bison may move out of their current range when disturbed. This has implications for disease transmission to the herd from infected animals in Wood Buffalo National Park, and also loss of hunting opportunities for Aboriginal peoples. a. Provide evidence to support its claim that wood bison from the Ronald Lake herd will likely remain within their current home range during Project construction and operations. As part of this response, provide: i. A summary of any research that evaluates the movement of wild (non-habituated) freeranging wood bison following disturbance; ii. A summary of natural movement patterns of wood bison in Wood Buffalo National Park; 4 Joly, D.O Brucellosis and tuberculosis as factors limiting population growth of northern bison. Ph.D. Thesis. Department of Biology, University of Saskatchewan, Saskatoon, Saskatchewan. October 2014 ESRD/CEAA Page 409

412 ESRD and CEAA Responses Approvals Frontier Oil Sands Mine Project iii. An evaluation of the carrying capacity of the remaining Ronald Lake herd range (i.e., outside disturbance areas) and the ability of this range to support the full Ronald Lake wood bison herd; iv. A summary of Aboriginal traditional knowledge (from existing and ongoing studies) on Ronald Lake bison movement patterns, distribution, and sensitivity to disturbance; and v. An evaluation of potential increased non-aboriginal harvest pressure on lands north of the Project area during construction and operations and potential effects of this harvest on herd movement, distribution and habitat use. b. Provide a summary of specific scientific studies Teck has conducted, including results, to identify the impacts of its winter exploration activities on movement, distribution and habitat use of the Ronald Lake wood bison herd, and how this information has been used to help evaluate impacts of mine development on herd movement and distribution. c. Provide a summary of ongoing studies on the Ronald Lake wood bison herd, the purpose and timing of these studies, study leads, and gaps in data collection (including gaps identified by Aboriginal groups) that are required to understand the distribution, abundance, trend, habitat use, movements, impacts to traditional use, and response to resource developments by the Ronald Lake wood bison herd. Identify how and when this information will be incorporated into the environmental assessment. Identify a schedule of studies that Teck will implement to fill data gaps. d. Re-evaluate, using the information above, and provide a summary of the potential movement and distribution of Ronald Lake wood bison following disturbance caused by Project construction and operations, as well as cumulative disturbances from other Projects, and whether the herd is likely to remain within its current home range. Identify any uncertainties in the analysis based on baseline data deficiencies. In developing this response, Teck should use a precautionary approach that assumes that Ronald Lake bison are not habituated to human presence, given the remote location and hunting of this herd, and are thus likely sensitive to human disturbance. Response 85 MCFN and ACFN have expressed concerns about the degree and manner with which their traditional knowledge and Aboriginal perspectives have been considered and incorporated by Teck, particularly in the assessment of impacts to Aboriginal rights and culture. To this end, Teck acknowledges the need for further engagement with MCFN and ACFN regarding bison, potential effects of the Project on bison, and development of the mitigation and monitoring plan for the Ronald Lake bison herd. Teck will revisit conclusions made in response to this SIR once the parties have pursued the collaborative processes that Teck, MCFN and ACFN are working to develop and as additional information is gathered. ESRD/CEAA Page 410 October 2014

413 Frontier Oil Sands Mine Project ESRD and CEAA Responses Approvals In the interim, Teck has provided currently information that is based on western science and that is relevant to each of these issues. Teck expects that this information will be reviewed in more detail with potentially affected Aboriginal communities, and that additional information provided by Aboriginal communities will be integrated into the bison-specific mitigation and monitoring plan that will be developed for the Project. a. i. In general, industrial development affects wildlife by increasing human and predator access, altering habitat suitability and increasing sensory disturbance. For bison specifically, disturbance related to Project construction and operations may reduce the amount of suitable habitat, increase risk of mortality from hunting and predation associated with improved access, and alter use of their historic range by displacing individuals or disrupting movement patterns. Teck plans to develop a bison-specific mitigation and monitoring plan that will be informed by research completed by the Ronald Lake Bison Herd Technical Studies Team as well as additional information provided by Aboriginal communities. In terms of their movement patterns, bison will typically travel between favoured foraging habitat patches along the most direct and practical route and rapidly establish trails in these areas using linear disturbances (i.e., roads, cutlines) as well as established bison trails (Gates et al. 2001; Bjornlie and Garrott 2001; Borkowski et al. 2006). Creation of linear features, including those created and used by bison for movement, can also increase human access into bison range. However, bison response to human activity will vary depending on a variety of conditions. For instance, bison have been observed to respond less often to people on trail than to people off-trail (Hardy 2001), and were as likely to flee from a person on foot as on a snowmobile (Fuller 1960; Fortin and Andruskiw 2003). Bison have also exhibited different responses to vehicle type, regardless of season. For example, bison stress levels were recorded to be higher in response to wheeled vehicles than to snowmobiles (Hardy 2001; Fortin and Andruskiw 2003). Research in Prince Albert National Park by Fortin and Andruskiw (2003) noted that radio-collared female bison moved greater distances on days they were disturbed compared to days that they were not disturbed. In addition, they found that large herds, which usually had young, were more likely to flee from a disturbance, regardless of the type of disturbance (i.e., snowmobile versus hiker), when compared to smaller herds (i.e., generally without young). Similar responses have been recorded in bison herds in Yellowstone National Park (YNP). During these studies, bison exhibited behavioural responses to snowmobiles and associated human activities that included increased vigilance (i.e., look and respond, alert and attention), travel (i.e., walking away) and occasionally flight or defense (Borkowski et al. 2006). The likelihood and intensity of responses by bison increased significantly if animals were on or near roads (mainly winter roads), groups were smaller, or animals were approached by humans or their movements were impeded or hastened by vehicles (Bjornlie and Garrott 2001; Borkowski et al. 2006). October 2014 ESRD/CEAA Page 411

414 ESRD and CEAA Responses Approvals Frontier Oil Sands Mine Project There is currently no evidence that the frequency of sensory disturbance imposed on bison by snowmobiles, trucks, or foot traffic has had important long-term effects on bison abundance or habitat use in Prince Albert National Park, Saskatchewan and YNP (Hardy 2001; Fortin and Andruskiw 2003; White et al. 2005; Borkowski et al. 2006). Results of the studies in Prince Albert National Park and YNP appear to align with the studies Teck is currently undertaking. Although data are still preliminary, results from remote camera studies completed during the winter drilling program and sightings of bison reported as part of Teck s wildlife sighting card collection, indicate that bison remained near the areas in which drilling activity was occurring (see the response to part b for additional details). Teck understands that MCFN has concerns regarding the reliability of remote camera studies. Teck expects to discuss these concerns in greater detail through the collaborative process previously noted. ii. The following is a summary of research on bison movement in WBNP. Distance, terrain and habitat features influence bison movements, including long-range movements of dispersing animals and localized foraging movement (Mitchell et al. 2000; Bruggeman et al. 2007). Bison have a high affinity for grass and sedge meadows and avoid travelling through muskeg, dense forest and steep terrain (Reynolds et al. 1978; Carbyn et al. 1993; Gates et al. 2001). Bison typically travel between favoured foraging habitat patches along the most direct and practical route and rapidly establish trails in these areas using linear disturbances (i.e., roads, cutlines) and bison trails (Gates et al. 2001). Bison will also use roadways, but only when they are aligned with natural corridors between favoured habitat patches (Bjornlie and Garrott 2001; Gates et al. 2001). Tessaro et al. (1990) identified areas in which bison moved across the boundary of WBNP into adjacent lands south of the Peace River in the southwest quadrant of the park. Bison were also reported in the Yates River area near the Alberta Northwest Territories border, west of WBNP. The Yates is a meandering river that may have suitable habitat and can be readily crossed by bison (Gates et al. 2001). Several long distance movements were also observed during a telemetry study in WBNP conducted in the early 1990s (Wood Buffalo National Park 1995) and during movement studies later (Gates et al. 2001). Eighty-eight percent of bison groups observed more than 10 km outside known herd ranges were male. iii. Wood bison prefer to forage in all seasons in graminoid-dominated wetlands, meadows, grasslands, and open shrublands with graminoid ground vegetation (Reynolds et al. 1978; Larter and Gates 1991; Gates et al. 2001; Jensen et al. 2004). In winter, wood bison rely almost exclusively on graminoids, particularly sedges, which retain more digestible nutrients than other forage types (Reynolds et al. 1978; Larter and Gates 1991; Strong and Gates 2009) and which they can readily access (Strong and Gates 2009). Clearcuts provide adequate forage for wood bison during the summer, but owing to low graminoid biomass they are not suitable as winter habitat (Hudson and Frank 1987; Redburn et al. 2008). The almost exclusive dependence on graminoid species and their respective habitats makes winter forage quality and availability a critical limiting ESRD/CEAA Page 412 October 2014

415 Frontier Oil Sands Mine Project ESRD and CEAA Responses Approvals factor for wood bison (Fuller 1960). This is therefore the primary criterion for assessing effects to bison (see Volume 6, Appendix 4A) and in determining the potential carrying capacity of the Ronald Lake bison herd. Wet sedge meadows are important bison habitat in WBNP. Assuming this is the same for the Ronald Lake bison herd, there is 13,681 ha of high-suitability winter habitat within the 156,060 ha Ronald Lake bison herd study area under existing conditions (see the response to ESRD/CEAA Round 2 SIR 136, Appendix 136a.4). A rudimentary estimate of carrying capacity can be derived based on annual aboveground estimates of forage biomass in various Alberta studies (see Table 85a-1). To be conservative, carrying capacity was estimated for the Ronald Lake bison herd using one of the lower biomass estimates reported for high biomass-producing graminoid and sedge species (1,975 kg) (see Table 85a-1). Even using the lowest forage biomass estimate from data for northcentral Alberta (1,975 kg/ha from WBNP; Strong and Gates 2009) translates into 27,019,975 kg of forage production (i.e., annual aboveground biomass x 13,681 ha of high-suitability habitat) (see Table 85a-2). Because bison usually graze only on the top third of wet-meadow vegetation (Reynolds et al. 1978; Hamilton 2005), approximately 8,997,352 kg of forage would be available. Dividing available production by the annual requirement of 3,796 kg dry matter per animal (10.4 kg/day) (Hamilton 2005; Kuzyk et al. 2009) suggests that approximately 2,370 individuals (i.e., 0.02 bison/ha or 1.52 bison/km 2 ) could be supported by the wet sedge meadows in the Ronald Lake bison study area (see Table 85a-2 for comparisons between different areas in Alberta). However, actual carrying capacity may be less, depending on areas inaccessible because of snow or ice cover. Despite this, based on habitat availability for the Ronald Lake bison herd study area (see the response to ESRD/CEAA Round 2 SIR 136, Appendix 136a.4), the present winter carrying capacity most likely surpasses the requirements of the existing bison population by an order of magnitude (i.e., estimated density of bison/ha or 0.12 bison/km 2 ) when calculated from the minimum population estimate of 186 animals (GOA 2013a). Abundant areas of open wetlands also exist outside the defined bison study area. These areas have high potential to support high-biomass graminoid and sedge species (see Appendix 85a.1). Following the carrying capacity data presented above for the Ronald Lake bison study area, there is ample biomass to support a larger herd (see Table 85a-2) than is known to presently occur (i.e., 186 individuals). In addition, the remaining area of graminoid wetlands for the PDC has the carrying capacity to support a bison herd that has been speculated to represent numbers of a selfsustaining, viable herd (i.e., assuming a viable subpopulation of bison requires 400 individuals [0.003 bison/ha or 0.26 bison/ km 2 ]; Gates et al. 2001). For example, at PDC for the revised Project, there are 9,579 ha of high suitability habitat in the Ronald Lake bison herd study area. This suggests that approximately 1,645 individuals (i.e., 0.01 bison/ha or 1.05 bison/km 2 ) could be supported by the wet sedge meadows in the Ronald Lake bison study area. October 2014 ESRD/CEAA Page 413

416 ESRD and CEAA Responses Approvals Frontier Oil Sands Mine Project Table 85a-1 Common Open Wetland Sedges and Graminoids Species Tall, high biomass producing, temporary to shallow marsh species and fen species Maximum Height (m) Biomass Average (and Range) (kg/ha) Available Nutrients Calamagrostis inexpansa A. Gray (northern reedgrass) ,575 (3,927 to 5,987) 6 Moderate 2 Low 2 Carex aquatilis Wahlenb. (water sedge) to ,834 (1,630 to 3,345) 6 Low 9 to Moderate 2 None 1,4 Salinity Tolerance Carex atherodes Spreng. (awned sedge) to 1.5 2,4 4,686 (3,510 to 6,043) 6 Moderate 2 None 2,4 to Moderate 12 Carex rostrata Stokes (beaked sedge) to ,564 (900 to 8,230) 7 Low 9 to Moderate 2 None 3 to Low 2,4 Carex utriculata Boott (small bottle sedge) 1.0 3,4 (1,975 to 4,575) 6 Low 9 to Moderate 2 Low 2,4 Scolochloa festucacea (Willd.) Link (spangletop) (1,975 to 4,575) 6 Moderate 2 None 1,4 to Moderate 12 Tall, high biomass producing, deep marsh species Typha latifolia L. (common cattail) ,457 (460 to 15,270) 7 Moderate 2 Low 2,4 Tall, moderate biomass, temporary to shallow marsh species and fen species Calamagrostis canadensis (Michx.) Beauv. (bluejoint) ,967 (10 to 8,070) 7 Moderate 2 None 2,4 to Low 12 Carex lasiocarpa Ehrh. (hairy-fruited sedge) to (13 to 477) 8 Low 9 to Moderate 11 Low 10,12 Short, low to moderate biomass fen species Carex chordorrhiza Ehrh. ex L. f. (prostrate sedge) 0.3 1,5 to ,330 7 Low 2 None 9 to Low 4 Carex diandra Schrank (two-stamened sedge) (500) 6 Low 1 None 2 Carex limosa L. (mud sedge) to Low 2 None 2 SOURCES: 1 Moss 1983; 2 USDA NRCS 2014; 3 Flora of North America 2003; 4 Alberta Environment 2007; 5 Johnson et al. 1995; 6 Strong and Gates 2009; 7 Campbell et al. 2000; 8 Luan et al. 2013; 9 Jacques Whitford AXYS 2007; 10 Gignac et al. 2004; 11 McClintock and Waterway1994; 12 Purdy et al ESRD/CEAA Page 414 October 2014

417 Frontier Oil Sands Mine Project ESRD and CEAA Responses Approvals Table 85a-2 Estimated Forage Biomass and Carrying Capacity Units PAD WBNP 1 Ministik, AB 2 Elk Island NP 3 North-Central Alberta 4 Sedge/grassland biomass kg/ha 5,247 5,602 6,053 1,975 Available forage (biomass x 13,681 ha) kg 71,784,207 76,640,962 82,811,093 27,019,975 Forage available for grazing (1/3 * available forage) Carrying capacity = grazing forage available/bison annual requirement (10.4 kg/day x 365 days) kg 23,904,141 25,521,440 27,576,094 8,997,652 number of individuals 6,297 6,723 7,265 2,370 Density of bison (carry capacity / 156,060 ha) bison/ha NOTES: PAD = Peace-Athabasca Delta. WBNP = Wood Buffalo National Park. SOURCES: 1 Hamilton (2005); 2 Hudson and Frank (1987); 3 Kuzyk et al. (2009); 4 Strong and Gates (2009). bison/km October 2014 ESRD/CEAA Page 415

418 ESRD and CEAA Responses Approvals Frontier Oil Sands Mine Project These estimates of carrying capacity show that there is potential for an order-of-magnitude increase in the number of individuals in the Ronald Lake bison herd study area relative to the current minimum known population size and additional habitat is available to the north in WBNP. These estimates, however, assume that herd size is based entirely on the amount of limiting winter suitable habitat. Overall, estimates of food-limited carrying capacity for large herbivores require information on fundamental ecological processes and linkages between: forage production and use habitat qualities and nutrition nutritional status and demographic responses of populations In this capacity, bison have been relatively well studied in the western U.S. and northern Canada (e.g., Reynolds et al. 1978; Larter and Gates 1991; Gates et al. 2001; Hamilton 2005; Kuzyk et al. 2009; Plumb et al. 2009; Strong and Gates 2009). Compared to bison in WBNP and YNP, the Ronald Lake bison herd is relatively understudied, and further information on population demographics, range size, and habitat data is still needed to provide an accurate estimate of carrying capacity. However, current studies led by ESRD, as well as independent studies being led by Teck, are contributing to a better understanding of the carrying capacity of the Ronald Lake bison herd (see the response to parts b and c). iv. MCFN has told Teck that it has concerns with the degree and manner with which MCFN s traditional knowledge and Aboriginal perspectives have been considered and incorporated by Teck, particularly in the assessment of impacts to MCFN s rights and culture. This response does not incorporate traditional knowledge. To this end, Teck acknowledges the need for further engagement regarding this SIR. Teck will revisit this SIR and conclusions contained in it once the parties have pursued the collaborative process that Teck and MCFN are working to develop and as additional information is gathered. ACFN has clearly stated that it has concerns with the degree and manner with which ACFN s traditional knowledge and Aboriginal perspectives have been considered and incorporated by Teck, particularly in the assessment of impacts to ACFN s rights and culture. Recognizing that additional work needs to be done, Teck has requested to meet with ACFN to co-create a process to address outstanding concerns, to revisit certain conclusions made by Teck in the Integrated Application, and to work toward understanding and incorporating ACFN s traditional land use and traditional knowledge into the assessment in a meaningful way. Teck will update regulators on a regular basis about the progress of these discussions. Teck will not be filing responses to Round 3 SIRs that pertain to traditional knowledge or the assessment of impacts to ACFN s rights and culture with regulators until the parties have pursued the collaborative process referred to above, or until Teck and ACFN agree otherwise. ESRD/CEAA Page 416 October 2014

419 Frontier Oil Sands Mine Project ESRD and CEAA Responses Approvals With respect to ESRD-led work, Teck is hopeful that the Technical Working Group will become the primary vehicle for integrating Aboriginal communities concerns and traditional knowledge into future planning for the Ronald Lake bison herd and providing a means to undertake scientific studies and set research priorities in a collaborative, cooperative manner. MCFN has told Teck and ESRD that it has a number of serious concerns about this technical team and asked Teck to present these concerns in this response. MCFN concerns include: exclusion from designing and carrying out these studies the role of indigenous knowledge in the work of the technical team a lack of transparency with the team other concerns relating to the draft terms of reference Teck understands that the draft terms of reference do not incorporate assessment of impacts to MCFN s rights. MCFN has also raised concerns about Alberta s unwillingness to provide bison data to MCFN. Teck has also committed capacity funding for MCFN to undertake several additional studies to address MCFN concerns with information gaps related to the assessment, including two related to bison: an MCFN-led documentary that documents a traditional bison hunt a species-specific MCFN indigenous knowledge and use report on bison for the Frontier Project. The objective of this study is to produce a species-specific indigenous knowledge report that considers the Frontier Project. MCFN and Teck expect the outcomes of the report to inform discussion between MCFN, Teck and regulators regarding bison. These studies are expected to be completed in v. See the response to ESRD/CEAA Round 3 SIR 81 for a discussion about a potential increase in non-aboriginal harvest pressure on the Ronald Lake bison herd. b. Teck continues to support research efforts on the Ronald Lake bison herd, including studies based on western-science approaches and studies based on traditional knowledge. Teck is currently gathering on-site data using wildlife sightings cards and remote cameras to understand whether individuals from the Ronald Lake bison herd were displaced by drilling activities. Results and observations from these studies are summarized below. During the winter program, Project employees submitted 217 wildlife records, including 21 bison observations (see the response to ESRD/CEAA Round 3 SIR 61, Appendix 61a.1). The following year, more than twice as many wildlife records (523) were submitted as part of the winter program; however, this increase may not have been related to an increase in wildlife use, but rather an increased awareness by on-site staff. These records included 17 sightings of bison; each sighting ranged from a single bison to groups of five bison, for a total of 36 bison October 2014 ESRD/CEAA Page 417

420 ESRD and CEAA Responses Approvals Frontier Oil Sands Mine Project observations (see the response to ESRD/CEAA Round 3 SIR 61, Appendix 61a.1). Of the 36 bison observed, only two were observed to be running. Teck acknowledges that incidental wildlife sightings provide limited information; however, these sightings confirm the continued presence of bison in the area during the period that the drilling program was active and that the majority of observed animals were not startled by the presence of machinery or human observers. The remote camera monitoring, which occurred from October 2013 to October 2014, was based on a before-after-control-impact (BACI) sampling design, with 20 cameras in the PDA and 20 in a control setting (Golder 2014). The 20 control cameras were placed north of the PDA, in relatively undisturbed habitat. Interim results showed bison at 10 control cameras and nine impact cameras, with bison recorded at 16 of the 19 cameras (10 control; 6 impact) occurring in undisturbed sites (see the response to ESRD/CEAA Round 3 SIR 61, Appendix 61a.2). As with the sighting cards, impact cameras recorded bison during the drilling program, which confirms that bison remained present in the area during drilling. Teck has investigated the extent of limiting winter habitat for an expanded area that includes the southern part of WBNP (see Appendix 85a.1). This study is being completed to better understand winter habitat availability outside the area currently identified as the Ronald Lake bison herd range that has been defined based on known information (i.e., the range defined in response to ESRD/CEAA Round 1 SIR 219c, Appendix 219c.1 and the minimum convex polygon defined by GOA [2013a]). As described in the response to ESRD/CEAA Round 3 SIR 61, Teck is currently contributing financial, technical and in-kind support ESRD s study of the Ronald Lake bison herd. This ongoing, multi-year study represents the first scientific study to collect data specifically on the Ronald Lake bison herd. The study includes aerial surveys, sample collection for disease and genetic testing, and bison collaring with GPS telemetry collars. Data from the collars will help to establish the Ronald Lake bison herd range and develop a resource-selection-function habitat suitability model. Funding provided by Teck supports work planned and conducted by ESRD from November 1, 2013 to March 31, Teck is currently in communication with ESRD to determine when data from the research program will be made available. Once available, the results of Teck s research and the ESRD-led research will be used to inform Project-specific mitigation and monitoring programs for the Ronald Lake bison herd. c. In Managing Disease Risk in Alberta s Wood Bison with Special Focus on Bison to the West of Wood Buffalo National Park: Progress Report, GOA (2012) makes a recommendation to: include the Ronald Lake bison herd... as part of the [provincial] disease management program. This would include bringing local stakeholders and aboriginal groups up-to-date on the disease management program, establishing good estimates for herd size and distribution, and determining the herd s disease status. ESRD/CEAA Page 418 October 2014

421 Frontier Oil Sands Mine Project ESRD and CEAA Responses Approvals GOA (2013b) acknowledges that existing data gaps must be addressed to effectively determine whether the Ronald Lake bison herd should be managed differently from the current provincial approach. As part of its research, ESRD will: acquire samples from the Ronald Lake bison herd for disease and genetic testing collar additional bison with GPS telemetry transmitters collect bison location data convene a small technical committee that includes representatives from industry, local Aboriginal communities and third-party experts. The committee s objective will be to analyze bison telemetry data to investigate bison habitat use and the effects of industrial development on bison use of their range. Coinciding with this, ESRD is currently leading a long-term study on the Ronald Lake bison herd for which Teck is providing financial, technical and in-kind support. This ongoing, multi-year study aims to collect data related to gaps in knowledge about the Ronald Lake bison herd. The study includes aerial surveys, sample collection for disease and genetic testing, and bison collaring with GPS telemetry collars. Data from the collars will help establish the Ronald Lake bison herd range and develop a resource-selection-function habitat suitability model. Information from this study will also be used in determining Project-specific mitigation that will be part of the wildlife mitigation and monitoring plan. Funding provided by Teck supports work planned and conducted by ESRD from November 1, 2013 to March 31, As identified in the response to part a-iv, MCFN has a number of concerns regarding the technical team. The winter program (GOA 2013a) focused on addressing knowledge gaps about the Ronald Lake bison herd (e.g., herd range and seasonal habitat use by bulls and cows). Traditional knowledge provided by ACFN (Candler et al. 2013a) and MCFN (Candler et al. 2013b) suggest that these bison have been there a long time and are not likely migrants from WBNP. Instead, they are possibly a long-established population that is genetically distinct and disease-free (ASRD 2010; GOA 2013a). Scouting flights conducted in December 2012 and March 2013 observed a total of 167 and 186 bison (GOA 2013a). These observations represent an increase from the previous estimate of 101 bison in 2010 (ASRD 2010). Population estimates will be updated following a mark and resight aerial survey, which is planned for the field season. A total of 24 bison were tested for bovine tuberculosis and brucellosis (GOA 2013a). Tissue and blood samples were collected from 11 individuals, and blood samples were collected from the 12 bison immobilized for collar deployment. One additional blood sample was submitted by a hunter from a harvested bison (GOA 2013a). Results (n=24) suggest that disease prevalence for the Ronald Lake bison herd ranges from 0% to 25% for tuberculosis and 0% to 12% for brucellosis, which are both less than the disease prevalence observed for bison in WBNP (GOA 2013a). An additional 49 animals are planned to be tested for disease during the 2014 field season. To date, all October 2014 ESRD/CEAA Page 419

422 ESRD and CEAA Responses Approvals Frontier Oil Sands Mine Project samples submitted have tested negative for disease. During a recent meeting of the Ronald Lake Bison Herd Technical Studies Team (June 13, 2014), it was discussed that the results of the 2014 testing also came up negative and that the newly calculated disease prevalence was less than 5% (Skilnick 2014, pers. comm.). Genetic testing of the Ronald Lake bison herd indicates the herd is genetically similar to bison in WBNP although the level of differentiation is strong, suggesting genetic exchange is negligible (Ball 2013). Genetic testing further suggests that the Ronald Lake Bison herd is not currently composed of genetically pure wood bison or pure plains bison; instead, results suggest that the herd shares a genetic association with both sub-species (Ball 2013). In March 2013, 12 bison cows were collared with satellite collars programmed to record their location every 90 minutes for approximately two years (GOA 2013a). Only six of the 12 collars were functional through the first year of the study. A minimum convex polygon of the herd s range has been calculated using bison locations observed during scouting flights and from location data downloaded from the deployed collars (GOA 2013a). Preliminary data collected from the collaring effort (based on 13 months of data collection) show that members of the Ronald Lake bison herd are travelling at least 10 km into WBNP. ESRD is currently analyzing collar data, and an update and new map are expected to be available in the future. Additional bison collaring is planned for the 2014 field season, and data collection will continue until approximately March Although early results indicate that members of the Ronald Lake bison herd enter WBNP (GOA 2013; Skilnick 2014, pers. comm.), there is no previous westernscience-based data to confirm whether WBNP is part of the herd s traditional range, a range expansion or a shift resulting from some other factor. The goals and objectives of data collection and subsequent research related to the Ronald Lake bison herd will be led by the Ronald Lake Bison Herd Technical Studies Team. Members of the team, as well as the team s terms of reference, are still to be determined. It is anticipated that the terms of reference will outline the structure, membership and mandate of the group. In February 2014, the Government of Alberta (via ESRD) held a meeting to discuss interest and options for expanding participation and input in directed studies of the Ronald Lake bison herd. The meeting also focused on establishing guiding principles for the Ronald Lake Bison Herd Technical Studies Team. The meeting included participation by: members of ACFN, MCFN, Métis Local 1935, Fort McKay the University of Alberta the Royal Alberta Museum Parks Canada and Environment Canada industry representatives from Teck, Shell and SilverWillow ESRD/CEAA Page 420 October 2014

423 Frontier Oil Sands Mine Project ESRD and CEAA Responses Approvals A follow-up meeting of the technical committee was held in June 2014 to discuss the future of the team and research progress to date. Minutes from the February meeting are provided in response to ESRD/CEAA Round 3 SIR 81, Appendix 81c.1. Minutes from the June meeting were not available at the time this response was drafted. As part of its ongoing efforts to understand the distribution, abundance and habitat use of the Ronald Lake bison herd, Teck will continue its directed studies /information gathering in the PDA and areas surrounding the lease (e.g., remote camera studies, wildlife sighting cards, mapping of bison habitat) and will continue to support the ESRD Ronald Lake Bison Herd Technical Studies Team. d. Long-term monitoring and study of the Ronald Lake bison herd is needed to fill in gaps in current data collection, with a goal for an understanding of how the herd responds to activities on the landscape and to harvest pressures. For example, a detailed habitat analysis of current herd range, and areas to the north, is required to better understand habitat availability. Collaring of both sexes will be used to better understand habitat preference, seasonal use and the development of a resource selection function habitat suitability model. Population surveys are needed to quantify calf-to-cow ratios, which are used as an index to herd productivity, and could be applied to help calculate rate of herd increase, mortality rates, herd age structure, herd health, nutritional level and range. As discussed in the responses to ESRD/CEAA Round 2 SIR 104 and SIR 188, Teck plans to review the conclusions and recommendations of the ESRD-led research, and once finalized, will use the data to inform the design of future studies and mitigation. MCFN has told Teck that it has concerns with the degree and manner with which MCFN s traditional knowledge and Aboriginal perspectives have been considered and incorporated by Teck, particularly in the assessment of impacts to MCFN s rights and culture. This response does not incorporate traditional knowledge. To this end, Teck acknowledges the need for further engagement regarding this SIR. Teck will revisit this SIR and conclusions contained in it once the parties have pursued the collaborative process that Teck and MCFN are working to develop and as additional information is gathered. ACFN has clearly stated that it has concerns with the degree and manner with which ACFN s traditional knowledge and Aboriginal perspectives have been considered and incorporated by Teck, particularly in the assessment of impacts to ACFN s rights and culture. Recognizing that additional work needs to be done, Teck has requested to meet with ACFN to co-create a process to address outstanding concerns, to revisit certain conclusions made by Teck in the, and to work toward understanding and incorporating ACFN s traditional land use and traditional knowledge into the assessment in a meaningful way. Teck will update regulators on a regular basis about the progress of these discussions. Teck will not be filing responses to Round 3 SIRs that pertain to traditional knowledge or the assessment of impacts to ACFN s rights and culture with regulators until the parties have pursued the collaborative process referred to above, or until Teck and ACFN agree otherwise. October 2014 ESRD/CEAA Page 421

424 ESRD and CEAA Responses Approvals Frontier Oil Sands Mine Project REFERENCES Alberta Environment Guideline for Wetland Establishment on Reclaimed Oil Sands Leases. Revised (2007) Edition. Edmonton, Alberta. December ASRD (Alberta Sustainable Resource Development) Ronald Lake Bison (Bison bison) Survey February Alberta Sustainable Resource Development, Fort McMurray, Alberta. November Ball, M.C Characterizing the Genetic Population Structure of Wild Bison in Alberta, Canada. Alberta Environment and Sustainable Resource Development. October Bjornlie, D.D. and R.A. Garrott Ecological effects of winter road grooming on bison in Yellowstone National Park. Journal of Wildlife Management 65: Borkowski, J.J., P.J. White, R.A. Garrott, T. Davis, A.M. Hardy and D.J. Reinhart Behavioral responses of bison and elk in Yellowstone to snowmobiles and snow coaches. Ecological Applications 16: Bruggeman, J.E., R.A. Garrott, P.J. White, F.G.R. Watson and R. Wallen Covariates affecting spatial variability in bison travel behavior in Yellowstone National Park. Ecological Applications 17: Campbell, C., D.H. Vitt, L.A. Halsey, I.D. Campbell, M.N. Thormann and S.E. Bayley Net Primary Production and Standing Biomass in Northern Continental Wetlands. Canadian Forest Service, Northern Forestry Centre, Information Report NOR-X-369. Candler, C., R. Olson and the Firelight Group Research Cooperative, with the Mikisew Chipewyan First Nation. 2013a. Mikisew Cree First Nation Indigenous Knowledge and Use Report and Assessment for Teck Resources Limited s Proposed Frontier Oil Sands Mine Project. Candler, C. and the Firelight Group Research Cooperative, with the Athabasca Chipewyan First Nation. 2013b. Athabasca Chipewyan First Nation Knowledge and Use Report and Assessment for Teck Resources Limited s Proposed Frontier Oil Sands Mine Project. Carbyn, L.N., S.M. Oosenbrug and D.W. Anions Wolves, Bison and the Dynamics Related to the Peace-Athabasca Delta in Canada's Wood Buffalo National Park. Circumpolar Research Series Number 4, Canadian Circumpolar Institute, University of Alberta, Edmonton, Alberta. Flora of North America Magnoliophyta: Commelinidea (in part) Cyperaceae (Volume 23). Available at: Accessed June Fortin, D. and M. Andruskiw Behavioral response of free-ranging bison to human disturbance. Wildlife Society Bulletin 31: Fuller, W.A Behaviour and social organization of wild bison of Wood Buffalo National Park, Canada. Arctic 13: ESRD/CEAA Page 422 October 2014

425 Frontier Oil Sands Mine Project ESRD and CEAA Responses Approvals Gates, C.C., J. Mitchell, J. Wierzchowski and L. Giles A landscape evaluation of bison movements and distribution in northern Canada. Prepared for the Canadian Bison Association, Parks Canada and GNWT Dept. of Resources, Wildlife and Economic Development. Gignac, L. D., R. Gauthier, L. Rochefort and J. Bubier Distribution and habitat niches of 37 peatland Cyperaceae species across a broad geographic range in Canada. Canadian Journal of Botany 82: Golder (Golder Associates Ltd.) Teck Frontier Wood Bison Camera Monitoring Interim Report. Prepared for Teck Resources and Shell Canada Limited. GOA (Government of Alberta) Managing Disease Risk in Alberta s Wood Bison with Special Focus on Bison to the West of Wood Buffalo National Park: Progress Report. Government of Alberta, Edmonton, Alberta. August GOA. 2013a. Ronald Lake Bison (Bison bison) Winter Activities Progress Report. Government of Alberta, Edmonton Alberta. GOA. 2013b. Managing Disease Risk in Northern Alberta Wood Bison Outside of Wood Buffalo National Park Progress Report. June Hamilton, S.G Estimating Winter Carrying Capacity for Bison in Wood Buffalo National Park. M.Sc. thesis, University of Alberta, Edmonton, Alberta. Hardy, A.R Bison and Elk Responses to Winter Recreation in Yellowstone National Park. M.Sc. thesis, Montana St. University, Bozeman, Montana. Hudson, R.J. and S. Frank Foraging ecology of bison in aspen boreal habitats. Journal of Range Management 40: Jacques Whitford AXYS An Analysis of Existing Information on Peatland Vegetation in the Regional Municipality of Wood Buffalo. Prepared for the Wetlands and Aquatics Subgroup, Reclamation Working Group, Cumulative Environmental Management Association. Fort McMurray, Alberta. Jensen, O.C., J. Nishi, N.L. Cool, D. Poll and H.W. Reynolds Assessing suitable and critical habitat for wood bison (Bison bison athabascae) using Geographic Information Systems (GIS) and remote sensing: preliminary results. In T.D. Hooper [ed.]. Proceedings of the Species at Risk 2004 Pathways to Recovery Conference, March 2 6, 2004, Victoria, B.C. Species at Risk 2004 Pathways to Recovery Conference Organizing Committee, Victoria, British Columbia Johnson, J.D., L.J. Kershaw, A. MacKinnon and J. Pojar Plants of the western boreal forest and aspen parkland. Lone Pine Publishing, Edmonton, Alberta. Joly, D.O Brucellosis and Tuberculosis as Factors Limiting Population Growth of Northern Bison. Ph.D. Thesis. Department of Biology, University of Saskatchewan, Saskatoon, Saskatchewan. October 2014 ESRD/CEAA Page 423

426 ESRD and CEAA Responses Approvals Frontier Oil Sands Mine Project Kuzyk, G.L., N.L. Cool, E.W. Bork, C. Bampfylde, A. Franke and R.J. Hudson Estimating economic carrying capacity for an ungulate guild in western Canada. The Open Conservation Biology Journal 3: Larter, N.C. and C.C. Gates Diet and habitat selection of wood bison in relation to seasonal changes in forage quantity and quality. Canadian Journal of Zoology 69: Luan, Z., Z. Wang, D. Yan, G. Liu and Y. Xu The ecological response of Carex lasiocarpa communities in the riparian wetlands to the environmental gradient of water depth in Sanjiang Plain, northeast China. The Scientific World Journal 2013: 1 7. McClintock, K. A. and M. J. Waterway Genetic differentiation between Carex lasiocarpa and C. pellita (Cyperaceae) in North America. American Journal of Botany 81: Mitchell, J.A., C.C. Gates, R. Rowell and K. Lloyd A decision-support tool for managing the risk of tuberculosis and brucellosis infection in northern Canada. pp In L.M. Darling [ed.] Proceedings of a Conference on the Biology and Management of Species and Habitats at Risk, Kamloops, B.C., February 15 to 19, Volume One. B.C. Ministry of Environment, Lands and Parks, Victoria, B.C. and University College of the Cariboo, Kamloops, British Columbia. Moss, E.H Flora of Alberta. 2nd Edition. University of Toronto Press, Toronto, Ontario. Plumb, G. E., P.J Whilte, M.B. Coughenour and R.L. Wallen Carrying capacity, migration, and dispersal in Yellowstone bison. Biological Conservation 142: Purdy, B., S.E. Macdonald and V.J. Lieffers Naturally saline boreal communities as models for reclamation of saline oil sands tailings. Restoration Ecology 13: Redburn, M.J., W.L. Strong and C.C. Gates Suitability of boreal mixedwood clearcuts as wood bison (Bison bison athabascae) foraging habitat in north-central Alberta, Canada. Forest Ecology and Management 255: Reynolds, H.W., R.M. Hansen and D.G. Peden Diets of the Slave River Lowlands bison herd, Northwest Territories, Canada. Journal of Wildlife Management 42: Skilnick, J Preliminary Activities Presented to the Ronald Lake Bison Herd Technical Studies Team. Senior Wildlife Biologist, Alberta Environment and Sustainable Resource Development. Fort McMurray, Alberta. Strong, W.L. and C.C. Gates Wood bison population recovery and forage availability in northwestern Canada. Journal of Environmental Management 90: Tessaro, S.V., L.B. Forbes and C. Turcotte A survey of brucellosis and tuberculosis in bison in and around Wood Buffalo National Park, Canada. Canadian Veterinary Journal 31: USDA NRCS (United States Department of Agriculture, Natural Resource Conservation Service) The PLANTS Database. Available at Accessed June ESRD/CEAA Page 424 October 2014

427 Frontier Oil Sands Mine Project ESRD and CEAA Responses Approvals White, P.J., T. Davis, J. Borkowski, D. Reinhart, C. McClure and P. Perotti Wildlife Responses to Motorized Winter Recreation in Yellowstone Annual Report. National Park Service, Resource Management and Visitor Protection. Wood Buffalo National Park Bison Movement and Distribution Study. Final Report. Technical Report 94-08WB. Parks Canada, Fort Smith, Northwest Territories. Question 86 Volume 1, ESRD/CEAA SIR 154, Page 449 In SIR response #154, Teck states that it recognizes that Aboriginal communities are concerned about increased access by non-aboriginal hunters; however, Teck will be legally obligated to provide access to both Aboriginal and non-aboriginal land users. Increased access by non- Aboriginal hunters to wood bison habitat north of the Project development area poses a risk to the Ronald Lake bison herd, given that hunting of this herd is not regulated. This risk, and measures to mitigate this risk, has not been fully evaluated by Teck. a. Describe measures Teck can use to effectively mitigate the risk of increased access of non- Aboriginal hunters to land north of the PAA to prevent additional harvest of the Ronald Lake bison herd. Response 86 a. Given the current provincial management regime for the Ronald Lake bison herd, Teck is in a position to apply control measures only for its workers and by restricting access through the Project area and the use of Teck built roads. Workers will be prevented from hunting or using firearms (see Volume 8, Section , Page 4-37). As stated in the response to ESRD/CEAA Round 3 SIR 75, Aboriginal and non-aboriginal individuals wanting to access lands north of the Project will have to notify Teck and the security office before crossing the Project area. All individuals will be required to check in at the security office and will be escorted across the active part of the Project area by security staff. Teck expects that these measures will reduce the potential for non-aboriginal hunting of the Ronald Lake bison herd. Teck is supporting incremental studies on the Ronald Lake bison herd. This work is being completed by ESRD and will be considered by a Technical Working Group comprising Aboriginal communities, industry and federal and provincial governments. As discussed in ESRD/CEAA Round 3 SIR 85c, there have been updates on the disease and genetic testing for the Ronald Lake bison herd. For the 2014 field season, an additional 49 animals were tested for disease. During a recent meeting of the Ronald Lake Bison Herd Technical Studies Team (June 13, October 2014 ESRD/CEAA Page 425

428 ESRD and CEAA Responses Approvals Frontier Oil Sands Mine Project 2014), it was discussed that the results of the 2014 testing also came up negative and that the newly calculated disease prevalence was less than 5% (Skilnick 2014, pers. comm.). Genetic testing of the Ronald Lake bison herd indicates they are genetically similar to bison in WBNP though the level of differentiation is strong, suggesting genetic exchange is negligible (Ball 2013). Genetic testing further suggests that the Ronald Lake Bison herd is not currently composed of genetically pure wood bison or pure plains bison with the results suggesting that the herd shares a genetic association with both sub-species (Ball 2013). Based on these results, it could be concluded that the Ronald Lake bison herd is not genetically pure wood bison and are likely to be disease-free. The latter conclusion will likely mean that management of the herd will change. Specifically, Ronald Lake bison will likely be designated as wildlife under the Alberta Wildlife Act. In this case, hunting of the herd could be regulated. Based on discussions at the last Ronald Lake bison herd Technical Group meeting, it appears that the Government of Alberta will be pursuing designation of the Ronald Lake bison herd as wildlife under the Wildlife Act (Jalkotzy 2014, pers. comm.). Teck could request that ESRD close public access to the PAA during winter drilling activities in a manner similar to Director s Order DO#01/2013 for the Dover Road (see Appendix 86a.1). Such action would be controversial. As such, Teck would only proceed with this option if the Technical Working Group determined it to be an appropriate short-term management strategy. During Project operation, the access management plan (see the response to ESRD/CEAA Round 3 SIR 75) could be used to help control public access to the Ronald Lake bison herd north of the Project. REFERENCES Ball, M.C., Characterizing the Genetic Population Structure of Wild Bison in Alberta, Canada. Alberta Environment and Sustainable Resource Development. October Jalkotzy, M Attendance at Ronald Lake Bison Herd Technical Studies Team June 2014 Meeting. Senior Wildlife Biologist, Golder Associates. Calgary, Alberta. Skilnick, J Preliminary Activities Presented to the Ronald Lake Bison Herd Technical Studies Team. Senior Wildlife Biologist, Alberta Environment and Sustainable Resource Development. Fort McMurray, Alberta. ESRD/CEAA Page 426 October 2014

429 Frontier Oil Sands Mine Project ESRD and CEAA Responses Approvals Question 87 Volume 1, ESRD/CEAA SIR 189, Pages Teck correctly indicates that the Project does not overlap with any currently designated boreal caribou range. However, the telemetry data summarized by Teck indicates that caribou occur in the northern portion of the PAA, and that the PAA may overlap with the home range of two GPS collared caribou (ID #1750 and #1751). Telemetry data indicate that the home ranges of these individuals also extend into the designated Red Earth range. As a result, the Project may have a measurable and direct effect on caribou that occupy the Red Earth range, contrary to Teck s assertion that the Project is unlikely to have direct and measureable effects on this boreal caribou population. Furthermore, telemetry data presented by Teck indicates there is high use of small patches of habitat immediately north of the PAA by collared individuals. These habitat patches overlap the PAA to a small extent. The high number of telemetry locations in this area suggests these patches of habitat may be important for some caribou. The use of small patches of high quality habitat within an upland matrix, as shown by caribou in the vicinity of the PAA, may be a unique trait of some Red Earth caribou (Anderson ). a. Provide, using a minimum convex polygon approach, a map of the home ranges for caribou #1750 and #1751 to determine the spatial overlap of caribou home ranges with the PAA and the designated Red Earth range and that Teck specifically identify: i. The area and percentage of each home range that may overlap with the PAA; and ii. The seasonal use and movement patterns of these caribou in the vicinity of the PAA (to the extent possible). b. Identify measures Teck will use to avoid direct and indirect disturbance of moderate and high quality caribou habitat in and adjacent to the PAA, as well as direct and indirect sensory disturbance of caribou. c. Discuss habitat use patterns for caribou in the Red Earth range, based on results of Anderson (1999) and any recent studies, and how this may reflect habitat use by caribou in and adjacent to the PAA. 5 Anderson, R.B Peatland habitat use and selection by woodland caribou (Rangifer tarandus caribou) in northern Alberta. M.Sc. Thesis. Department of Biological Sciences, University of Alberta, Edmonton, Alberta. October 2014 ESRD/CEAA Page 427

430 ESRD and CEAA Responses Approvals Frontier Oil Sands Mine Project Response 87 a. i. The response to ESRD/CEAA Round 2 SIR 189 identified two collared caribou (ID 1750 and ID 1751) that were present near the PAA in 2011 and Additional collar data obtained from Stambaugh (2014, pers. comm.) provides further information about caribou movement near the PAA, including: more recent movement data for caribou ID 1750 and ID 1751 (from March 2011 to early 2013) data indicating the presence of three other collared caribou (ID 1863, ID 1906, and ID 2100) near the PAA. These observations occurred from: January 2012 to January 2014 (ID 1863) March 2012 to May 2013 (ID 1906) January 2014 to May 2014 (ID 2100) No information from other years or about other collared caribou is available (e.g., there is no information for caribou ID 1750 in 2014). Table 87a-1 shows the period of observation for collared caribou near the PAA. This response reflects the available data from all collared caribou and relevant years. Table 87a-1 Data Gaps and Observations for Collared Caribou near the PAA Caribou Collar ID ID 1750 ID 1751 ID 1863 ID 1906 ID 2100 NOTE: = GPS collar data available. = No data. Home range boundaries are delineated for caribou ID 1750, ID 1751, ID 1863, ID 1906 and ID 2100 with 100% minimum convex polygon (MCP) estimations. GPS collar locations are provided as pooled (multi-year) datasets (see Figure 87a-1) and annual (see Figures 87a-2 to 87a-6) MCP home ranges for each caribou. Home ranges were calculated using Geospatial Modelling Environment (GME) software, Version RC2 (Spatial Ecology LLC 2012) and imported into ArcGIS 10.0 (Service Pack 5) for visual representation. Annual MCP estimations are included because ranges for these individuals were highly variable among years. This variation contributes to an overestimation of caribou use of the PAA for the multi-year MCP calculation. For example, for caribou ID 1750, connecting the peripheral GPS collar locations for 2011 and 2012, which occurred on either side of the PAA (~40 km apart), ESRD/CEAA Page 428 October 2014

431 Frontier Oil Sands Mine Project ESRD and CEAA Responses Approvals produces a MCP home range boundary that overlaps much of the northern portion of the PAA (see GPS collar observations in Figure 87a-2). However, it is unlikely that the habitat between these outlying locations, which largely overlaps the PAA, was used because no GPS collar locations were recorded in the PAA. Furthermore, the peripheral locations on either side of the PAA are from different years, there was no direct movement between these locations. Only two individuals (caribou ID 1751 and ID 1906), had any GPS collar locations within the PAA (see Figures 87a-3 to 87a-5). Table 87a-2 summarizes the area and percentage of each home range that might overlap the PAA. Approximately 99 km 2 (4.2%) of the multi-year MCP home range for caribou ID 1750 overlaps the PAA (see Table 87a-2 and Figure 87a-1). For caribou ID 1751, the overlap is approximately 20 km 2 (0.8%), and for caribou ID 1863, ID 1906 and ID 2100, the multi-year MCP home ranges overlap the PAA to a lesser extent, about 1 km 2 to 6 km 2 (0.1% to 0.8%) (see Table 87a-2 and Figure 87a-1). Annual MCP homes ranges for 2011 overlap the PAA by 34 km 2 (1.8% of home range) and 20 km 2 (0.9% of home range) for caribou ID 1750 and ID In 2012 and 2013, annual MCP homes ranges for these caribou do not overlap the PAA (see Table 87a-2 and Figures 87a-2 to 87a-3). Similarly, for caribou ID 1863, the annual MCP home ranges do not overlap the PAA (see Table 87a-2 and Figure 87a-4). For caribou ID 1906, the 2013 annual MCP home range overlaps the PAA by 3 km 2 (0.7% of home range), but no overlap occurs in 2012 (see Table 87a-2 and Figure 87a-5). Annual MCP home range for caribou ID 2100 overlaps the PAA by 6 km 2 (0.8% of home range) in 2014 (the only year GPS collar locations were obtained for this individual) (see Table 87a-1 and Figure 87a-6). Overall, annual MCP home ranges for all caribou assessed overlap the PAA by less than 2%. Although the MCP method provides a simple delineation of range, it does not identify areas of the home range receiving greater intensity of use, which is important for inferring habitat selection and assessing the effect of the Project on caribou and caribou habitat. Kernel density estimates (KDE) provide a statistical method for estimating probability densities from a set of locations and can provide a more accurate account of habitat use than MCP methods (Seaman and Powell 1996). KDE can also help show activity centers (i.e., areas of high use) for these individuals. As such, multi-year KDE were calculated as an alternate method for identifying home ranges and areas of high use for the five caribou whose multi-year MCP range overlaps the PAA (see Figures 87a-7 to 87a-11). The multi-year KDE indicate that habitat use in the PAA between 2011 and 2014 is low for all caribou assessed relative to overall use of habitat. Using the 95% isopleth (i.e., 95% of the locations fall within this area) as a conservative estimate, most of the habitat selected is located within the Red Earth range boundary (see Figures 87a-7 to 87a-11). Caribou ID 1750, ID 1863, and ID 2100 also selected habitat within Wood Buffalo National Park, while caribou ID 1751 and ID 1906 selected habitat within the northern portion of the PAA. October 2014 ESRD/CEAA Page 429

432 ESRD and CEAA Responses Approvals Frontier Oil Sands Mine Project Table 87a-2 MCP Home Range for Caribou ID 1750, ID 1751, ID 1863, ID 1906 and ID 2100 and Overlap with the PAA Home Range Estimate MCP multiyear MCP 2011 MCP 2012 MCP 2013 MCP 2014 NOTE: = No data Home Range Area (km 2 ) Caribou ID 1750 Caribou ID 1751 Caribou ID 1863 Caribou ID 1906 Caribou ID 2100 Area of Overlap with PAA (km 2 ) % of Home Range Home Range Area (km 2 ) Area of Overlap with PAA (km 2 ) % of Home Range Home Range Area (km 2 ) Area of Overlap with PAA (km 2 ) % of Home Range Home Range Area (km 2 ) Area of Overlap with PAA (km 2 ) % of Home Range Home Range Area (km 2 ) Area of Overlap with PAA (km 2 ) 2, , , , , , % of Home Range ESRD/CEAA Page 430 October 2014

433 Lake Claire R18 T108 R17W4 R16 R15 R14 R13 R12 Lake Claire R11 R10 R9 R8 ³ T107 T106 Wood Buffalo National Park T105 Richardson River Dunes Wildland Provincial Park T104 T103 Athabasca River T102 T101 T100 T99 Birch Mountains Wildland Provincial Park T98 McClelland Lake T97 T96 T95 Home Range ID 1750 ( ) ID 1751 ( ) ID 1863 ( ) ID 1906 ( ) ID 2100 (2014) Athabasca River Caribou Herd Range Red Earth Richardson West Side Athabasca Terrestrial Local Study Area Vegetation and Wildlife Regional Study Area Project Assessment Area Township Watercourse National Park Provincial Park/ Protected Area Waterbody T94 Acknowledgements: Base data: AltaLIS. Caribou Collar Data: AESRD (2012). Herds: Canvec. T93 Date: File ID: KILOMETRES 1:600,000 UTM Zone 12 NAD 83 Author: SL Checked: AU (Original page size: 8.5X11) Figure 87a-1 Multi-year MCP Home Range for Caribou ID 1750, 1751, 1863, 1906 and 2100 Frontier Project Response to Supplemental Information Request: Round 3 ESRD/CEAA

434 Lake Claire R18 T108 R17W4 R16 R15 R14 R13 R12 Lake Claire R11 R10 R9 R8 ³ T107 T106 Wood Buffalo National Park T105 T104 T103 T102 T101 T100 Athabasca River Richardson River Dunes Wildland Provincial Park T99 Birch Mountains Wildland Provincial Park T98 T97 T96 T95 GPS Collar Observation Caribou ID 1750, Year Home Range Caribou Herd Range Red Earth Richardson Athabasca River West Side Athabasca McClelland Terrestrial Lake Local Study Area Vegetation and Wildlife Regional Study Area Project Assessment Area Township Watercourse National Park Provincial Park/ Protected Area Waterbody T94 Acknowledgements: Base data: AltaLIS. Caribou Collar Data: AESRD. Herds: Canvec. Home Range: Stantec (2014). T93 Date: File ID: KILOMETRES 1:600,000 UTM Zone 12 NAD 83 Author: SL Checked: CS (Original page size: 8.5X11) Figure 87a-2 Annual MCP Home Range for Caribou ID 1750 (2011 to 2013) Frontier Project Response to Supplemental Information Request: Round 3 ESRD/CEAA

435 Lake Claire R18 T108 R17W4 R16 R15 R14 R13 R12 Lake Claire R11 R10 R9 R8 ³ T107 T106 Wood Buffalo National Park T105 T104 T103 T102 T101 Athabasca River Richardson River Dunes Wildland Provincial Park T100 T99 Birch Mountains Wildland Provincial Park T98 T97 T96 T95 GPS Collar Observation Caribou ID 1751, Year Home Range Caribou Herd Range Red Earth Richardson Athabasca River West Side Athabasca McClelland Terrestrial Lake Local Study Area Vegetation and Wildlife Regional Study Area Project Assessment Area Township Watercourse National Park Provincial Park/ Protected Area Waterbody T94 Acknowledgements: Base data: AltaLIS. Caribou Collar Data: AESRD. Herds: Canvec. Home Range: Stantec (2014). T93 Date: File ID: KILOMETRES 1:600,000 UTM Zone 12 NAD 83 Author: SL Checked: CS (Original page size: 8.5X11) Figure 87a-3 Annual MCP Home Range for Caribou ID 1751 (2011 to 2013) Frontier Project Response to Supplemental Information Request: Round 3 ESRD/CEAA

436 Lake Claire R18 T108 R17W4 R16 R15 R14 R13 R12 Lake Claire R11 R10 R9 R8 ³ T107 T106 Wood Buffalo National Park T105 T104 Richardson River Dunes Wildland Provincial Park T103 T102 T101 T100 Athabasca River T99 Birch Mountains Wildland Provincial Park T98 T97 T96 T95 GPS Collar Observation Caribou ID 1863, Year Home Range Caribou Herd Range Red Earth Richardson Athabasca River West Side Athabasca McClelland Terrestrial Lake Local Study Area Vegetation and Wildlife Regional Study Area Project Assessment Area Township Watercourse National Park Provincial Park/ Protected Area Waterbody T94 Acknowledgements: Base data: AltaLIS. Caribou Collar Data: AESRD. Herds: Canvec. Home Range: Stantec (2014). T93 Date: File ID: KILOMETRES 1:600,000 UTM Zone 12 NAD 83 Author: SL Checked: CS (Original page size: 8.5X11) Figure 87a-4 Annual MCP Home Range for Caribou ID 1863 (2012 to 2014) Frontier Project Response to Supplemental Information Request: Round 3 ESRD/CEAA

437 Lake Claire R18 T108 R17W4 R16 R15 R14 R13 R12 Lake Claire R11 R10 R9 R8 ³ T107 T106 Wood Buffalo National Park T105 T104 T103 Athabasca River T102 T101 T100 T99 T98 McClelland Lake T97 T96 T95 GPS Collar Observation Caribou ID 1906, Year Home Range Caribou Herd Range Red Earth Richardson Athabasca River West Side Athabasca Terrestrial Local Study Area Vegetation and Wildlife Regional Study Area Project Assessment Area Township Watercourse National Park Provincial Park/ Protected Area Waterbody T94 Acknowledgements: Base data: AltaLIS. Caribou Collar Data: AESRD. Herds: Canvec. Home Range: Stantec (2014). T93 Date: File ID: KILOMETRES 1:600,000 UTM Zone 12 NAD 83 Author: SL Checked: CS (Original page size: 8.5X11) Figure 87a-5 Annual MCP Home Range for Caribou ID 1906 (2012, 2013) Frontier Project Response to Supplemental Information Request: Round 3 ESRD/CEAA

438 Lake Claire R18 T108 R17W4 R16 R15 R14 R13 R12 Lake Claire R11 R10 R9 R8 ³ T107 T106 Wood Buffalo National Park T105 T104 T103 Athabasca River Richardson River Dunes Wildland Provincial Park T102 T101 T100 T99 Birch Mountains Wildland Provincial Park T98 McClelland Lake T97 T96 T95 GPS Collar Observation Caribou ID 2100, Year 2014 Home Range 2014 Caribou Herd Range Red Earth Richardson Athabasca River West Side Athabasca Terrestrial Local Study Area Vegetation and Wildlife Regional Study Area Project Assessment Area Township Watercourse National Park Provincial Park/ Protected Area Waterbody T94 Acknowledgements: Base data: AltaLIS. Caribou Collar Data: AESRD. Herds: Canvec. Home Range: Stantec (2014). T93 Date: File ID: KILOMETRES 1:600,000 UTM Zone 12 NAD 83 Author: SL Checked: CS (Original page size: 8.5X11) Figure 87a-6 Annual MCP Home Range for Caribou ID 2100 (2014) Frontier Project Response to Supplemental Information Request: Round 3 ESRD/CEAA

439 Lake Claire R18 T108 R17W4 R16 R15 R14 R13 R12 Lake Claire R11 R10 R9 R8 ³ T107 T106 Wood Buffalo National Park T105 Richardson River Dunes Wildland Provincial Park T104 T103 Athabasca River T102 T101 T100 T99 Birch Mountains Wildland Provincial Park T98 T97 T96 T95 95% Isopleth Kernel Density 10% 20% 30% 40% 50% 60% 70% 80% 90% Home Range Athabasca River Caribou Herd Range Red Earth McClelland Lake Richardson West Side Athabasca Terrestrial Local Study Area Vegetation and Wildlife Regional Study Area Project Assessment Area Township Watercourse National Park Provincial Park/ Protected Area Waterbody T94 Acknowledgements: Base data: AltaLIS. Herds: Canvec. Collar Data: AESRD (2012). Kernel Density and Home Range: Stantec (2014). T93 Figure 87a-7 Multi-year MCP Home Range and Multi-year Density for Caribou ID 1750 (2011 to 2013) Frontier Project Response to Supplemental Information Request: Round 3 ESRD/CEAA Date: File ID: KILOMETRES 1:600,000 UTM Zone 12 NAD 83 Author: SL Checked: CS (Original page size: 8.5X11)

440 Lake Claire R18 T108 R17W4 R16 R15 R14 R13 R12 Lake Claire R11 R10 R9 ³ R8 T107 T106 Wood Buffalo National Park T105 T104 T103 Athabasca River T102 T101 T100 T99 Birch Mountains Wildland Provincial Park T98 T97 T96 T95 T94 95% Isopleth Kernel Density 10% 20% 30% 40% 50% 60% 70% 80% 90% Home Range Caribou Herd Range Athabasca River Red Earth Richardson McClelland Lake West Side Athabasca Terrestrial Local Study Area Vegetation and Wildlife Regional Study Area Project Assessment Area Township Watercourse National Park Provincial Park/ Protected Area Waterbody T93 Acknowledgements: Base data: AltaLIS. Herds: Canvec. Collar Data: AESRD (2012). Kernel Density and Home Range: Stantec (2014). Date: File ID: KILOMETRES 1:600,000 UTM Zone 12 NAD 83 Author: SL Checked: CS (Original page size: 8.5X11) Figure 87a-8 Multi-year MCP Home Range and Multi-year Density for Caribou ID 1751 (2011 to 2013) Frontier Project Response to Supplemental Information Request: Round 3 ESRD/CEAA

441 R18 T108 R17W4 R16 R15 R14 R13 R12 Lake Claire R11 R10 R9 R8 T107 T106 Wood Buffalo National Park T105 Richardson River Dunes Wildland Provincial Park T104 T103 Athabasca River T102 T101 T100 T99 Birch Mountains Wildland Provincial Park T98 T97 T96 T95 95% Isopleth Kernel Density 10% 20% 30% 40% 50% 60% 70% 80% 90% Home Range Athabasca River Caribou Herd Range Red Earth McClelland Lake Richardson West Side Athabasca Terrestrial Local Study Area Vegetation and Wildlife Regional Study Area Project Assessment Area Township Watercourse National Park Provincial Park/ Protected Area Waterbody T94 Acknowledgements: Base data: AltaLIS. Herds: Canvec.Kernal Density and Home Range: Stantec (2014) T93 Date: File ID: KILOMETRES 1:600,000 UTM Zone 12 NAD 83 Author: SL Checked: CES (Original page size: 8.5X11) Figure 87a-9 Multi-year MCP Home Range and Multi-year Density for Caribou ID 1863 (2012 to 2014) Frontier Project Response to Supplemental Information Request: Round 3 ESRD/CEAA

442 R18 T108 R17W4 R16 R15 R14 R13 R12 Lake Claire R11 R10 R9 R8 T107 T106 Wood Buffalo National Park T105 Richardson River Dunes Wildland Provincial Park T104 T103 Athabasca River T102 T101 T100 T99 Birch Mountains Wildland Provincial Park T98 T97 T96 T95 95% Isopleth Kernel Density 10% 20% 30% 40% 50% 60% 70% 80% 90% Home Range Athabasca River Caribou Herd Range Red Earth Richardson McClelland Lake West Side Athabasca Terrestrial Local Study Area Vegetation and Wildlife Regional Study Area Project Assessment Area Township Watercourse National Park Provincial Park/ Protected Area Waterbody T94 Acknowledgements: Base data: AltaLIS. Herds: Canvec. Kernal Density and Home Range: Stantec (2014) T Date: File ID: KILOMETRES 1:600,000 UTM Zone 12 NAD 83 Author: SL Checked: CS (Original page size: 8.5X11) Figure 87a-10 Multi-year MCP Home Range and Multi-year Density for Caribou ID 1906 (2012, 2013) Frontier Project Response to Supplemental Information Request: Round 3 ESRD/CEAA

443 R18 T108 R17W4 R16 R15 R14 R13 R12 Lake Claire R11 R10 R9 R8 T107 T106 Wood Buffalo National Park T105 Richardson River Dunes Wildland Provincial Park T104 T103 Athabasca River T102 T101 T100 T99 Birch Mountains Wildland Provincial Park T98 T97 T96 T95 95% Isopleth Kernel Density 10% 20% 30% 40% 50% 60% 70% 80% 90% Home Range Athabasca River Caribou Herd Range Red Earth Richardson McClelland Lake West Side Athabasca Terrestrial Local Study Area Vegetation and Wildlife Regional Study Area Project Assessment Area Township Watercourse National Park Provincial Park/ Protected Area Waterbody T94 Acknowledgements: Base data: AltaLIS. Herds: Canvec. Kernal Density and Home Range: Stantec (2014) T Date: File ID: KILOMETRES 1:600,000 UTM Zone 12 NAD 83 Author: SL Checked: CS (Original page size: 8.5X11) Figure 87a-11 Multi-year MCP Home Range and Multi-year Density for Caribou ID 2100 (2014) Frontier Project Response to Supplemental Information Request: Round 3 ESRD/CEAA

444 ESRD and CEAA Responses Approvals Frontier Oil Sands Mine Project ii) Seasonal 100% MCP home ranges were calculated by year for: late winter (February 22 to April 30) calving (May 1 to June 30) summer (July 1 to September 15) rut (September 16 to November 15) early winter (November 16 to February 21) These seasons were delineated based on those used by Dyer et al. (2001) for boreal caribou in northeastern Alberta. Seasonal MCP home ranges are shown for each caribou in Figures 87a-12 to 87a-16. Seasonal use of the PAA was limited to late winter for three of the caribou (ID 1750, 1751, 2100; see Figures 87a-12, 87a-13, 87a-16), while caribou ID 1906 was in the PAA only during the 2013 calving period (see Figure 87a-15); the MCP of caribou ID 1863 did not overlap the PAA in any season (see Figure 87a-14). For caribou ID 1750 and ID 1751, approximately 32 km 2 (2.1%) and 20 km 2 (1.3%) of the MCP 2011 late winter home ranges overlap the PAA, respectively. For caribou ID 2100, approximately 4.6 km 2 (0.7%) of the 2014 MCP late winter home range overlaps the PAA and, for caribou ID 1906, approximately 2.8 km 2 (20%) of the 2013 calving period home range overlaps the PAA. Caribou ID 1750 was within 10 km of the PAA between April 17 and April 28, 2011 (late winter). However, it was otherwise mostly within the Red Earth range boundary or in Wood Buffalo National Park (WBNP) (see Figure 87a-12). Caribou ID 1751 was also within 10 km of the PAA during late winter 2011 (between April 17 and April 27, 2011), but was otherwise within the Red Earth range boundary throughout 2011 and 2012 (see Figure 87a-13). These data are consistent with other studies for boreal caribou in Alberta that describe considerable overlap between summer and winter ranges (Stuart-Smith et al. 1997; Dalerum et al. 2007), with larger winter ranges compared to those during the calving season and summer (Fuller and Keith 1981; Stuart-Smith et al. 1997). Movement pathways near the PAA are shown for each of these caribou during late winter and calving periods (see Figures 87a-17 and 87a-18) and summarized as follows (note: pathways are based on multiple points recorded per day): Caribou ID 1750 made a west-to-east foray towards the PAA between April 17 and April 24, The closest location to the PAA was approximately 6 km away (see Figure 87a-17). On April 27, 2011, caribou ID 1750 moved 27 km from the southwest to the northeast and likely crossed the PAA (see Figure 87a-17). The following day, this individual moved approximately 52 km north to WBNP, where it stayed until late June, presumably to calve. ESRD/CEAA Page 442 October 2014

445 Frontier Oil Sands Mine Project ESRD and CEAA Responses Approvals On April 17, 2011, caribou ID 1751 moved approximately 16 km from the southwest to the northeast into the northern portion of the PAA (see Figure 87a-17). This individual left the PAA on April 19 and remained 2 km to 3 km north of the PAA boundary until April 27. At this point, it moved to a location 35 km northwest of the PAA. Caribou ID 1751 remained in this area until June 1, 2011, again presumably to calve. In 2012, pre-calving (i.e., late winter) movements for caribou ID 1750 and ID 1751 did not come within 10 km of the PAA boundary. Caribou ID 1863 travelled northeast from the Red Earth range boundary to an area approximately 15 km north of the PAA between April 17 and 23, In mid-april 2013, this individual travelled northeast into WBNP, where it remained until June 8, 2013 (see Figure 87a-18). Caribou ID 2100 took a similar path to WBNP in April 2014 (see Figure 87a-18). Neither of these individuals entered the PAA. Caribou ID 1906 travelled into the northwest portion of the PAA on May 4, 2013, and remained there until May 11, 2013 (see Figure 87a-18). b. Direct (e.g. habitat loss) and indirect (e.g. sensory disturbance) disturbance will occur in caribou habitat to some extent because the locations of Project components (e.g., mine pits) are determined by the resource. Sensory disturbance will likely occur for caribou using habitat adjacent to the PAA. However, the MCP home ranges and KDE discussed in the response to part a indicate low use of habitat within and near the PAA by caribou (see Figures 87a-1 to 87a-16). Although GPS collar data indicate a low probability for direct effects of the Project on caribou, Teck commits to developing mitigation measures specifically for caribou. In keeping with its corporate goal to achieve a net positive impact on biodiversity by maintaining or re-establishing selfsustaining landscapes and ecosystems that lead to viable long-term and diverse land uses in the areas in which we operate (Teck 2014), Teck will explore potential strategies to mitigate or offset effects of the Project on wildlife and wildlife habitat. These strategies have not been determined, but might include measures to improve caribou movement and habitat connectivity in the region. As discussed in Environment Canada (2012), one of the primary threats to woodland caribou is predation, which can indirectly result from the creation of anthropogenic linear disturbances and features. COSIA, of which Teck is a member company, has initiated two studies that involve reclaiming seismic lines to improve caribou use and monitoring the effectiveness of reclamation efforts on wildlife use and movement. These studies include the Algar Caribou Habitat Restoration Program and the Linear Deactivation Project. Teck plans to use learnings from these studies to develop and refine closure plans for the PAA and surrounding area and provide guidance about potential offset strategies to create net benefits for caribou and other wildlife species. October 2014 ESRD/CEAA Page 443

446 Lake Claire R15 T108 R14W4 R13 R12 Lake Claire R11 R10 R9 R8 Richardson Lake Migratory Bird Sanctuary R7 R6 R5 ³ T107 T106 Wood Buffalo National Park Maybelle River Wildlland Provincial Park Athabasca Dunes Ecological Reserve T105 T104 T103 T102 T101 T100 Athabasca River Richardson River Dunes Wildland Provincial Park Marguerite River Wildland Provincial Park Birch Mountains Wildland Provincial Park T99 T98 T97 T96 T95 GPS Collar Observation Caribou ID 1750, Season Late Winter Calving Summer McClelland Lake Rut Early Winter 2011 Late Winter Calving Summer Rut Early Winter 2012 Late Winter Calving Early Winter 2013 Late Winter Early Winter Caribou Herd Range Red Earth Richardson West Side Athabasca Terrestrial Local Study Area Vegetation and Wildlife Regional Study Area Project Assessment Area Township Watercourse National Park Provincial Park/ Protected Area Waterbody T94 Acknowledgements: Base data: AltaLIS. Caribou Collar Data: AESRD (2012). Herds: Canvec. T93 Figure 87a-12 Seasonal MCP Home Range for Caribou ID 1750 (2011 to 2013) Frontier Project Response to Supplemental Information Request: Round 3 ESRD/CEAA Date: File ID: KILOMETRES 1:600,000 UTM Zone 12 NAD 83 Author: SL Checked: AU (Original page size: 8.5X11)

447 T106 Wood Buffalo National Park ³ T105 T104 T103 T102 T101 Athabasca River Richardson River Dunes Wildland Provincial Park T100 T99 Birch Mountains Wildland Provincial Park T98 McClelland Lake T97 T96 T95 T94 T93 GPS Collar Observation Caribou ID 1751, Season Late Winter Calving Summer Rut Early Winter 2011 Late Winter Calving Summer Rut Early Winter 2012 Late Winter Calving Summer Rut Early Winter Athabasca River 2013 Early Winter Caribou Herd Range Red Earth Richardson West Side Athabasca Terrestrial Local Study Area Vegetation and Wildlife Regional Study Area Project Assessment Area Township Watercourse National Park Provincial Park/ Protected Area Waterbody T KILOMETRES Acknowledgements: Base T91data: AltaLIS. Caribou Collar Data: AESRD (2012). Herds: Canvec. Date: File ID: :600,000 UTM Zone 12 NAD 83 Author: SL Checked: AU (Original page size: 8.5X11) Figure 87a-13 Seasonal MCP Home Range for Caribou ID 1751 (2011 to 2013) Frontier Project Response to Supplemental Information Request: Round 3 ESRD/CEAA

448 R18 T106 R16 R15 Wood Buffalo National Park R14 R13 R12 R11 R10 R9 R8 ³ T105 Richardson River Dunes Wildland Provincial Park T104 T103 T102 T101 T100 Athabasca River T99 Birch Mountains Wildland Provincial Park T98 McClelland Lake T97 T96 T95 T94 T93 GPS Collar Observation Caribou ID 1863, Season Late Winter Calving Summer Rut Early Winter 2012 Late Winter Calving Summer Rut Early Winter 2013 Late Winter Early Winter Athabasca River Caribou Herd Range Red Earth Richardson West Side Athabasca Terrestrial Local Study Area Vegetation and Wildlife Regional Study Area Project Assessment Area Township Watercourse National Park Provincial Park/ Protected Area Waterbody T KILOMETRES Acknowledgements: Base T91data: AltaLIS. Caribou Collar Data: AESRD (2012). Herds: Canvec. Date: File ID: :600,000 UTM Zone 12 NAD 83 Author: SL Checked: AU (Original page size: 8.5X11) Figure 87a-14 Seasonal MCP Home Range for Caribou ID 1863 (2012 to 2014) Frontier Project Response to Supplemental Information Request: Round 3 ESRD/CEAA

449 Lake Claire T107 R17W4 R16 R15 R14 R13 R12 R11 R10 R9 R8 ³ R7 T106 Wood Buffalo National Park T105 Richardson River Dunes Wildland Provincial Park T104 T103 Athabasca River T102 T101 T100 T99 Birch Mountains Wildland Provincial Park T98 McClelland Lake T97 T96 T95 T94 GPS Collar Observation Caribou ID 1906, Season Late Winter Calving Summer Rut Early Winter 2012 Late Winter Calving Summer Rut Early Winter 2013 Late Winter Athabasca River Caribou Herd Range Red Earth Richardson West Side Athabasca Terrestrial Local Study Area Vegetation and Wildlife Regional Study Area Project Assessment Area Township Watercourse National Park Provincial Park/ Protected Area Waterbody Calving Early Winter T KILOMETRES Acknowledgements: T92Base data: AltaLIS. Caribou Collar Data: AESRD (2012). Herds: Canvec. Date: File ID: :600,000 UTM Zone 12 NAD 83 Author: SL Checked: AU (Original page size: 8.5X11) Figure 87a-15 Seasonal MCP Home Range for Caribou ID 1906 (2012, 2013) Frontier Project Response to Supplemental Information Request: Round 3 ESRD/CEAA

450 Lake Claire T107 R17W4 R16 R15 R14 R13 R12 R11 R10 R9 R8 ³ R7 T106 Wood Buffalo National Park T105 T104 T103 Athabasca River Richardson River Dunes Wildland Provincial Park T102 T101 T100 T99 Birch Mountains Wildland Provincial Park T98 McClelland Lake T97 T96 T95 T94 GPS Collar Observation Caribou ID 2100, Season Late Winter Calving Early Winter 2014 Early Winter Calving Late Winter Caribou Herd Range Athabasca River Red Earth Richardson West Side Athabasca Terrestrial Local Study Area Vegetation and Wildlife Regional Study Area Project Assessment Area Township Watercourse National Park Provincial Park/ Protected Area Waterbody T KILOMETRES Acknowledgements: T92 Base data: AltaLIS. Caribou Collar Data: AESRD (2012). Herds: Canvec. Date: File ID: :600,000 UTM Zone 12 NAD 83 Author: SL Checked: AU (Original page size: 8.5X11) Figure 87a-16 Seasonal MCP Home Range for Caribou ID 2100 (2014) Frontier Project Response to Supplemental Information Request: Round 3 ESRD/CEAA

451 T107 GF 4/29/2011 ³ R15 T106 R14W4 R13 R12 R11 R10 R9 R8 T105 GF 4/28/2011 Wood Buffalo National Park GF 4/29/2011 T104 T103 T102 4/17/2011 GF GF GF GF 4/28/2011 4/27/2011 GF 4/24/2011 4/20/2011 GF 4/18/2011 GF 4/27/2011 GF GF 4/19/2011 4/22/2011 Athabasca River GF 4/23/2011 T101 4/26/2011 GF GF 4/17/2011 T100 T99 T98 Approximate Location (m/dd/yyyy) GF GF ID 1750 ID 1751 GPS Collar Observations Caribou Pathway ID 1750 ID 1751 Red Earth Caribou Herd Range Terrestrial Local Study Area Vegetation and Wildlife Regional Study Area Project Assessment Area Township Watercourse National Park Provincial Park/ Protected Area Waterbody T97 Acknowledgements: Base data: Canvec. Caribou Collar Data: AESRD (2012). Herds: Canvec. Date: File ID: KILOMETRES 1:400,000 UTM Zone 12 NAD 83 McClelland Lake Author: SL Checked: CES (Original page size: 8.5X11) Figure 87a-17 Movement Pathways of Caribou ID 1750 and 1751 near the PAA Frontier Project Response to Supplemental Information Request: Round 3 ESRD/CEAA

452 T107 R14W4 R13 R12 R11 R10 R9 R8 ³ T106 T105 T104 T103 T102 T101 4/11/2014 3/12/2014 4/15/2014 4/23/2013 4/22/2013 4/14/2014 4/29/2013 Wood Buffalo National Park 6/13/2013 4/24/2012 GF GF GFGF GF GF GF GFGFGF GF GF GF GF GF GF GF GF GF GF GF GF GF GF GF GF GF GF GF GF GF GF GF 5/3/2012 7/6/2013 4/16/2014 6/12/2013 4/26/2013 4/23/2012 4/30/2012 5/3/2013 4/30/2013 4/18/2012 5/11/2013 5/4/2013 5/10/2013 4/18/2014 4/27/2013 4/22/2012 4/19/2012 5/12/2013 5/28/2013 4/23/2014 6/8/2013 5/14/2014 4/29/2014 4/28/2014 Athabasca River Richardson River Dunes Wildland Provincial Park T100 Birch Mountains Wildland Provincial Park T99 T98 Approximate Location (m/dd/yyyy) GF GF GF ID 1863 ID 1906 ID 2100 GPS Collar Observations Caribou Pathways ID 1863 ID 1906 ID 2100 Red Earth Caribou Herd Range Terrestrial Local Study Area Vegetation and Wildlife Regional Study Area Project Assessment Area Township Watercourse National Park Provincial Park/ Protected Area Waterbody Acknowledgements: T97 Base data: Altalis. Caribou Collar Data: AESRD (2012). Herds: Canvec. Date: File ID: KILOMETRES McClelland 1:400,000 UTM Zone 12 NAD Lake 83 Author: SL Checked: CES (Original page size: 8.5X11) Figure 87a-18 Movement Pathways of Caribou ID 1863, 1906 and 2100 near the PAA Frontier Project Response to Supplemental Information Request: Round 3 ESRD/CEAA

453 Frontier Oil Sands Mine Project ESRD and CEAA Responses Approvals c. Anderson (1999) examined patterns of habitat use and selection by caribou in the Red Earth range. The study looked at different scales (coarse and fine). Habitat data for the coarse scale derived from 1:250,000 air photo interpretation and subdivided into large habitat polygons classified by dominant habitat class (i.e., treed peatland-dominated landscapes or upland-dominated landscapes). Based on coarse-scale habitat data, he identified that caribou in the Red Earth range are not restricted to landscapes dominated by treed peatlands. They are also present in upland-dominated landscapes. Refined analysis using fine-scale mapping of the southern Red Earth range (from 1:15,000 to 1:40,000) showed that, although these animals occurred in upland-dominated polygons at a coarse scale, they selected treed peatlands within the upland matrix. Although not investigated by Anderson (1999), a similar pattern of fine-scale habitat selection might be exhibited by individuals in the northern part of that range and in areas near the PAA where peatland-upland matrices occur. Telemetry data obtained from ESRD indicate that the home ranges of five GPS-collared caribou that reside in the northeastern portion of the Red Earth range (caribou IDs 1750, 1751, 1863, 1906 and 2100) might overlap the PAA, although only two individuals had GPS collar locations within the PAA (ID 1751 and ID 1906; see the response to part a). In late April 2011, caribou ID 1750 and ID 1751 accessed a relatively large peatland complex north of the PAA, and ID 1751 accessed small patches of treed fen within the PAA boundary. This peatland complex is unconnected to larger peatlands within the Red Earth range (see Volume 6, Section 3.4.1, Figure 3-3, Page 3-19), but it appears to offer temporary late-winter habitat, and possibly calving habitat, for some members of the Red Earth population. In early May 2013, caribou ID 1906 entered the northwestern perimeter PAA in early May 2013, an area that consists primarily of swamps and fens (see Volume 6, Section 3.4.2, Figure 3-5, Page 3-23). Selection of peatland habitat has been described for boreal caribou elsewhere in northeastern Alberta (e.g., Stuart-Smith et al. 1997; James et al. 2004; Wasser et al. 2011; Latham et al. 2013). Analysis of very high frequency (VHF) collar data for boreal caribou south of the PAA (i.e., West Side Athabasca River [WSAR] and East Side Athabasca River [ESAR] ranges) revealed that 98.7% of caribou locations were within fen complexes (Stuart-Smith et al. 1997). Peatlands (e.g., fens and bogs) allow for spatial separation between caribou and alternate prey species such as moose and deer, which are more common in upland habitat (James et al. 2004; Latham et al. 2013). It is reasonable to assume that if caribou are present in the PAA they will select areas of peatland, where available, in April and May. GPS collar data indicate post-calving, rutting and early winter activities do not occur in the PAA (see the response to part a). This suggests habitat suitability for these activities is low in the PAA relative to that within the Red Earth range. October 2014 ESRD/CEAA Page 451

454 ESRD and CEAA Responses Approvals Frontier Oil Sands Mine Project REFERENCES Anderson, R.B Peatland habitat use and selection by woodland caribou (Rangifer tarandus caribou) in northern Alberta. M.Sc. Thesis. Department of Biological Sciences, University of Alberta, Edmonton, Alberta. Dalerum, F., S. Boutin and J.S. Dunford Wildfire effects on home range size and fidelity of boreal caribou in Alberta, Canada. Canadian Journal of Zoology 85: Dyer, S.J., J.P. O Neil, S.M. Wasel and S. Boutin Avoidance of industrial development by woodland caribou. Journal of Wildlife Management 65: Environment Canada Recovery Strategy for the Woodland Caribou (Rangifer tarandus caribou), Boreal Population, in Canada. Species at Risk Act Recovery Strategy Series. Ottawa, Ontario. Fuller, T.K. and L.B. Keith Woodland caribou population dynamics in northeastern Alberta. Journal of Wildlife Management 45: James, A.R.C., S. Boutin, D.M. Hebert and A.B Rippin Spatial separation of caribou from moose and its relation to predation by wolves. Journal of Wildlife Management 68: Latham, A.D.M., M.C. Latham, K.H Knopff, M. Hebblewhite and S. Boutin Wolves, white-tailed deer, and beaver: implications of seasonal prey switching for woodland caribou declines. Ecography 36: Seaman, D.E. and R.A. Powell An evaluation of the accuracy of kernel density estimators for home range analysis. Ecology 77: Stambaugh, C Data Sharing Agreement for Caribou Collar Data in Northeastern Alberta. Alberta Environment and Sustainable Resource Development. Personal communication, May 23, Spatial Ecology LLC Geospatial Modelling Environment Program, Version RC2. Available at: Accessed June Stuart-Smith, A.K., C.J. Bradshaw, S. Boutin, D.M. Herbert and A.B. Rippen Woodland caribou relative to landscape patterns in northeastern Alberta. Journal of Wildlife Management 61: Teck (Teck Resources Limited) Biodiversity. Available at: page=teck+site%2fresponsibility+pages%2fsustainability+pages%2fkey+focus+area+pages%2fe cosystems+and+biodiversity&portalname=tc. Accessed March Wasser S.K., J.L. Keim, M.L. Taper and R.L. Subhash The influences of wolf predation, habitat loss, and human activity on caribou and moose in Alberta oil sands. Frontiers in Ecology and the Environment 9: ESRD/CEAA Page 452 October 2014

455 Frontier Oil Sands Mine Project ESRD and CEAA Responses Approvals Question 88 Volume 1, ESRD/CEAA SIR 193 Tables 193a-2, Page 549 Table 193a-4, Page 551 Teck reviewed amphibian aqueous exposure toxicity literature and discussed potential toxicity and health risks on amphibians associated with Project-related chemicals of potential concern (COPCs). The calculation of risk was based on the predicted surface water concentrations of these chemicals. In their assessment, Teck highlights that the concentration of aluminum and zinc will exceed a toxicological threshold value (LC50) in all assessment cases (predevelopment, Base Case, Application Case and PDC) for Gastrophryne carolinensis (Eastern narrow-mouthed toad). Tables 193a-2 (pg. 549) and 193a-4 (pg. 551) indicate that aluminum and zinc concentrations will increase approximately forty-fold and two-fold, respectively, in the surface water of certain water bodies and watercourses over the course of the Project. a. Explain why aluminum and zinc concentrations in Redclay Creek will increase by approximately forty-fold and two-fold, respectively, from predevelopment and Base Cases to Application and Planned Development Cases. b. Provide a table of predicted changes in the surface water and in the sediment of concentrations of all Project-related COPCs in Redclay Creek for all assessment cases. Response 88 As discussed in the response to AER Round 3 SIR 1, Teck intends to update the for the Project to: recover additional resource from leases acquired from Shell during the Teck Shell asset exchange optimize the tailings management strategy in consideration of the current state of engineering practice and improved understanding of site-specific conditions reflect additional engineering studies and information obtained from Shell as part of the asset exchange consider input received from regulators and potentially affected Aboriginal communities during the review process Portions of this SIR response will be reevaluated as part of the Project Update; however, the following discussion provides further context in response to questions asked by the reviewer. a. As mentioned in Volume 5, Section , Pages 4-90 to 4-91 of the, discharge from the central pit lake in 2068 and 2157 (under the Application Case and PDC, respectfully), is predicted to increase the concentrations of some substances in Redclay Creek. During filling, the two major sources of water for central pit lake A are Athabasca River water and tailings area water (for details, see the response to ESRD/CEAA Round 1 SIR 45, Appendix 45a.7, Table 4-28). The predicted elevated concentrations of total aluminum and zinc in central pit lake A are October 2014 ESRD/CEAA Page 453

456 ESRD and CEAA Responses Approvals Frontier Oil Sands Mine Project because the Athabasca River water and tailings water are rich in aluminum and zinc (see Volume 5, Appendix 4A, Section 4A.3, Pages 4A-50 to 4A-66). As described previously (see Volume 5, Appendix 4A, Section 4A.2.2.1, Pages 4A-9 to 4A-13 and the response to ESRD/CEAA Round 1 SIR115b), the water quality models assumed that particulate metals in process-affected waters would remain in suspension in the pit lake water column. Current understanding of pit lake limnological processes indicates that most of these particulate metals will settle during the filling period (2055 to 2067). Removal of particulate metals from the pit lake water column is expected to result in waterborne total metal concentrations lower than the conservative predictions of the pit lake assessment. b. Predicted changes in the surface water and sediment concentrations of identified chemicals of potential concern (COPC) in Redclay Creek were provided in the : For surface water concentrations, see Volume 5, Section , Table 4-12, Pages 4-69 to Revisions based on the revised surface water quality assessment are presented in response to ESRD/CEAA Round 1 SIR 308, Appendix 308a.4, Table 308a.4-4. The revised concentrations presented in Table 308a.4-4 for the Application Case are reproduced in Table 88b-1. For predicted changes in sediment concentrations, see Volume 5, Section , Table 4-21, Page For convenience, predicated concentrations for Redclay Creek are presented here in Table 88b-2). REFERENCES CCME (Canadian Council of Ministers of the Environment) (with updates through 2014). Canadian Environmental Quality Guidelines. Winnipeg, Manitoba. ESRD/CEAA Page 454 October 2014

457 Frontier Oil Sands Mine Project ESRD and CEAA Responses Approvals Table 88b-1 Predicted Application Case Concentrations in Redclay Creek Parameter Unit Water Quality Guideline Benchmark Predevelopment Application Case Aquatic Life (a,b) Fish Median Peak Median Concentration Peak Concentration Acute Chronic Chronic Observed Natural Variation (c) Concentration (d) Concentration (d,e) Aluminum mg/l ( ) n = Ammonia mg/l <0.05 (< ) n = Antimony mg/l (< ) n = Arsenic mg/l < (< ) n = Barium mg/l ( ) n = Beryllium mg/l <0.001 (<0.001 <0.001) n = Boron mg/l ( ) n = Cadmium mg/l < (< <0.0002) n = Chloride mg/l ( ) n = Chromium mg/l < (< ) n = Copper mg/l <0.001 ( ) n = Iron mg/l ( ) n = Lead mg/l (< ) n = Manganese mg/l ( ) n = Mercury mg/l < (< ) n = Molybdenum mg/l (< ) n = Naphthenic Acids - Labile mg/l Naphthenic Acids - Refractory mg/l Naphthenic Acids - Inert mg/l Naphthenic Acids - Total (Upper) mg/l <1 (<1 1) n = Naphthenic Acids - Total (Lower) mg/l <1 (<1 1) n = Nickel mg/l (< ) n = PAH group 1 µg/l <0.04 (< <0.04) n = PAH group 2 µg/l <0.04 (< <0.04) n = PAH group 3 µg/l 0.99 <0.01 (< <0.01) n = PAH group 4 µg/l <0.04 (< <0.04) n = PAH group 5 µg/l <0.04 ( <0.04) n = PAH group 6 µg/l 64 <0.04 (0.038 <0.04) n = PAH group 7 µg/l <0.04 (0.011 <0.04) n = October 2014 ESRD/CEAA Page 455

458 ESRD and CEAA Responses Approvals Frontier Oil Sands Mine Project Table 88b-1 Predicted Application Case Concentrations in Redclay Creek (cont d) Water Quality Guideline Benchmark Predevelopment Application Case Parameter Unit Aquatic Life (a,b) Fish Median Peak Median Concentration Peak Concentration Acute Chronic Chronic Observed Natural Variation (c) Concentration (d) Concentration (d,e) PAH group 8 µg/l <0.04 (< ) n = PAH group 9 µg/l <0.04 ( <0.04) n = Selenium mg/l < (< ) n = Silver mg/l ( ) n = Strontium mg/l ( ) n = Sulphate mg/l 96 (46 209) n = Sulphide mg/l (< ) n = Tainting potential TPU Total dissolved solids mg/l ( ) n = Total nitrogen mg/l (< ) n = Total phenolics mg/l (< ) n = Total phosphorus mg/l ( ) n = Toxicity- acute TUa Toxicity- chronic TUc Vanadium mg/l (< ) n = Zinc mg/l (< ) n = NOTES: (a) (b) (c) (d) (e) = No guideline or no data available From U.S.EPA (2002, 2003, 2009), CCME (1999, 2012) and AENV (1999), assuming a ph of 7.4, temperature of 4.6ºC and hardness of 232 mg/l. Observed natural variation from 1976 to 2010, based on information from AENV (2010), Shell (2007) and the water quality baseline. If predicted concentrations were so low they became negligible, model results were replaced with zeros. Peak concentrations represent percentile values calculated from a model dataset containing more than 16,000 data points; with the exception of acute toxicity, which is a daily peak, concentrations are shown as four-day average concentrations. Bold font indicates concentration is greater than the chronic guideline. ESRD/CEAA Page 456 October 2014

459 Frontier Oil Sands Mine Project ESRD and CEAA Responses Approvals Table 88b-2 Predicted Metal and PAH Concentrations in Sediments in Redclay Creek Metals Parameter Unit Benchmarks Redclay Creek ISQG PEL Predevelopment Base Case Arsenic mg/kg Cadmium mg/kg Chromium mg/kg Copper mg/kg Lead mg/kg Mercury mg/kg Nickel mg/kg Zinc mg/kg PAHs Application Case Acenaphthene mg/kg Acenaphthylene mg/kg Anthracene mg/kg Benzo(a)anthracene mg/kg Benzo[a]pyrene mg/kg Chrysene mg/kg Dibenzo(a,h)anthracene mg/kg Fluoranthene mg/kg Fluorene mg/kg Naphthalene mg/kg C1 substituted naphthalenes mg/kg Phenanthrene mg/kg Pyrene mg/kg NOTES: ISQG = CCME interim sediment quality guideline (CCME 1999 with updates through 2014). PEL = probable effects level. PAH = polycyclic aromatic hydrocarbon. Bold font indicates concentration are greater than the ISQG. October 2014 ESRD/CEAA Page 457

460 ESRD and CEAA Responses Approvals Frontier Oil Sands Mine Project Water Quality Question 89 Frontier Oil Sands Mine Project, Environmental Impact Statement (EIS), Volume 5 Sections , Management and Monitoring, Pages Section 4.12, Table 4-34, Fish Tissue Effects Concentrations, Page Section , Table 4-37, Predicted Changes in Fish Tissue Concentrations (LAS), Page Section Management and Monitoring, Page Teck s Response to Supplemental Information Request Number 2, Volume 1, ESRD/CEAA, Section 6, Approvals, Federal, Water Quality, SIR 170, Pages In SIR response #170a. Teck addresses predicted concentrations of metals in fish tissues, and the level of conservatism used in the predictions. EC notes that there are still some areas of uncertainty associated with predictions. EC SIRs the rationale for dismissing selenium, since it does appear that it will exceed the water quality benchmark in the central pit lake concentrations in the future (see figure 31-a-3 8 of 11 in this SIR). Selenium especially, needs to have the tissue residue value that was developed in Table 4-34 volume 5 Water, linked to the chronic effects benchmarks, and to use the egg/ovary tissue value as the primary benchmark for monitoring selenium Similarly, there are uncertainties with other parameters that underscore the need for monitoring and adaptive management. For example, chromium and vanadium were identified as potentially causing low level fish tissue accumulation effects. In SIR response #170a.i, Teck outlines bioavailability related to total versus dissolved chromium, and presents a discussion of hardness as a toxicity modifying factor. It should be noted that both chromium and vanadium normally exist in water as oxyanions and thus uptake and toxicity are not particularly influenced by water hardness; therefore the effects of hardness are not as conservative as suggested. Similarly, although bioavailability of total versus dissolved vanadium has been discussed, it has not been identified whether dietary uptake for those higher levels of total vanadium is a factor in fish tissue accumulations of vanadium. In SIR response #170b, Teck states that there will be annual fish tissue monitoring, and SIR response #170c elaborates further on comparisons to toxicological benchmarks and subsequent actions for adaptive management. EC concurs with the use of ongoing monitoring to assess risks on an ongoing basis, and inform adaptive management. a. Clarify the linkage between fish tissue monitoring and adaptive management response. b. Provide rationale as to why fish tissue selenium concentrations were dismissed in the effects analysis. ESRD/CEAA Page 458 October 2014

461 Frontier Oil Sands Mine Project ESRD and CEAA Responses Approvals i. Specifically, what management response actions will be triggered by exceedances of tissue chronic effects benchmarks. c. Discuss whether Teck commits to providing a formal adaptive management plan (which is linked to monitoring results) prior to construction. Response 89 a. Teck will apply an adaptive management approach to results it obtains from fish tissue monitoring. Teck will follow the overall strategies and adaptive management approach suggested by Allen and Gunderson (2011), Williams et al. (2009), and Williams and Brown (2012), as outlined in the response to ERCB Round 1 SIR 88a. These strategies are summarized as follows: engage stakeholders, particularly Aboriginal communities define the challenges and objectives set out management actions, including mitigation design a monitoring plan to evaluate the progress toward achieving objectives develop and refine predictive models implement the Project, including mitigation monitor and observe performance of operational and closure mitigation compare monitoring data with desired outcomes to evaluate the effectiveness of management and mitigation revise the design of the Project, including mitigation as necessary (cycle back) The iterative cycle of decision making, monitoring and assessment, repeated over the life of the Project, leads to a better understanding of Project dynamics and an adjusted management strategy based on what is learned. As noted in the response to ESRD/CEAA Round 2 SIR 170c, Teck will annually monitor fish tissue in the LSA, including specimens from the FHCL, receiving waters and reference sites. This monitoring will occur throughout Project construction, operation and closure. Pit lakes will be monitored during closure and post-closure periods. Teck will also periodically revisit predicted values using refined bioaccumulation factors (BAFs), as required. BAFs may be refined based on new fish tissue data or refined water quality modelling predictions. As additional information and monitoring data become available, the refined BAFs will be used to update and validate adaptive management inputs. Fish tissue chronic effects benchmarks (CEBs) for selenium and other metals will be revised, as warranted, based on recent literature, regional information and results of the monitoring programs. Teck will use these benchmarks to define fish tissue concentrations at which adaptive management actions may be triggered. October 2014 ESRD/CEAA Page 459

462 ESRD and CEAA Responses Approvals Frontier Oil Sands Mine Project b. Waterborne selenium concentrations predicted at closure and post-closure are not expected to result in selenium accumulation in tissues to levels of toxicological concern in resident fish species based on the updated fish tissue assessment for selenium in the pit lakes (presented in the response to ESRD/CEAA Round 1 SIR 115a). Fish tissue selenium concentrations were not dismissed in the effects analysis; rather, the effects assessment for selenium focused primarily on tissue uptake (as opposed to waterborne exposure). In fish, selenium is expected to affect reproduction due to accumulation and maternal transfer, as opposed to direct waterborne exposure (Chapman et al. 2010). As indicated in the response to ESRD/CEAA Round 1 SIR 115a, the aquatic life assessment for selenium considered the potential for teratogenesis (i.e., development of physical defects in the embryo) by predicting fish tissue selenium concentrations and comparing them to a tissue-based effects threshold for selenium. Predicted egg and ovary concentrations of selenium in the LSA were presented in Volume 5, Section , Pages 4-65 to 4-88 of the and revised in response to ESRD/CEAA Round 1 SIR 45a, Appendix 45a.7. These concentrations were below an egg and ovary tissue benchmark of 20 mg/kg dw. This benchmark was derived from a review by DeForest et al. (2011) of reproductive toxicity threshold studies for resident Canadian fish species; this benchmark is considered protective by the authors. Predicted egg and ovary concentrations were also below the toxicity value reported for embryo mortality in westslope cutthroat trout, and toxicity values reported for larval deformities in rainbow trout and northern pike. i. As described in the response to ESRD/CEAA Round 2 SIR 170c, average annual concentrations of selenium and other metals measured in small-bodied fish will be compared to tissue CEBs. Depending on the magnitude, extent and duration of measured fish tissue concentrations above CEBs, adaptive management actions might escalate to address the issue. As mentioned in the response to ESRD/CEAA Round 2 SIR 170c, potential management actions might include but are not limited to: further toxicological investigation of the implications of the tissue accumulation, in pit lakes, the FHCL and downstream watercourses initiation of small-bodied fish tissue monitoring in downstream watercourses mitigation and treatment of water quality in pit lakes and the FHCL If CEBs are not above guidelines, regular monitoring would continue. Other adaptive management strategies and responses are described in: Volume 5, Section , Page 4-97 and Section , Pages to of the the responses to ERCB Round 1 SIR 88a and SIR 89b ESRD/CEAA Page 460 October 2014

463 Frontier Oil Sands Mine Project ESRD and CEAA Responses Approvals c. Teck is committed to developing and implementing adaptive management frameworks for its operations. For example, Teck developed a Cumulative Effects Management Framework (CEMF) for its steel-making coal operations in the Elk River Valley, British Columbia. Based on Teck s experience with CEMFs, the outline of an adaptive management framework document for the Project (and specifically for water quality and aquatic health) could include: in-stream environmental management levels water quality and aquatic health modelling incorporation of water quality assessment into mine planning management actions aquatic effects monitoring program and site monitoring special studies applied research and development implementation and reporting Teck is committed to developing a formal adaptive management plan for the Project prior to its construction, operation and closure. The plan will help maintain water quality to support a healthy aquatic ecosystem and other water uses. Teck will draw on its experience with other developments as well as monitoring results and integrate this approach with frameworks that are under development in the oil sands region, including the Lower Athabasca Regional Plan (LARP) and the Joint Canada- Alberta Implementation Plan for Oil Sands Monitoring. REFERENCES Allen, C.R. and L.H. Gunderson Pathology and failure in the design and implementation of adaptive management. Journal of Environmental Management 92: Chapman, P.M., W.J. Adams, M.L. Brooks, C.G. Delos, S.N. Luoma, W.A. Maher, H.M. Ohlendorf, T.S. Presser and D.P. Shaw Ecological Assessment of Selenium in the Aquatic Environment. Society of Environmental Toxicology and Chemistry (SETAC). Pensacola, FL, USA. DeForest, D.K., G. Gilron, S.A. Armstrong and E.L. Robertson Species sensitivity distribution (SSD) evaluation for selenium in fish eggs: Considerations for development of a Canadian tissue based guideline. Integrated Environmental Assessment and Management 8: Williams, B.K. and E.D. Brown Adaptive Management: The U.S. Department of the Interior Applications Guide. Adaptive Management Working Group, U.S. Department of the Interior. Washington, DC. USA. Williams, B.K., R.C. Szaro and C.D. Shapiro Adaptive Management: The U.S. Department of the Interior Technical Guide. Adaptive Management Working Group, U.S. Department of the Interior. Washington, DC. USA. October 2014 ESRD/CEAA Page 461

464 ESRD and CEAA Responses Approvals Frontier Oil Sands Mine Project Question 90 Frontier Oil Sands Mine Project, Environmental Impact Statement (EIS), Volume 5, Section , Page Volume 1, ESRD/CEAA, Section 6, Approvals, Federal, Water Quality, SIR 172, Page 490 SIR response #172 relies on data from the Alberta and Canadian government programs. a. Discuss whether Teck will be conducting monitoring to track aerial deposition. b. Discuss whether Teck commits to sharing this data with stakeholders when it becomes available. Response 90 a. Teck completed a winter sampling survey for water quality and snowpack chemistry in February 2012, with additional winter sampling for snowpack chemistry completed in March These data will be combined with datasets from ESRD and Environment Canada, once available. Teck will use this data to track aerial deposition and validate water quality modelling predictions, as described in Volume 5, Section , Pages to b. Teck commits to share snow survey data with stakeholders; this includes survey data collected by Teck or other publically available data that Teck obtains. For results of the February 2012 sampling, see Appendix 90b.1. For results of the March 2014 sampling, see Appendix 90b.2. Question 91 Frontier Oil Sands Mine Project, Environmental Impact Statement (EIS), Volume 5, Appendix 4A, Section 4A.3, Page 4A-50 Volume 1, ESRD/CEAA, Section 6, Approvals, Federal, Water Quality, SIR 173, Page 492 EC has concerns that predictions for mercury in the aquatic environment have been underestimated by not including methylmercury increases associated with impoundment of the fish habitat compensation lake (FHCL). SIR response #173, Teck states that there would be difficulties in predicting and modeling mercury for the conceptual FHCL. Further consideration has been deferred to the fish habitat compensation planning process. EC notes that methylmercury increases in impounded lakes have been well studied, and the associated effects on biota, water, and sediment quality from creation of the FHCL should be considered as an additional environmental cost associated with this development. ESRD/CEAA Page 462 October 2014

465 Frontier Oil Sands Mine Project ESRD and CEAA Responses Approvals a. Discuss whether Teck commits to identifying and managing effects of methylmercury increases due to impoundment of the fish habitat compensation lake, through ongoing monitoring and adaptive management, with development of a formal plan prior to construction of the fish habitat compensation lake. Response 91 a. As indicated in the response to ESRD/CEAA Round 3 SIR 89c, adaptive management approaches will be developed and implemented for various components of the Project. The FHCL is one of these components; one or several management targets could be adopted for the FHCL, including maintaining concentrations of methylmercury in water and fish tissue below a specific level. As noted in the response to ESRD/CEAA Round 2 SIR 174a, and in the preamble to this question, methylmercury concentrations have not been modelled in the FHCL given that more detailed engineering has not yet been completed for the FHCL. Potential challenges in accurately modelling methylmercury concentrations may be addressed by gathering specific data about the location of the impoundment, including its chemical, physical and geomorphological characteristics, the resident vegetation and its water sources. Teck will periodically monitor water quality and fish tissue for several constituents of concern, including methylmercury. This data will be compared with data used to develop EIA predictions, and used, where applicable, to refine modelling results for the Project. Teck will then evaluate the refined modelling results to determine appropriate actions to achieve management targets. These might include, but are not limited to, the strategies described in response to ESRD/CEAA Round 1 SIR 424d and ESRD/CEAA Round 2 SIR 174a. The effectiveness of the mitigation strategies would then be evaluated through monitoring and refined modelling, as required. Teck commits to developing a formal adaptive management plan for the methylmercury concentrations in the FHCL prior to its construction and during its operation. October 2014 ESRD/CEAA Page 463

466 ESRD and CEAA Responses Approvals Frontier Oil Sands Mine Project Navigability Question 92 In response to SIR #182(b), the proponent states that adaptive management and environmental monitoring measures under the WMF include flow and water level monitoring of the Athabasca River and the PAD. a. Provide additional details on the flow and water level monitoring measures of the Athabasca River and the PAD proposed under the WMF. b. Explain how these measures will help ensure that effects to navigation in the Athabasca River and the PAD are negligible. Response 92 a. A list of key topics (under the headings Hydrology and Compliance and Biological/Social) identified for detailed monitoring plan designs is provided in the Phase 2 Framework Committee Report (Ohlson et al. 2010) for the Lower Athabasca River (see Section 9.5.1, Table 21, Page 121). The environmental impact assessment completed for the Project included the Water Management Framework (WMF) and concluded that effects of the Project on water levels in the Athabasca River and Peace-Athabasca Delta (PAD) are negligible. Teck will comply with the WMF, including required monitoring, and anticipates that specific monitoring requirements will be a condition of the anticipated EPEA approval for the Project. b. Initial investigations concluded that... the range of water management alternatives proposed in Phase 2 of the Athabasca River Water Management Framework will have insignificant impact on the navigation on the Lower Athabasca River (AECOM 2009, as referenced in Ohlson et al. 2010). Compliance with the WMF, including monitoring, requires that Project-related water withdrawals from the Athabasca River follow specific rules that balance social, environmental and economic interests, including navigability. REFERENCES AECOM Review of Water Management Alternatives on Water Depth in the Lower Athabasca River. Report prepared for the Cumulative Environmental Management Association and cited in Ohlson et al Ohlson, D., G. Long and T. Hatfield Phase 2 Framework Committee Report. Report submitted to Alberta Environment, Fisheries and Oceans Canada, and the Cumulative Environmental Management Association. January ESRD/CEAA Page 464 October 2014

467 Frontier Oil Sands Mine Project ESRD and CEAA Responses Approvals Human Health Question 93 SIR 199 (EIA Volume 1, Section , pp to 14-29, Teck s Jan 2013 Response, p , and Teck s Oct 2013 Response, pp ) Teck notes that polyacrylamide is not expected to be released during normal operations. Further information would be beneficial to assess: potential effects due to non-typical conditions at the Project site (e.g. leaks/spills, unexpected releases, run-off, flooding), downstream drinking water treatment capabilities, monitoring or verification plans, and triggers for additional sampling/analysis when unexpected releases occur. a. Confirm that, if polyacrylamide or related breakdown products are identified in the surface water during the on-going monitoring or due to an unexpected event, appropriate actions will be undertaken. b. Identify what concentrations will trigger a mitigative response and how will those triggers be established. c. Explain what actions will be taken and at what concentrations. d. Discuss how site-specific conditions (e.g., soil and surface water chemistry, typical moisture levels) could influence the rate of, and mechanism for polyacrylamide breakdown at the Frontier site. Response 93 a. Teck will take appropriate action if monitoring shows surface water concentrations of polyacrylamide or related breakdown products that could affect aquatic life. The potential for effects will be determined based on whether concentrations are greater than those associated with chronic toxicity in the receiving waters. b. Because polyacrylamide has been shown to have low toxicity to aquatic life (de Rosemond and Liber 2004; Beim and Beim 1994; Liber et al. 2005), the monitoring and development of trigger levels would more appropriately focus on related breakdown products, specifically the acrylamide monomer. Toxicity data are available for the monomer, and trigger levels could be developed should the monomer be detected in any seepage from the Project. Quebec, the European Union and the World Health Organization (WHO) have set drinking water guidelines for the protection of human health for the acrylamide monomer of 0.05 µg/l, 0.1 µg/l and 0.5 µg/l, respectively. These drinking water guidelines might serve as suitable receiving environment trigger levels because each guideline value is considered protective against ILCRs resulting from October 2014 ESRD/CEAA Page 465

468 ESRD and CEAA Responses Approvals Frontier Oil Sands Mine Project consumption of acrylamide monomer over a human lifetime (i.e., based on ILCR of 1 in 1 million, 1 in 500,000 and 1 in 100,000, respectively). Potential trigger levels and associated mitigation could include, for example: 0.05 µg/l as a trigger for further confirmatory sampling and more frequent monitoring 0.1 µg/l as a trigger for source investigation and mitigation (e.g., improved seepage interception or spill cleanup as appropriate) 0.5 µg/l as a trigger for source investigation and mitigation (e.g., improved seepage interception or spill cleanup as appropriate) and notification of downstream users (e.g., water use advisories) c. See the response to part b. d. Recent studies have shown that the toxicity of anionic polymers is derived mainly from changes in the physical characteristics of the water caused by application of the polymer rather than from direct physiological effects of the polymer on aquatic organisms (de Rosemond and Liber 2004; Weston et al. 2009; Acharya et al. 2010; Harford et al. 2011). For example, Acharya et al. (2010) and Harford et al. (2011) hypothesize that increased water viscosity from the addition of polymer might result in increased energy demands for locomotion and food filtering, thereby reducing an organisms available energy for reproduction and growth. Sublethal effect concentrations observed in these studies ranged from 14 mg/l to more than 200 mg/l for various aquatic species. The sublethal effects concentrations are much higher than the polymer concentrations expected to be associated with the Project, and the acrylamide monomer concentrations at the proposed trigger levels (i.e., less than 1 mg/l based on a monomer content of 0.05%). For details, see the response to part b. Polyacrylamides are commercially available as industrial flocculants that function by attracting soil particles and suspended materials. These materials bind to the polyacrylamide, creating a higher molecular weight aggregate that more readily settles out of solution (Liber at al. 2005; Entry et al. 2008). Flocculation capabilities are influenced by molecular weight and charge density, where greater molecular weight and charge density increases the probability of interparticle bond formation (Hu et al. 1996; Entry et al. 2002; Heller and Keren 2002). Current applications of polyacrylamide include the following (Barvenik 1994; Peng and Di 1994; Sojka and Entry 2000; Aguilar et al. 2005; Liber et al. 2005; Exon 2006; Entry et al. 2008; Krauth et al. 2008): use as a flocculant in the treatment of wastewater generated as part of mining, pulp and paper, municipal, textile and oil recovery operations use as a binding or thickening agent in food processing, personal care products and cosmetics use as an erosion control and prevention mechanism in agricultural and construction industries Polyacrylamide has long been used as a soil conditioner in agriculture where it has been shown to effectively stabilize soil aggregates and reduce soil erosion (Seybold 1994). It is a high-molecularweight, synthetic organic polymer that primarily interacts with the clay fraction of soils. Barvenik (1994) noted that although polyacrylamide is water soluble, it adsorbs to solids through several ESRD/CEAA Page 466 October 2014

469 Frontier Oil Sands Mine Project ESRD and CEAA Responses Approvals mechanisms, including electrostatic attraction or charge neutralization. It also bridges adjacent particles owing to its extremely large molecular dimensions, resulting in large aggregates or flocs. As a result, the fate of polyacrylamide in the environment is sorption to soil solids (which explains its use as a soil-binding agent for erosion control). Degradation of polyacrylamide is mainly through physical breakdown (i.e., physical shearing) and photodegradation (Barvenik 1994; Woodrow et al. 2008). The rate at which polyacrylamide is broken down by ultraviolet (UV) radiation and other mechanisms has been estimated at approximately 10% per year (Barvenik 1994; Entry et al. 2002), which equates to a degradation rate of day -1. Reductions in UV exposure (e.g., under snow cover or below the soil surface where UV light is attenuated or blocked) are expected to reduce the rate of polymer breakdown and make acrylamide accumulation even less likely. In comparison, the degradation rate of acrylamide in aerobic environments (such as those that will be present in open-air drying areas and process-affected waters in closed circuit operations) has been estimated as day -1 (U.S. EPA 2001, as cited in WBK 2001). Therefore, as noted in Volume 5, Section , Pages 4-19, accumulation of acrylamide is not expected to occur because the rate of acrylamide degradation is faster than its generation rate. If there are any changes in polymer and acrylamide degradation rates with temperature, they would be expected to co-vary (e.g., both rates would be expected to decrease by the same fraction with reductions in temperature) and the rate of acrylamide degradation would again be expected to remain faster than its generation rate. There are no known or suspected properties related to site-specific water chemistry or soil moisture conditions that would change this conclusion. REFERENCES Acharya, K., C. Schulman and M.H. Young Physiological response of Daphnia magna to linear anionic polyacrylamide: ecological implications for receiving waters. Water Air and Soil Pollution 212: Aguilar, M.I., J. Sáez, M. Lloréns, A. Solar, J.F. Ortuño, V. Meseguer and A. Fuentes Improvement of coagulation-flocculation process using anionic polyacrylamide as coagulant aid. Chemosphere 58: Barvenik, F.W Polyacrylamide characteristics related to soil applications. Soil Science 158: Beim, A.A. and A.W. Beim Comparative ecological-toxicological data on determination of maximum permissible concentrations (MPC) for several flocculants. Environmental Toxicology 18: de Rosemond, S.J.C. and K. Liber Wastewater treatment polymers identified as the toxic component of a diamond mine effluent. Environmental Toxicology and Chemistry 23: October 2014 ESRD/CEAA Page 467

470 ESRD and CEAA Responses Approvals Frontier Oil Sands Mine Project Entry, J.A., R.E. Sojka, M. Watwood and C. Ross Polyacrylamide preparations for protection of water quality threatened by agricultural runoff contaminants. Environmental Pollution 120: Entry, J.A., R.E. Sojka and B.J. Hicks Carbon and nitrogen stable isotope ratios can estimate anionic polyacrylamide degradation in soils. Geoderma 145: Exon, J.H A review of the toxicology of acrylamide. Journal of Toxicology and Environmental Health Part B: Critical Reviews 9(5): Harford, A.J., A.C. Hogan, D.R. Jones and R.A. van Dam Ecotoxicological assessment of a polyelectrolyte flocculant. Water Research 45: Heller, H. and R. Keren Anionic polyacrylamide polymers on rheological behavior of sodiummontmorillonite suspensions. Soil Science. Soc. Am. J. 66: Hu, X., Q. Luo and C. Wang Investigations on the state of water in a flocculated filter cake. Separation Science and Technology 31(13): Krauth, D.M., J.L. Bouldin and V.S. Green Evaluation of a polyacrylamide soil additive to reduce agriculture-associated contamination. Bull. Environ. Contam. Toxicol. 81: Liber, K., L. Weber and C. Lévesque Sublethal toxicity of two wastewater treatment polymers to lake trout fry (Salvelinus namaycush). Chemosphere 61: Peng, F.F. and P. Di Effect of multivalent salts-calcium and aluminum on the flocculation of kaolin suspension with anionic polyacrylamide. Journal of Colloid and Interface Science 164: Seybold, C.A Polyacrylamide review: Soil conditioning and environmental fate. Communications in Soil Science and Plant Analysis 25: Sojka, R.E. and J.A. Entry Influence of polyacrylamide application to soil on movement of microorganisms in runoff water. Environmental Pollution 108(3): U.S. EPA (United States Environmental Protection Agency) Integrated Risk Information System Online. Office of Research and Development, National Center for Environmental Assessment. Cincinnati, OH. Available at: Accessed: September WBK (WBK & Associates Inc.) Screening Evaluation and Risk Assessment of Acrylamide Impacts from Polymer-Amended Thickened Tailings Deposits. Report for Albian Sands Energy Inc. December Weston, D.P., R.D. Lentz, M.D. Cahn, R. Scott Ogle, A.K. Rothert and M.J. Lydy Toxicity of anionic polyacrylamide formulations when used for erosion control in agriculture. Journal of Environmental Quality 38: ESRD/CEAA Page 468 October 2014

471 Frontier Oil Sands Mine Project ESRD and CEAA Responses Approvals Woodrow, J.E., J.N. Seiber and G.C. Miller Acrylamide release resulting from sunlight irradiation of aqueous polyacrylamide/iron mixtures. Journal of Agriculture and Food Chemistry 56: Question 94 SIR 201 (EIA Volume 7, Section 2.7.1, p. 2-39, Teck s Jan 2013 Response, pp to 8-765, and Teck s Oct 2013 Response, pp addendum) Teck provided discussion of TRV selection and consideration of chemical interactions, and some information regarding proposed monitoring activities. However, if certain aspects of exposure pathways, COPC, and receptor selection approaches relevant to cumulative exposure were considered, this may result in a reduced level of uncertainty in the assessments conclusions. a. Explain why moose, grouse, and hare were selected as surrogates for all other species consumed, while other species commonly consumed by local aboriginal (e.g. waterfowl) were not included in the HHRA. Indicate whether the selection of game species also reflected those species most likely to be impacted by the Project, and was therefore protective to human health within the context of a multiple-pathway, cumulative assessment. b. Explain why Teck used dust level values for (non-industrial) passenger vehicle traffic and not site-specific dust concentrations that can be expected at sites with extensive (industrial) land use. c. It appears that Teck considered that 100% of an individual s exposure to each COPC came from the Project site without demonstrating that this is the case for all COPC. Since background exposures to some of the COPCs (e.g., via food, and water) were not considered, the use of a hazard quotient of 1 may lead to an underestimation of an individual s health risk to some of the COPCs. To be protective, a hazard quotient of less than 1 may be more appropriate. d. Explain the rationale for considering the exposure to each COPC and what other factors have been considered. Response 94 a. Moose, snowshoe hare and grouse were selected as surrogates to represent large and small mammals, and upland birds that are known to be consumed in the area based on data from Wein et al. (1989). As well, measured concentrations of trace metals in moose, snowshoe hare and grouse tissue were available from a Fort McKay traditional food study (Golder 2003). These concentrations were used to characterize baseline concentrations of metals in game meat. The Golder (2003) study does not provide metal concentrations in waterfowl meat, nor are measured concentrations available from other sampling programs in the oil sands region. As such, waterfowl were not assessed in the human health risk assessment (HHRA). October 2014 ESRD/CEAA Page 469

472 ESRD and CEAA Responses Approvals Frontier Oil Sands Mine Project Moose, hare and grouse were selected for the HHRA because they are commonly consumed by First Nations in the Wood Buffalo region. Exposure to these species was estimated by assuming that these animals would never leave the area. In other words, the moose, hare and grouse assessed in the HHRA were assumed to receive 100% of their dietary requirements near the Project area. With respect to the potential risks to human health, the game species selected in the HHRA reflect the species mostly likely to be impacted by the Project and thereby most likely to affect human health. Consumption rates for wild game were based on a combination of Health Canada s food ingestion rates for Canadian Aboriginal populations (Health Canada 2012) and data on the consumption frequency of wild game from Wein et al. (1989) for First Nations in the Wood Buffalo region. For example, the consumption rate for moose was calculated by multiplying the consumption frequency for moose by the total consumption rate for all wild game. The consumption frequencies of the various types of wild game need to sum to 100%. As such, inclusion of waterfowl reduces the relative portion and ingestion rates for the other (surrogate) animals in the HHRA exposure model. To fully address this SIR, the HHRA exposure model was revised to include waterfowl, and revised risk estimates are provided. A mallard was chosen to represent waterfowl. Based on Wein et al. (1989), it was assumed that waterfowl accounted for about 10% of total wild game consumption. The food consumption rates for all game animals were recalculated to reflect the addition of another category of wild game. These revised exposure rates are presented in Table 94a-1. Consumption rates were revised only for the resident and recreational group; game consumption was not evaluated for the worker group in the original HHRA or the revised assessment (see ESRD/CEAA Round 2 SIR 113a, Appendix 113a.1). Table 94a-1 Revised Wild Game Consumption Rates Resident and Recreational Groups Category # Occasions Consumed/ Year Percentage of Total Wild Game Consumed (%) Adjusted Consumption Rate (g/day) Infant Toddler Child Adolescent Adult Large mammals (moose) Small mammals (snowshoe hare) Upland birds (grouse) Waterfowl (mallard) Total MCFN has told Teck that it has concerns with the degree and manner with which MCFN s traditional knowledge and Aboriginal perspectives have been considered and incorporated by Teck, particularly in the assessment of impacts to MCFN s rights and culture. This response does not incorporate traditional knowledge. To this end, Teck acknowledges the need for further engagement regarding this SIR. Teck will revisit this SIR and conclusions made in it once the parties have pursued the collaborative process that Teck and MCFN are working to develop and as additional information is ESRD/CEAA Page 470 October 2014

473 Frontier Oil Sands Mine Project ESRD and CEAA Responses Approvals gathered. Teck will consider the food contamination study recently undertaken by MCFN and following the outcome of the collaborative process. ACFN has clearly stated that it has concerns with the degree and manner with which ACFN s traditional knowledge and Aboriginal perspectives have been considered and incorporated by Teck, particularly in the assessment of impacts to ACFN s rights and culture. Recognizing that additional work needs to be done, Teck has requested to meet with ACFN to co-create a process to address outstanding concerns, to revisit certain conclusions made by Teck in the and to work toward understanding and incorporating ACFN s traditional land use and traditional knowledge into the assessment in a meaningful way. Teck will update regulators on a regular basis about the progress of these discussions. Teck will not be filing responses to Round 3 SIRs that pertain to traditional knowledge or the assessment of impacts to ACFN s rights and culture with regulators until the parties have pursued the collaborative process referred to above, or until Teck and ACFN agree otherwise. Because of the addition of waterfowl, sediment was added to the multiple pathway exposure model to characterize exposure through sediment and benthic invertebrate ingestion. Sediment concentrations were based on measured data and predicted concentrations from the (specifically Volume 2, Section 5.3, Pages 5-26 to and Volume 5, Section 4.8, Pages to 4-115). Measured sediment concentrations used to estimate mallard exposures and predict benthic invertebrate concentrations are listed in Table 94a-2. Predicted benthic invertebrate concentrations are provided in Table 94a-3. Mallard consumption rates are estimated to be 0.23 kg-food/day, kg-soil/day and kgsediment/day based on a free metabolic rate of 314 kcal/day (Nagy et al. 1999). It was assumed that the mallard diet consisted of the following dietary apportionment: 20% browse, 40% benthic invertebrate and 40% aquatic plant (U.S. EPA 1993). The soil and sediment ingestion rate assumed that each of these media represented 3.3% (Beyer et al. 1994) of the mallard s diet. Predicted mallard tissue concentrations are provided in Table 94a-4. With the addition of mallards as a potential dietary item for the area residents and recreational users, risk quotients (RQ) and incremental lifetime cancer risks (ILCR) were recalculated for the resident and recreational receptor groups (see Tables 94a-5 to 94a-10). Except for cobalt, the predicted RQ or ILCR values decreased or stayed the same as a result of adding mallard consumption to the diet. The decrease in RQ and ILCR values is not unexpected because the predicted mallard meat concentrations are lower than the moose concentrations, and the moose consumption rate was reduced as a result of adding mallard consumption to the diet. The cobalt RQ values increased from 1.4 to 1.6 in the Base Case, Application Case and PDC, primarily because of a predicted tissue concentration in mallards (0.1 mg/kg) that is approximately three to eight times greater than the predicted tissue concentrations in moose (0.013 mg/kg), ruffed grouse (0.013 mg/kg) and snowshoe hare (0.031 mg/kg). Overall, the October 2014 ESRD/CEAA Page 471

474 ESRD and CEAA Responses Approvals Frontier Oil Sands Mine Project inclusion of mallards as a dietary item in the exposure assessment does not change the conclusions of the HHRA. Table 94a-2 Sediment Concentrations Used to Estimate Exposures for the Mallard and Predict Benthic Invertebrate Concentrations Chemical Existing Condition Base Case Measured Sediment Concentration [mg/kg] Application Case PDC Project Only PDC Incremental Pit Lake Pit Lake Incremental Aluminum (Al) 8.7E E E E E E E E-02 Antimony (Sb) 1.0E E E E E E E E-04 Arsenic (As) 9.5E E E E E E E E-04 Barium (Ba) 6.9E E E E E E E E-03 Beryllium (Be) 7.6E E E E E E E E+00 Boron (B) 5.5E E E E E E E E+00 Cadmium (Cd) 1.0E E E E E E E E-04 Chromium (Cr) 6.4E E E E E E E E-03 Chromium (CrVI) 5.3E E E E E E E E+00 Cobalt (Co) 2.1E E E E E E E E-03 Copper (Cu) 7.1E E E E E E E E-03 Lead (Pb) 4.4E E E E E E E E-03 Manganese (Mn) 8.3E E E E E E E E-03 Mercury (Hg) 1.8E E E E E E E E+00 Molybdenum (Mo) 3.4E E E E E E E E-02 Nickel (Ni) 1.7E E E E E E E E-03 Selenium (Se) 2.7E E E E E E E E+00 Silver (Ag) 2.6E E E E E E E E-03 Strontium (Sr) 6.4E E E E E E E E-04 Tin (Sn) 1.0E E E E E E E E-04 Vanadium (V) 5.6E E E E E E E E-03 Zinc (Zn) 5.1E E E E E E E E-02 7,12- Dimethylbenz(a)anthracene 1.1E E E E E E E E-06 Acenaphthene 5.2E E E E E E E E-10 Anthracene 2.0E E E E E E E E-06 Benzo(a)anthracene 1.3E E E E E E E E-05 Benzo(a)pyrene 1.5E E E E E E E E-06 Benzo(b)fluoranthene 1.9E E E E E E E E-07 Benzo(g,h,i)perylene 2.5E E E E E E E E-06 Benzo(k)fluoranthene 7.2E E E E E E E E-05 Chrysene 8.3E E E E E E E E-04 Cyclopenta(cd)pyrene 1.4E E E E E E E E-05 Dibenz(a,h)anthracene 4.3E E E E E E E E-05 Fluoranthene 1.3E E E E E E E E-04 Indeno(1,2,3 cd)pyrene 4.4E E E E E E E E-06 Phenanthrene 5.3E E E E E E E E-05 ESRD/CEAA Page 472 October 2014

475 Frontier Oil Sands Mine Project ESRD and CEAA Responses Approvals Table 94a-2 Sediment Concentrations Used to Estimate Exposures for the Mallard and Predict Benthic Invertebrate Concentrations (cont d) Chemical Existing Condition Base Case Measured Sediment Concentration [mg/kg] Application Case PDC Project Only PDC Incremental Pit Lake Pit Lake Incremental Pyrene 2.8E E E E E E E E-07 2-Chloronaphthalene 9.1E E E E E E E E-12 Aliphatic C 17-C E E E E E E E E-04 Aniline 3.7E E E E E E E E-07 Aromatic C 17-C E E E E E E E E-08 Aromatic C 9-C E E E E E E E E-05 Aromatic Ketones 5.9E E E E E E E E-01 Carboxylic Acids 6.7E E E E E E E E-02 Formaldehyde 4.5E E E E E E E E-08 Hexachloro-1,3 butadiene 1.2E E E E E E E E-10 Phenothiazine 1.3E E E E E E E E-03 NOTE: 0.0E+00 indicates that no changes were predicted. Table 94a-3 Predicted Benthic Invertebrate Concentrations Chemical Existing Condition Base Case Benthic Invertebrate Concentration [mg/kg-dry weight] Application Case PDC Project Only PDC Incremental Pit Lake Pit Lake Incremental Aluminum (Al) 7.8E E E E E E E E-02 Antimony (Sb) 9.0E E E E E E E E-04 Arsenic (As) 5.1E E E E E E E E-03 Barium (Ba) 3.7E E E E E E E E-02 Beryllium (Be) 4.1E E E E E E E E+00 Boron (B) NA NA NA NA NA NA NA NA Cadmium (Cd) 2.0E E E E E E E E-03 Chromium (Cr) 1.5E E E E E E E E-03 Chromium (CrVI) 1.2E E E E E E E E+00 Cobalt (Co) 1.1E E E E E E E E-02 Copper (Cu) 1.3E E E E E E E E-02 Lead (Pb) 1.7E E E E E E E E-03 Manganese (Mn) 4.5E E E E E E E E-03 Mercury (Hg) 7.3E E E E E E E E+00 Molybdenum (Mo) 1.8E E E E E E E E-02 Nickel (Ni) 9.2E E E E E E E E-02 Selenium (Se) 1.5E E E E E E E E+00 Silver (Ag) 2.3E E E E E E E E-03 Strontium (Sr) NA NA NA NA NA NA NA NA Tin (Sn) NA NA NA NA NA NA NA NA Vanadium (V) 3.0E E E E E E E E-02 October 2014 ESRD/CEAA Page 473

476 ESRD and CEAA Responses Approvals Frontier Oil Sands Mine Project Table 94a-3 Predicted Benthic Invertebrate Concentrations (cont d) Chemical Existing Condition Base Case Benthic Invertebrate Concentration [mg/kg-dry weight] Application Case PDC Project Only PDC Incremental Pit Lake Pit Lake Incremental Zinc (Zn) 1.7E E E E E E E E-02 7,12- Dimethylbenz(a)anthracene 1.1E E E E E E E E-05 Acenaphthene 6.0E E E E E E E E-08 Anthracene 1.9E E E E E E E E-05 Benzo(a)anthracene 1.1E E E E E E E E-04 Benzo(a)pyrene 1.4E E E E E E E E-05 Benzo(b)fluoranthene 1.8E E E E E E E E-06 Benzo(g,h,i)perylene 2.4E E E E E E E E-05 Benzo(k)fluoranthene 7.0E E E E E E E E-04 Chrysene 6.9E E E E E E E E-03 Cyclopenta(cd)pyrene 1.3E E E E E E E E-04 Dibenz(a,h)anthracene 4.1E E E E E E E E-04 Fluoranthene 1.2E E E E E E E E-03 Indeno(1,2,3 cd)pyrene 4.3E E E E E E E E-05 Phenanthrene 5.0E E E E E E E E-04 Pyrene 2.7E E E E E E E E-06 2-Chloronaphthalene 8.6E E E E E E E E-11 Aliphatic C 17-C E E E E E E E E+01 Aniline 1.5E E E E E E E E-07 Aromatic C 17-C E E E E E E E E-07 Aromatic C 9-C E E E E E E E E-03 Aromatic Ketones 3.8E E E E E E E E+00 Carboxylic Acids 9.5E E E E E E E E-02 Formaldehyde 3.8E E E E E E E E-08 Hexachloro-1,3 butadiene 5.4E E E E E E E E-10 Phenothiazine 2.3E E E E E E E E-01 NOTES: NA indicates literature-based uptake model data were not available to predict concentrations. 0.0E+00 indicates that no changes were predicted on an incremental basis. ESRD/CEAA Page 474 October 2014

477 Frontier Oil Sands Mine Project ESRD and CEAA Responses Approvals Table 94a-4 Predicted Mallard Meat Concentrations Used to Estimate Exposures and Risks for the Resident and Recreational Groups Chemical Existing Condition Base Case Application Case Concentration [mg/kg wet weight] PDC Project Only PDC Incremental Pit Lake Pit Lake Incremental Aluminum (Al) 1.2E E E E E E E E-01 Antimony (Sb) 4.7E E E E E E E E-04 Arsenic (As) 4.9E E E E E E E E-04 Barium (Ba) 2.5E E E E E E E E-04 Beryllium (Be) 2.1E E E E E E E E-05 Boron (B) 3.7E E E E E E E E-02 Cadmium (Cd) 1.0E E E E E E E E-02 Chromium (Cr) 2.8E E E E E E E E-02 Chromium (CrVI) 3.6E E E E E E E E-03 Cobalt (Co) 1.0E E E E E E E E-05 Copper (Cu) 1.4E E E E E E E E-03 Lead (Pb) 6.1E E E E E E E E-04 Manganese (Mn) 8.2E E E E E E E E-01 Mercury (Hg) 1.2E E E E E E E E+00 Molybdenum (Mo) 5.1E E E E E E E E-04 Nickel (Ni) 3.1E E E E E E E E-04 Selenium (Se) 1.1E E E E E E E E+00 Silver (Ag) 2.4E E E E E E E E-04 Strontium (Sr) 1.2E E E E E E E E-01 Tin (Sn) 3.0E E E E E E E E-07 Vanadium (V) 3.2E E E E E E E E-06 Zinc (Zn) 3.5E E E E E E E E+00 7,12- Dimethylbenz(a)anthra cene 6.1E E E E E E E E-10 Acenaphthene 3.5E E E E E E E E-06 Anthracene 2.6E E E E E E E E-06 Benzo(a)anthracene 3.1E E E E E E E E-05 Benzo(a)pyrene 1.5E E E E E E E E-06 Benzo(b)fluoranthene 3.1E E E E E E E E-05 Benzo(g,h,i)perylene 4.3E E E E E E E E-06 Benzo(k)fluoranthene 5.4E E E E E E E E-06 Chrysene 5.9E E E E E E E E-06 Cyclopenta(cd)pyrene 1.7E E E E E E E E-09 Dibenz(a,h)anthracene 2.6E E E E E E E E-06 Fluoranthene 8.0E E E E E E E E-05 Indeno(1,2,3 cd)pyrene 2.2E E E E E E E E-05 Phenanthrene 1.2E E E E E E E E-06 Pyrene 5.8E E E E E E E E-06 2-Chloronaphthalene 9.5E E E E E E E E-10 Aliphatic C 17-C E E E E E E E E-02 October 2014 ESRD/CEAA Page 475

478 ESRD and CEAA Responses Approvals Frontier Oil Sands Mine Project Table 94a-4 Predicted Mallard Meat Concentrations Used to Estimate Exposures and Risks for the Resident and Recreational Groups (cont d) Chemical Existing Condition Base Case Application Case Concentration [mg/kg wet weight] PDC Project Only PDC Incremental Pit Lake Pit Lake Incremental Aniline 2.7E E E E E E E E-07 Aromatic C 17-C E E E E E E E E-05 Aromatic C 9-C E E E E E E E E-05 Aromatic Ketones 1.8E E E E E E E E-04 Carboxylic Acids 1.0E E E E E E E E-04 Formaldehyde 6.9E E E E E E E E-05 Hexachloro-1,3 butadiene 4.1E E E E E E E E-06 Phenothiazine 3.9E E E E E E E E-06 Table 94a-5 Recalculated Chronic, Multiple Pathway, Non-Carcinogenic Risk Quotients for the Residential Group (Revised Table 113a-24) Metals COPC Existing Condition Revised HHRA Risk Quotients 1 (Round 2 SIR 113a, Appendix 113a.1) Base Case Application Case PDC Existing Condition Recalculated Risk Quotients 1 (with Mallard Consumption Added) Base Case Application Case Aluminum (Al) 7.4E E E E E E E E-01 Antimony (Sb) 2.2E E E E E E E E-01 Barium (Ba) 7.2E E E E E E E E-02 Beryllium (Be) 1.1E E E E E E E E-02 Boron (B) 4.1E E E E E E E E-01 Cadmium (Cd) 3.7E E E E E E E E-01 Chromium (Cr) 3.1E E E E E E E E-03 Chromium (CrVI) 2.9E E E E E E E E-01 Cobalt (Co) 1.4E E E E E E E E+00 Copper (Cu) 2.0E E E E E E E E-01 Lead (Pb) 6.6E E E E E E E E-01 Manganese (Mn) 2.3E E E E E E E E+00 Mercury (Hg) 3.5E E E E E E E E-01 Methyl mercury (MeHg) 6.4E E E E E E E E+00 Molybdenum (Mo) 2.9E E E E E E E E-01 Nickel (Ni) 8.7E E E E E E E E-02 Selenium (Se) 3.9E E E E E E E E-01 Silver (Ag) 4.5E E E E E E E E-02 Strontium (Sr) 2.6E E E E E E E E-01 Tin (Sn) 1.5E E E E E E E E-02 Vanadium (V) 6.9E E E E E E E E-01 Zinc (Zn) 8.3E E E E E E E E-01 PDC ESRD/CEAA Page 476 October 2014

479 Frontier Oil Sands Mine Project ESRD and CEAA Responses Approvals Table 94a-5 Recalculated Chronic, Multiple Pathway, Non-Carcinogenic Risk Quotients for the Residential Group (Revised Table 113a-24) (cont d) PAHs COPC Existing Condition Revised HHRA Risk Quotients 1 (Round 2 SIR 113a, Appendix 113a.1) Base Case Application Case PDC Existing Condition Recalculated Risk Quotients 1 (with Mallard Consumption Added) Base Case Application Case Pyrene 4.8E E E E E E E E-03 VOCs 2-Chloronaphthalene 1.4E E E E E E E E-08 Aliphatic C 17-C 34 group 7.1E E E E E E E E-02 Aniline 2.9E E E E E E E E-03 Aromatic C 17-C 34 group Aromatic C 9-C 16 group Aromatic Ketones group 4.3E E E E E E E E E E E E E E E E E E E E E E E E-02 Formaldehyde 1.1E E E E E E E E-02 Phenothiazine 1.2E E E E E E E E-01 Mixtures 2 Gastrointestinal toxicants 3.1E E E E E E E E-01 Hepatotoxicants 1.7E E E E E E E E+00 Neurotoxicants 1.1E E E E E E E E+01 Renal toxicants 1.6E E E E E E E E+00 Reproductive and developmental toxicants 9.3E E E E E E E E+01 NOTES: 1 An RQ equal to or less than 1.0 signifies that the estimated exposure is equal to or less than the exposure limit. Values in bold indicate an RQ greater than 1.0. With scientific notation, any value expressed to the negative power (i.e., E-x) shows that predicted exposures were less than the exposure limit; whereas, a value expressed to the positive power (i.e., E+x) shows exposure estimates are above the exposure limit. 2 Individual constituents of the chemical mixtures are identified in the (see Volume 7, Section 2.7.3, Table 2-15, Pages 2-50 to 2-51). Note that addition of the individual RQ values provided in the above table for a mixture s chemical constituents might not equate to the RQ value provided for the mixture because the RQ values in the table represent the highest RQ for each lifestyle category regardless of the location at which it occurred. PDC October 2014 ESRD/CEAA Page 477

480 ESRD and CEAA Responses Approvals Frontier Oil Sands Mine Project Table 94a-6 Recalculated Chronic, Multiple Pathway, Non-Carcinogenic Risk Quotients for the Recreational Group Metals COPC Revised HHRA Risk Quotients 1 (Round 2, SIR 113a, Appendix 113a.1) Existing Condition Base Case Application Case PDC Existing Condition Recalculated Risk Quotients 1 (with Mallard Consumption Added) Base Case Application Case Aluminum (Al) 4.9E E E E E E E E-01 Antimony (Sb) 1.3E E E E E E E E-01 Barium (Ba) 1.6E E E E E E E E-02 Beryllium (Be) 6.7E E E E E E E E-03 Boron (B) 7.1E E E E E E E E-02 Cadmium (Cd) 2.3E E E E E E E E-01 Chromium (Cr) 2.5E E E E E E E E-03 Chromium (CrVI) 2.6E E E E E E E E-01 Cobalt (Co) 5.6E E E E E E E E-01 Copper (Cu) 1.1E E E E E E E E-01 Lead (Pb) 5.2E E E E E E E E-01 Manganese (Mn) 2.6E E E E E E E E-01 Mercury (Hg) 1.5E E E E E E E E-01 Methyl mercury (MeHg) 3.2E E E E E E E E+00 Molybdenum (Mo) 1.4E E E E E E E E-01 Nickel (Ni) 3.4E E E E E E E E-02 Selenium (Se) 2.5E E E E E E E E-01 Silver (Ag) 7.6E E E E E E E E-03 Strontium (Sr) 3.0E E E E E E E E-02 Tin (Sn) 1.5E E E E E E E E-02 Vanadium (V) 5.1E E E E E E E E-01 Zinc (Zn) 7.2E E E E E E E E-01 PAHs Pyrene 2.5E E E E E E E E-04 VOCs 2-Chloronaphthalene 3.4E E E E E E E E-08 Aliphatic C 17-C 34 group 5.4E E E E E E E E-02 Aniline 5.4E E E E E E E E-04 Aromatic C 17-C 34 group 2.3E E E E E E E E-04 Aromatic C 9-C 16 group 1.7E E E E E E E E-03 Aromatic Ketones group 3.9E E E E E E E E-03 Formaldehyde 3.2E E E E E E E E-02 Phenothiazine 1.4E E E E E E E E-03 PDC ESRD/CEAA Page 478 October 2014

481 Frontier Oil Sands Mine Project ESRD and CEAA Responses Approvals Table 94a-6 Recalculated Chronic, Multiple Pathway, Non-Carcinogenic Risk Quotients for the Recreational Group (cont d) Mixtures 2 COPC Gastrointestinal toxicants Revised HHRA Risk Quotients 1 (Round 2, SIR 113a, Appendix 113a.1) Existing Condition Base Case Application Case PDC Existing Condition Recalculated Risk Quotients 1 (with Mallard Consumption Added) Base Case Application Case 2.7E E E E E E E E-01 Hepatotoxicants 1.0E E E E E E E E+00 Neurotoxicants 4.7E E E E E E E E+00 Renal toxicants 9.2E E E E E E E E-01 Reproductive and developmental toxicants 4.9E E E E E E E E+00 NOTES: 1 An RQ equal to or less than 1.0 signifies that the estimated exposure is equal to or less than the exposure limit. Values in bold indicate an RQ greater than 1.0. With scientific notation, any value expressed to the negative power (i.e., E-x) shows that predicted exposures were less than the exposure limit; whereas, a value expressed to the positive power (i.e., E+x) shows exposure estimates are above the exposure limit. 2 Individual constituents of the chemical mixtures are identified in the (see Volume 7, Section 2.7.3, Table 2-15, Pages 2-50 to 2-51). Note that addition of the individual RQ values provided in the above table for a mixture s chemical constituents might not equate to the RQ value provided for the mixture because the RQ values in the table represent the highest RQ for each lifestyle category regardless of the location at which it occurred. PDC Table 94a-7 Chronic Multiple Pathway Risk Quotients for the Pit Lake Scenario, Residential Group (Revised Table 113a-30) Metals COPC Revised HHRA Risk Quotients 1 (Round 2, SIR 113a, Appendix 113a.1) Recalculated HHRA Risk Quotients 1 (with Mallard Consumption Added) Aluminum (Al) 7.6E E-01 Antimony (Sb) 3.3E E-01 Barium (Ba) 7.3E E-02 Beryllium (Be) 1.2E E-02 Boron (B) 4.2E E-01 Cadmium (Cd) 4.2E E-01 Chromium (Cr) 4.2E E-03 Chromium (CrVI) 9.0E E-01 Cobalt (Co) 1.4E E+00 Copper (Cu) 2.1E E-01 Lead (Pb) 8.2E E-01 Manganese (Mn) 2.3E E+00 Mercury (Hg) 3.6E E-01 Methyl mercury (MeHg) 7.4E E+00 Molybdenum (Mo) 3.6E E-01 Nickel (Ni) 8.8E E-02 Selenium (Se) 4.4E E-01 Silver (Ag) 5.1E E-02 October 2014 ESRD/CEAA Page 479

482 ESRD and CEAA Responses Approvals Frontier Oil Sands Mine Project Table 94a-7 Chronic Multiple Pathway Risk Quotients for the Pit Lake Scenario, Residential Group (Revised Table 113a-30) (cont d) COPC Revised HHRA Risk Quotients 1 (Round 2, SIR 113a, Appendix 113a.1) Recalculated HHRA Risk Quotients 1 (with Mallard Consumption Added) Strontium (Sr) 2.6E E-01 Tin (Sn) 1.5E E-02 Vanadium (V) 7.2E E-01 Zinc (Zn) 8.6E E-01 PAHs Pyrene 1.2E E-03 VOCs 2-Chloronaphthalene 3.1E E-08 Aliphatic C 17-C 34 group 2.5E E-02 Aniline 3.5E E-03 Aromatic C 17-C 34 group 1.9E E-04 Aromatic C 9-C 16 group 3.8E E-02 Aromatic Ketones 5.8E E-02 Formaldehyde 2.4E E-02 Phenothiazine 2.3E E-01 Mixtures 2 Gastrointestinal toxicants 9.3E E-01 Hepatotoxicants 2.0E E+00 Neurotoxicants 1.2E E+01 Renal toxicants 1.7E E+00 Reproductive and Developmental Toxicants 1.0E E+01 NOTES: 1 Values in bold signify the estimated exposure is equal to or less than the exposure limit. 2 Individual constituents of the chemical mixtures are identified in the (see Volume 7, Section 2.7.3, Table 2-15, Pages 2-50 to 2-51). Note that addition of the individual RQ values provided in the above table for a mixture s chemical constituents might not equate to the RQ value provided for the mixture because the RQ values in the table represent the highest RQ for each lifestyle category regardless of the location at which it occurred. Table 94a-8 Recalculated Chronic Multiple Pathway Incremental Lifetime Cancer Risks for the Residential Group (Revised Table 113a-27) COPC Revised HHRA ILCRs (per 100,000) (Round 2 SIR 113a, Appendix 113a.1) Recalculated HHRA ILCRs (per 100,000) (with Mallard Consumption Added) Project PDC Incremental Project PDC Incremental Arsenic 1.5E E E E-01 Benzo(a)pyrene 4.1E E E E-01 Hexachloro-1,3 butadiene 3.9E E E E-02 NOTE: An ILCR equal to or less than 1.0 signifies an ILCR that is below the benchmark ILCR of 1.0 in 100,000 (i.e., within the generally accepted limit deemed to be protective of public health). With scientific notation, any value expressed to the negative power (i.e., E-x) shows that predicted exposures were less than the exposure limit; whereas, a value expressed to the positive power (i.e., E+x) shows exposure estimates greater than the exposure limit. ESRD/CEAA Page 480 October 2014

483 Frontier Oil Sands Mine Project ESRD and CEAA Responses Approvals Table 94a-9 Recalculated Chronic Multiple Pathway Incremental Lifetime Cancer Risks for the Recreational Group (Revised Table 113a-29) COPC Revised HHRA ILCRs (per 100,000) (Round 2 SIR 113a, Appendix 113a.1) Recalculated HHRA ILCRs (per 100,000) (with Mallard Consumption Added) Project PDC Incremental Project PDC Incremental Arsenic 1.5E E E E-01 Benzo(a)pyrene 4.0E E E E-01 Hexachloro-1,3 butadiene 3.9E E E E-02 NOTE: An ILCR equal to or less than 1.0 signifies an ILCR that is below the benchmark ILCR of 1.0 in 100,000 (i.e., within the generally accepted limit deemed to be protective of public health). With scientific notation, any value expressed to the negative power (i.e., E-x) shows that predicted exposures were less than the exposure limit; whereas, a value expressed to the positive power (i.e., E+x) shows exposure estimates greater than the exposure limit. Table 94a-10 Recalculated Chronic Multiple Pathway Incremental Lifetime Cancer Risks for the Pit Lake Scenario, Residential Group (Revised Table 113a-31) COPC Revised HHRA ILCRs (per 100,000) (Round 2 SIR 113, Appendix 113a.1) Recalculated HHRA ILCRs (per 100,000) (with Mallard Consumption Added) Arsenic 4.0E E-01 Benzo(a)pyrene 6.9E E-01 Hexachloro-1,3 butadiene 3.9E E-02 NOT E: An ILCR equal to or less than 1.0 signifies an ILCR that is below the benchmark ILCR of 1.0 in 100,000 (i.e., within the generally accepted limit deemed to be protective of public health). With scientific notation, any value expressed to the negative power (i.e., E- x) shows that predicted exposures were less than the exposure limit; whereas, a value expressed to the positive power (i.e., E+x) shows exposure estimates greater than the exposure limit. b. In its guidance on conducting preliminary quantitative risk assessments, Health Canada (2010a) states: When [inhalation of fugitive dust] is included in a [preliminary quantitative risk assessment], an average airborne concentration of respirable ( 10 µm aerodynamic diameter) particulate matter should be assumed to be 0.76 µg/m 3 (based on US EPA, 1992). For situations where significant vehicle traffic on contaminated unpaved surfaces is a concern, such traffic can generate considerably greater suspended dust levels than that on paved surfaces. Dust levels from unpaved roads vary according to climatic conditions, traffic levels, and the texture and nature of the roadsurface material (Claiborn et al., 1995). A reasonable dust level created by vehicle traffic on unpaved roads is 250 µg/m 3 (downwind side of the road) (Claiborn et al., 1995). Similarly, in its guidance on detailed quantitative risk assessments, Health Canada (2010b) states: In addition to the chemical concentration in airborne particulate, the amount of respirable airborne particulate (i.e. PM 10, particulate matter with an aerodynamic diameter 10 μm) present in the air must also be known to evaluate exposure through this medium, either by direct measurement or by estimation. In the absence of site-specific data, a typical airborne particulate October 2014 ESRD/CEAA Page 481

484 ESRD and CEAA Responses Approvals Frontier Oil Sands Mine Project matter concentration of 0.76 μg/m 3 may be assumed for most sites (HC, 2010b: based on U.S. EPA, 1992a) or a concentration of 250 μg/m 3 for sites with vehicle traffic on contaminated unpaved surfaces (HC, 2010b: based on Claiborn et al., 1995). The HHRA conducted for the Project to followed Health Canada guidance by assuming a background dust level of 0.76 µg/m 3 for the residential and recreational receptors, and a dust level of 250 µg/m 3 for the workers (see Volume 7, Appendix 2B1, Section 2B1.3, Pages 2B1-8 to 2B1-9). In light of Teck s plan to mitigate dust, the HHRA assumed that the background dust levels at the residential and recreational locations would be similar to average (or typical) concentrations. Dust mitigation measures for the Project include selecting appropriate road materials for mine haul roads, limiting vehicle speeds on haul roads, surface watering (or equivalent) of haul roads, using thin-lift drying tailings technology, and progressively reclaiming and temporarily vegetating disturbed lands (see Volume 4, Section , Page 3-42). To fully address this SIR, the HHRA was rerun using the 250 µg/m 3 dust level at the residential and recreational locations. The revised RQ values are compared to the RQs that were based on the lower dust levels (see Table 94b-1 and Table 94b-2 for the resident and recreational groups, respectively). Similarly, revised ILCRs are compared to the ILCRs that were based on the lower dust levels (see Table 94b-3 and Table 94b-4 for the resident and recreational group, respectively). As shown in Tables 94b-1 to 94b-4, the higher dust concentration (250 µg/m 3 ) does not materially affect the predicted health risks for the resident and recreational groups. Therefore, the conclusions of the HHRA remain unchanged. Table 94b-1 Recalculated Chronic Multiple Pathway Risk Quotients for the Residential Group Metals COPC Base Case 2013 HHRA Risk Quotients 1 Risk Quotients based on New Dust Level Application Case PDC Base Case Application Case Aluminum (Al) 7.4E E E E E E-01 Antimony (Sb) 2.2E E E E E E-01 Barium (Ba) 7.2E E E E E E-02 Beryllium (Be) 1.1E E E E E E-02 Boron (B) 4.2E E E E E E-01 Cadmium (Cd) 3.9E E E E E E-01 Chromium (Cr) 3.1E E E E E E-03 Chromium (CrVI) 7.2E E E E E E-01 Cobalt (Co) 1.4E E E E E E+00 Copper (Cu) 2.0E E E E E E-01 Lead (Pb) 6.7E E E E E E-01 Manganese (Mn) 2.3E E E E E E+00 PDC ESRD/CEAA Page 482 October 2014

485 Frontier Oil Sands Mine Project ESRD and CEAA Responses Approvals Table 94b-1 Recalculated Chronic Multiple Pathway Risk Quotients for the Residential Group (cont d) COPC Base Case 2013 HHRA Risk Quotients 1 Risk Quotients based on New Dust Level Application Case PDC Base Case Application Case Mercury (Hg) 3.6E E E E E E-01 Methyl mercury (MeHg) 7.4E E E E E E+00 Molybdenum (Mo) 3.1E E E E E E-01 Nickel (Ni) 8.8E E E E E E-02 Selenium (Se) 4.1E E E E E E-01 Silver (Ag) 4.5E E E E E E-02 Strontium (Sr) 2.6E E E E E E-01 Tin (Sn) 1.5E E E E E E-02 Vanadium (V) 7.1E E E E E E-01 Zinc (Zn) 8.3E E E E E E-01 PAHs Pyrene 1.1E E E E E E-03 VOCs 2-Chloronaphthalene 2.9E E E E E E-08 Aliphatic C 17-C 34 group 2.4E E E E E E-02 Aniline 3.5E E E E E E-03 Aromatic C 17-C 34 group 2.9E E E E E E-04 Aromatic C 9-C 16 group 3.7E E E E E E-02 Aromatic Ketones group 5.7E E E E E E-02 Formaldehyde 2.3E E E E E E-02 Phenothiazine 2.3E E E E E E-01 Mixtures Gastrointestinal toxicants 7.6E E E E E E-01 Hepatotoxicants 1.8E E E E E E+00 Neurotoxicants 1.2E E E E E E+01 Renal toxicants 1.6E E E E E E+00 Reproductive and developmental toxicants 1.0E E E E E E+01 NOTES: 1 From the response to ESRD/CEAA Round 2 SIR 113a, Appendix 113a.1, Table 113a-24. PDC October 2014 ESRD/CEAA Page 483

486 ESRD and CEAA Responses Approvals Frontier Oil Sands Mine Project Table 94b-2 Recalculated Chronic Multiple Pathway Risk Quotients for the Recreational Group Metals COPC Base Case 2013 HHRA Risk Quotients 1 Risk Quotients based on New Dust Level Application Case PDC Base Case Application Case Aluminum (Al) 4.9E E E E E E-01 Antimony (Sb) 1.2E E E E E E-01 Barium (Ba) 1.6E E E E E E-02 Beryllium (Be) 6.8E E E E E E-03 Boron (B) 7.2E E E E E E-02 Cadmium (Cd) 2.4E E E E E E-01 Chromium (Cr) 2.5E E E E E E-03 Chromium (CrVI) 4.8E E E E E E-01 Cobalt (Co) 5.6E E E E E E-01 Copper (Cu) 1.1E E E E E E-01 Lead (Pb) 5.2E E E E E E-01 Manganese (Mn) 2.6E E E E E E-01 Mercury (Hg) 1.6E E E E E E-01 Methyl mercury (MeHg) 3.7E E E E E E+00 Molybdenum (Mo) 1.5E E E E E E-01 Nickel (Ni) 3.5E E E E E E-02 Selenium (Se) 2.6E E E E E E-01 Silver (Ag) 7.6E E E E E E-03 Strontium (Sr) 3.0E E E E E E-02 Tin (Sn) 1.5E E E E E E-02 Vanadium (V) 5.2E E E E E E-01 Zinc (Zn) 7.2E E E E E E-01 PAHs Pyrene 9.5E E E E E E-04 VOCs 2-Chloronaphthalene 2.8E E E E E E-08 Aliphatic C 17-C 34 group 2.2E E E E E E-02 Aniline 6.9E E E E E E-04 Aromatic C 17-C 34 group 2.5E E E E E E-04 Aromatic C 9-C 16 group 5.3E E E E E E-03 Aromatic Ketones group 4.7E E E E E E-02 Formaldehyde 1.7E E E E E E-03 Phenothiazine 2.8E E E E E E-02 Mixtures Gastrointestinal toxicants 4.9E E E E E E-01 Hepatotoxicants 1.0E E E E E E+00 Neurotoxicants 5.2E E E E E E+00 PDC ESRD/CEAA Page 484 October 2014

487 Frontier Oil Sands Mine Project ESRD and CEAA Responses Approvals Table 94b-2 Recalculated Chronic Multiple Pathway Risk Quotients for the Recreational Group (cont d) COPC Base Case 2013 HHRA Risk Quotients 1 Risk Quotients based on New Dust Level Application Case PDC Base Case Application Case Renal toxicants 9.2E E E E E E-01 Reproductive and developmental toxicants 5.4E E E E E E+00 NOTES: 1 From the response to ESRD/CEAA Round 2 SIR 113a, Appendix 113a.1, Table 113a-26. PDC Table 94b-3 Recalculated Chronic Multiple Pathway Incremental Lifetime Cancer Risks for the Residential Group COPC ILCR based on New Dust Level (per 100,000) 2013 HHRA ILCRs 1 (per 100,000) Project PDC Incremental Project PDC Incremental Arsenic 1.5E E E E-01 Benzo(a)pyrene 4.1E E E E-01 Hexachloro-1,3 butadiene 3.9E E E E-02 NOTES: 1 From the response to ESRD/CEAA Round 2 SIR 113a, Appendix 113a.1, Table 113a-27. Table 94b-4 Recalculated Chronic Multiple Pathway Incremental Lifetime Cancer Risks for the Recreational Group COPC ILCR based on New Dust Level (per 100,000) 2013 HHRA ILCRs 1 (per 100,000) Project PDC Incremental Project PDC Incremental Arsenic 1.5E E E E-01 Benzo(a)pyrene 4.0E E E E-01 Hexachloro-1,3 butadiene 3.9E E E E-02 NOTES: 1 From ESRD/CEAA Round 2 SIR 113a, Appendix 113a.1, Table 113a-29. c. The response to ESRD/CEAA Round 2 SIR 201 focused on chemicals potentially emitted or released by the Project for which no exposure limits could be identified, based on the selection criteria set out in the HHRA (see Volume 7, Section 2.7.1, Page 2-39). Chemicals potentially emitted or released by the Project for which scientifically defensible, health-based exposure limits are available were quantitatively assessed as chemicals of potential concern (COPC) in the HHRA on a cumulative basis. The HHRA considered all relevant routes of exposure, including potential background sources. A benchmark value of one (i.e., hazard or risk quotient = 1.0) was considered acceptable for risks predicted from multiple pathways of exposure (i.e., air, oral and dermal route). Although CCME October 2014 ESRD/CEAA Page 485

488 ESRD and CEAA Responses Approvals Frontier Oil Sands Mine Project (1996, 2006) used a hazard quotient (HQ) less than one to characterize acceptable risks for noncarcinogenic chemicals, this was done to derive soil quality guidelines. However, these guidelines were derived for specific and individual pathways of exposure (e.g., soil ingestion). The concept is based on a soil allocation factor (SAF) of 20% that allows for 80% of the remaining tolerable incremental exposure to be reserved for other media (i.e., food, air, water and consumer products). The default value of 20% is used to apportion only 20% of the residual tolerable daily intake (RTDI) to soils when deriving soil remediation guidelines. Health Canada (2012) states that a target HQ of one is acceptable in a detailed quantitative risk assessment (DQRA) if background exposures have been quantified. Similarly, Alberta Environment (2010) states that if assumptions in an HHRA are sufficiently conservative, then hazard indices or exposure ratios less than unity, based on all sources of exposure, signify negligible potential for adverse effect. Other agencies offer similar guidance, for example: Alberta Health (2011) recommends an exposure ratio (ER, equivalent to an HQ) value of one be used as a benchmark when conducting HHRAs as part of EIAs in Alberta. Superfund guidance from the United States Environmental Protection Agency (U.S. EPA) also suggests that an HQ less than or equal to one is considered health-protective for non-carcinogens (U.S. EPA 1989; U.S. EPA OSW 2005). Background exposures can be an important consideration in setting HQ benchmarks. The U.S. EPA acknowledges that non-cancer effects do not distinguish between exposures from anthropogenic versus non-anthropogenic sources. In certain cases, a HQ may be adjusted downward to account for any exposure that individuals might have from non-assessed sources. The multiple pathway exposure model used to assess potential health effects of the Project incorporated exposures from multiple routes (e.g., air, soil, food and water), including background exposures. Therefore, a HQ (or RQ) of one was deemed reasonable for the HHRA completed for the Project. d. The response to ESRD/CEAA Round 2 SIR 201 evaluated the potential health risks for chemicals that were not quantitatively evaluated in the HHRA by comparing predicted air concentrations to effects screening levels (ESLs) from the Texas Commission on Environmental Quality (TCEQ). As described in the response to ESRD/CEAA Round 2 SIR 201, limited, if any, supporting documentation is available for many of the ESLs. As such, the specific basis and scientific merit of these limits remains unknown. Chronic HQs associated with predicted long-term air concentrations are provided in Table 94d-1 for chemicals evaluated in ESRD/CEAA Round 2 SIR 201. To account for other possible routes of exposure, the HQs for these chemicals are compared to a benchmark of 0.2. Hazard quotients are presented only for chronic or long-term exposures; acute or short-term exposures are not considered relevant when assessing multiple routes of exposure (i.e., it is appropriate to characterize short-term health risks using a HQ benchmark of 1.0). As shown in Table 94d-1, predicted HQ values are greater than 0.2 for pyrene, the aliphatic C 17 -C 34 group, the aromatic C 17 -C 34 group, benzaldehyde, mercaptans and thiophenes. Predicted HQ values for the remaining chemicals were all less than 0.2. ESRD/CEAA Page 486 October 2014

489 Frontier Oil Sands Mine Project ESRD and CEAA Responses Approvals For chemicals with HQ values greater than 0.2, the question becomes whether they should be assessed through multiple exposure pathways (i.e., in addition to the inhalation pathway). As described in Volume 7, Section 2.6.2, Pages 2-26 to 2-36, potential health risks associated with possible secondary pathways were assessed for those COPCs emitted by the Project that, although emitted into air, could potentially persist or accumulate in sufficient quantities for people to be exposed via soil, food or water. Identifying which chemicals should be evaluated in the multiple exposure pathway assessment proceeded step-wise, as follows: Step 1: The chemicals physical-chemical properties (i.e., molecular weight, Henry s Law Constant, vapour pressure) were compared with established criteria for volatility. Step 2: For COPC that were identified as volatile, the Log Kow values were evaluated to determine the chemical s potential to bioaccumulate. Step 3: COPC that were determined to be volatile and non-bioaccumulative were subjected to fugacity modelling to determine the potential relative apportionment of the chemical within environmental compartments other than air. Table 94d-1 Hazard Quotients for Peak Predicted Air Concentrations based on TCEQ ESLs Chemical Category COPC Base Case Application Case PDC Acids Carboxylic acids Metals Antimony Strontium Tin Zinc PAHs Pyrene VOCs 2-Chloronaphthalene Aliphatic alcohols Aliphatic C 17-C 34 group Aromatic C 17-C 34 group Aromatic ketones Benzaldehyde Butyl isocyanate Dibenzofuran Heptanamine Hexachlorobutadiene Piperidine Pyridine Sulphur compounds Mercaptans Thiophenes NOTE: Values shown in bold text indicate where the predicted HQs are greater than 0.2. October 2014 ESRD/CEAA Page 487

490 ESRD and CEAA Responses Approvals Frontier Oil Sands Mine Project If a chemical met any of these criteria, sufficient opportunity could be present for exposure via secondary pathways, and the COPC was evaluated in the multiple exposure pathway assessment. If a chemical did not meet any of the criteria, it was assessed only through the inhalation pathway. As shown in Table 94d-2, benzaldehyde, mercaptans and thiophenes do not meet any of the criteria. Therefore, these chemicals were not evaluated through any exposure pathways other than inhalation. The aliphatic and aromatic C 17 -C 34 groups and pyrene met the criteria for being included in the multiple exposure pathway assessment. For that reason, these COPC were assessed for all possible pathways of exposure in the HHRA. Results of the multiple exposure assessment for these COPC were presented in Volume 7, Section , Pages 2-97 to and revised in the response to ESRD/CEAA Round 2 SIR 113a, Appendix 113a.1. Table 94d-2 Determination for Assessing COPC with HQ > 2.0 through Multiple Exposure Pathways COPC Molecular Weight (g/mol) Evaluation Criteria Step 1 Step 2 Step 3 Henry s Law Constant (atm-m 3 /mol) Vapour Pressure (mm Hg) Log K ow Fugacity >3.5 <95% in air Aliphatic C 17-C Yes Aromatic C 17-C Yes Benzaldehyde No Pyrene Yes Mercaptans No Thiophenes No Include in Multiple Exposure Pathway Assessment? (Yes/No) NOTES: Adopted from Volume 7, Table Values shown in bold text indicate that the physical-chemical property meets or is greater than the criterion, and the chemical should be included in the multiple exposure pathway assessment. = step was not completed based on the step-wise approach described in Volume 7, Section REFERENCES Alberta Environment Alberta Tier 1 Soil and Groundwater Remediation Guidelines. Air, Land and Waste Policy Branch. Environmental Assurance Division. ISBN: December Alberta Health Guidance on Human Health Risk Assessment for Environmental Impact Assessment in Alberta. Alberta Health and Wellness. Government of Alberta. August Beyer, W.N., E.E. Connor and S. Gerould Estimates of soil ingestion by wildlife. Journal of Wildlife Management 58: ESRD/CEAA Page 488 October 2014

491 Frontier Oil Sands Mine Project ESRD and CEAA Responses Approvals CCME (Canadian Council of Ministers of the Environment) A Protocol for the Derivation of Environmental and Human Health Soil Quality Guidelines. The National Contaminated Sites Remediation Program, Canadian Council of Ministers of the Environment. Winnipeg, Manitoba. March CCME A Protocol for the Derivation of Environmental and Human Health Soil Quality Guidelines. ISBN PDF. Golder (Golder Associates Ltd.) Trace Metals in Traditional Foods within the Athabasca Oil Sands Area. Submitted to Fort McKay Environmental Services and Wood Buffalo Environmental Association, Terrestrial Environmental Effects Monitoring Science Subcommittee. April Health Canada 2010a. Part I: Guidance on Human Health Preliminary Quantitative Risk Assessment (PQRA). Version 2.0. Federal Contaminated Site Risk Assessment in Canada. Contaminated Sites Division. ISBN: Health Canada 2010b. Part V: Guidance on Human Health Detailed Quantitative Risk Assessment for Chemicals (DQRAChem). Federal Contaminated Site Risk Assessment in Canada. Contaminated Sites Division. ISBN: Health Canada Federal Contaminated Site Risk Assessment in Canada. Part I: Guidance on Human Health Preliminary Quantitative Risk Assessment (PQRA), Version 2.0. Prepared by Contaminated Sites Division Safe Environments Program. Draft for Comment. 2010, Revised ISBN: Cat.: H128-1/11-632E-PDF Nagy, K.A., I.A. Girard and T.K. Brown Energetics of free-ranging mammals, reptiles and birds. Annual Review of Nutrition 19: U.S. EPA (United States Environmental Protection Agency) Risk Assessment Guidance for Superfund: Volume I. Human Health Evaluation Manual (Part A). OERR. Washington, D.C. OERR U.S. EPA Wildlife Exposure Factors Handbook. Washington, DC: Office of Health and Environmental Assessment, Office of Research and Development. EPA/600/R-93/187. December U.S. EPA OSW (United States Environmental Protection Agency s Office of Solid Waste) Screening Level Ecological Risk Assessment Protocol for Hazardous Waste Combustion Facilities, Final. United States Environmental Protection Agency Region 6. Multimedia Planning and Permitting Division. Center for Combustion Science and Engineering, Office of Solid Waste. Wein, E.E., J.H. Sabry and F.T. Evers Food health beliefs and preferences of northern native Canadians. Ecology of Food and Nutrition 23: October 2014 ESRD/CEAA Page 489

492 ESRD and CEAA Responses Approvals Frontier Oil Sands Mine Project Question 95 SIR 204 (Volume 7, Table 2-13, pp to 2-45, Teck s Jan 2013 Response, pp to 8-766, and Teck s Oct 2013 Response, p. 587) The use of certain types of TRVs, while published, may not be protective for certain populations when exposures are continuous, and other options may be preferable. The TRVs used, and the hazard quotients obtained, in the HHRA may need to be reconsidered, along with the uncertainty analyses. a. Discuss whether the approach used by the Proponent to adjusted TRVs were protective of all receptor groups including sensitive populations (e.g. pregnant women, elderly, infants and children) and further discuss any uncertainties associated with this approach, including: i. The adjusted occupational exposure limits used in Table 204a-1; ii. The Acute Exposure Guidance Levels 1 used in Vol. 7 Table 2-13; Response 95 a. Using a default factor of 10 to adjust for intraspecies variability is considered a standard practice in human health risk assessment (U.S. EPA 2002, 2012; TCEQ 2009) to account for potential differences in sensitivity between individuals (e.g., because of age, medical conditions, genetics). When adequate information exists, novel uncertainty factors can be used in the HHRA. However, when this information is not available, the accepted default appears to be a factor of 10. Several examples of this approach are cited below: In its most recent publication of toxicological reference values for human health risk assessment, Health Canada (2010) uses a default factor of 10 to account for intraspecies differences. The most recent guidance from the U.S. EPA (2002) on deriving reference doses (RfD) and reference concentrations (RfC) states: Because the RfD/RfC is defined to be applicable to susceptible subgroups, this UF [uncertainty factor] was established to account for uncertainty in that regard. In general, the Technical Panel reaffirms the importance of this UF, recommending that reduction of the intraspecies UF from a default of 10 be considered only if data are sufficiently representative of the exposure/doseresponse data for the most susceptible subpopulation(s). At the other extreme, a 10-fold factor may sometimes be too small because of factors that can influence large differences in susceptibility, such as genetic polymorphisms. The Technical Panel urges the development of data to support the selection of the appropriate size of this factor, but recognizes that often there are insufficient data to support a factor other than the default. ESRD/CEAA Page 490 October 2014

493 Frontier Oil Sands Mine Project ESRD and CEAA Responses Approvals The U.S. EPA (2012) indicates that the use of uncertainty factors ranging from 3 to 10 is considered appropriate in deriving RfCs from benchmark dose modelling. The Texas Commission for Environmental Quality also notes that an uncertainty factor may be used to account for the variation in sensitivity among the members of the human population. Although this guidance document recommends that chemical-specific data (if available) should be considered in deriving uncertainty factors (e.g., toxicokinetic or toxicodynamic data), (a default) factor of 10 is considered to protect the majority of the human population including children and the elderly (TCEQ 2012). As described in the toxicity profiles (see Volume 7, Appendix 2A) and in the responses to ESRD/CEAA Round 1 SIR 494 and ESRD/CEAA Round 2 SIR 204, additional uncertainty factors were applied to values such as the American Council of Governmental Industrial Hygienists (ACGIH) threshold limit value-time-weighted average (TLV-TWA) or short-term exposure limit (STEL). This approach was used for a small number of chemicals in the assessment and only in circumstances where no other toxicological reference values were available from reputable regulatory sources for which there was supporting documentation. Overall, the methodology of applying a default uncertainty factor of 10 to account for potential intraspecies differences (i.e. potential sensitive individuals in the population) is consistent with current risk assessment guidance. REFERENCES Health Canada Health Canada Toxicological Reference Values (TRVs) and Chemical Specific Factors. Version 2.0. Part II. Federal Contaminated Site Risk Assessment in Canada. TCEQ (Texas Commission on Environmental Quality) TCEQ Guidelines to Develop Toxicity Factors. Toxicology Division. Revised RG-442. October U.S. EPA (United States Environmental Protection Agency) A Review of the Reference Dose and Reference Concentration Processes. EPA/630/P-02/002F. Risk Assessment Forum, Washington DC. Available at: U.S. EPA Benchmark Dose Technical Guidance. EPA/100/R-12/001. June October 2014 ESRD/CEAA Page 491

494 ESRD and CEAA Responses Approvals Frontier Oil Sands Mine Project Question 96 SIR 205 (Volume 4, Section 3.6.8, pp to 3-229, Teck s Jan 2013 Response, p , and Teck s Oct 2013 Response, pp ). The California Air Resources Board (CARB 2005) documents discussing threshold values of 0.12ppm for the health effects of ozone are outdated. The 2013 US EPA Integrated Science Assessment for Ozone and Related Photochemical Oxidants ( recordisplay.cfm?deid=247492#download) indicates that there are health effects as low as 0.06 ppm with no threshold identifiable. a. Provide a discussion of the predicted Project-related health effects of ozone in the context of the 2013 EPA document. Response 96 a. The U.S. EPA (2013) Integrated Science Assessment for Ozone and Related Photochemical Oxidants concludes, based on a weight of evidence, that there is no apparent health effects threshold for ozone. However, it also notes that some uncertainty exists in the lower end of dose-response evaluations because of data limitations. No ambient air quality guideline or standard is recommended in this document. Recent guidance directly relevant to the Project and managing potential adverse effects of ozone exposure is the current Canadian Ambient Air Quality Standard (CAAQS), published by the Canadian Council of Ministers of the Environment (CCME 2012). The standard for ozone is 63 parts per billion (ppb) or 123 µg/m 3 when compared with the three-year average of the annual 4th highest daily maximum 8-hour average concentrations. The (see Volume 4, Appendix 3B, Section 3B5.2, Page 3B-63) discusses monitoring work completed by Alberta Environment (AENV 2009) in the Athabasca Oil Sands Region using three-year averages of annual 4th highest 8-hour ozone concentrations. These data indicate: no values greater than the previous Canada-wide standard (128 μg/m 3 ), the new CAAQS (123 µg/m 3 ) (CCME 2012), or the Alberta Environment Exceedance Trigger (128 μg/m 3 ) no values greater than the Alberta Environment Planning Trigger (113 μg/m 3 ) As stated in Volume 4, Section , Page and the response to ESRD/CEAA Round 2 SIR 205, future increases in ozone precursor emissions can potentially increase the 4 th highest daily 8-hour concentrations by 4 μg/m 3 to 8 μg/m 3. In addition, Alberta Environment (2009) notes that all stations in the WBEA [Wood Buffalo Environmental Association] airshed are assigned a Surveillance Actions level and that stations in the WBEA airshed can be influenced by wildfires in the summertime. It also notes that anthropogenic ozone episodes in the Fort McMurray region can ESRD/CEAA Page 492 October 2014

495 Frontier Oil Sands Mine Project ESRD and CEAA Responses Approvals occur during periods of hot summertime weather (AENV 2009). As a result, it is probable that ozone concentrations in the region will continue to fluctuate. In summary, ozone emissions from the Project depend, in part, on precursor emissions (NO X and VOCs), and regional concentrations of ozone might vary depending on several factors. As a result, Teck will focus on monitoring, in accordance with current provincial and federal guidance, to manage ozone in relation to potential human health effects associated with the Project. Based on the no-threshold-of-effect concept, any increase in regional ozone concentrations could result in adverse health effects. The degree to which health would be affected would then depend on the extent, frequency and magnitude of the predicted ozone concentrations. In the response to ESRD/CEAA Round 1 SIR 142, Teck states that: The Project, together with other developments in the oil sands region, collectively results in an increase in ozone precursor NOx and volatile organic compound (VOC) emissions. With certain weather conditions, these emissions can lead to an increase in ambient ozone episodes. The Frontier Project will include an active management and monitoring plan to identify and manage emissions. Combined with the regional monitoring program for ozone, Teck s emissions management plan will mitigate the potential ozone-related health risks in the area. REFERENCES AENV (Alberta Environment) Particulate Matter and Ozone Assessment for Alberta: Air Policy Section, Alberta Environment. Edmonton, Alberta. CCME (Canadian Council of Ministers of the Environment) Guidance Document on Achievement Determination Canadian Ambient Air Quality Standards for Fine Particulate Matter and Ozone. Available at: Accessed March U.S. EPA (United States Environmental Protection Agency) EPA Integrated Science Assessment for Ozone and Related Photochemical Oxidants. October 2014 ESRD/CEAA Page 493

496 ESRD and CEAA Responses Approvals Frontier Oil Sands Mine Project ESRD/CEAA Page 494 October 2014

497 Frontier Oil Sands Mine Project ESRD and CEAA Responses Errata 8 ERRATA Question 97 Volume 1, ESRD/CEAA SIR 75, Page 207 Teck quotes the Canada Soil Survey Committee, Subcommittee on Soil Classification (1998) Chapter 2 as stating that Soil may have water covering its surface to a depth of 60 cm or less either at low tide in coastal areas or during the driest part of the year; however, the full quote reads: Soil may have water covering its surface to a depth of 60 cm or less either at low tide in coastal areas or during the driest part of the year in areas inland. a. Correct the quote. Response 97 a. The full quotation from the Canada Soil Survey Committee, Subcommittee on Soil Classification (1998) Chapter 2 is: Soil may have water covering its surface to a depth of 60 cm or less either at low tide in coastal areas or during the driest part of the year in areas inland. REFERENCES Canada Soil Survey Committee, Subcommittee on Soil Classification The Canadian System of Soil Classification, 3 rd Edition. Agriculture and Agri-Food Canada Publication NRC Research Press. Ottawa, Ontario. Question 98 Volume 1, ESRD/CEAA SIR 81, Page Volume 2, Appendix 81a.1 (Soil Maps) Teck provided updated soil maps. Errors were found on two of the map sheets: Map 01 has a soil map unit that incorrectly labelled (site #UTSFR505AS). Map 05 has a map unit symbol missing from a polygon located near VLS466. a. Provide corrected soil map sheets. Response 98 a. Corrected map sheets for Maps 01 and 05 are provided in Appendix 98a.1. October 2014 ESRD/CEAA Page 495

498 ESRD and CEAA Responses Errata Frontier Oil Sands Mine Project Question 99 Volume 2, Appendix 7a.1, Attachment 7a.1D, Figure 3D-5R Figure 3D-5R is missing. a. Provide this figure. Response 99 a. Figure 3D-5R was erroneously missed in Teck s Round 2 SIR submission. Figure 3D-5R is provided. Because no revisions have been made, the original figure numbering has been retained. ESRD/CEAA Page 496 October 2014

499 Figure 3D-5R: Background Nitrogen Deposition (keq H+/ha/a) in the RSA Frontier Project - Response to Supplemental Information Request: Round 2- ESRD/CEAA