2. Assessment Process

Transcription

1 2. Assessment Prcess Pretium Resurces Inc. (Pretivm r the Prpnent) prpses t develp the Brucejack Gld Mine Prject (the Prject) as a 2,700 tnne per day (tpd) undergrund gld/silver mine in the Reginal District f Kitimat-Stikine in nrthern British Clumbia (BC). Pursuant t Sectin 3(1) f the Reviewable Prjects Regulatin (BC Reg. 370/2002), the prpsed prductin capacity fr the Prject exceeds the criteria f 75,000 tnnes per annum (tpa) f mineral re fr a new mineral mine and will require a prvincial envirnmental assessment (EA) under the BC Envirnmental Assessment Act (BC EAA; 2002a). Federally, the Prject is cnsidered a designated prject under Sectin 16 (c) f the Regulatins Designating Physical Activities (SOR/ ) as the prductin rate will exceed the threshld fr a gld mine f 600 tpd. Designated prjects are subject t the Canadian Envirnmental Assessment Act, 2012 (CEAA 2012; 2012). This chapter describes the assessment prcess relevant t the Prject as prescribed by federal and prvincial EA legislatin and plicy. The chapter is brken int sectins that prvide a detailed descriptin f the fllwing tpics: prvincial and federal EA requirements; the cperative prvincial and federal EA prcess; the Prject scpe per the prvincial Sectin 11 Order and Envirnmental Impact Statement (EIS) Guidelines; prvincial and federal permitting requirements; transbundary regulatry issues; and EA prvisins f the Nisga a Final Agreement (NFA; NLG, Prvince f BC, and Gvernment f Canada 1998). 2.1 PROVINCIAL AND FEDERAL ENVIRONMENTAL ASSESSMENT REQUIREMENTS British Clumbia Envirnmental Assessment Requirements British Clumbia Envirnmental Assessment Act The BC EAA (2002a) requires that certain large-scale prject prpsals underg an EA and btain an EA Certificate befre they can prceed. Under the BC EAA, prjects requiring an EA Certificate must prepare an Applicatin fr an EA Certificate that identifies and assesses any ptential envirnmental, scial, ecnmic, health, and heritage effects that may result frm the prpsed prject, and t mitigate adverse effects where pssible. The BC EAA and accmpanying regulatins establish the framewrk fr delivering EAs. Within this framewrk, the scpe, prcedures, and methds f the assessment are custmized t the circumstances f each prject. This apprach allws each review t fcus n relevant issues when determining whether r nt the prject shuld prceed (BC EAO 2003). The decisin t apprve r reject a prvincial EA fr a mining prject is made by the Minister f Energy and Mines and by the Minister f Envirnment. In making their ministerial referrals, the British Clumbia Envirnmental Assessment Office (BC EAO) cnsiders the infrmatin presented in the Applicatin, alng with any issues raised thrughut the review prcess, t infrm their cnclusins regarding the ptential fr the Prject t result in significant adverse effects. If the Prject is allwed PRETIUM RESOURCES INC. 2-1

2 APPLICATION FOR AN ENVIRONMENTAL ASSESSMENT CERTIFICATE / ENVIRONMENTAL IMPACT STATEMENT t prceed, an EA Certificate is issued under Sectin 17 (3) f the BC EAA and is subject t cmpliance and reprting requirements. The Certificate describes the physical wrks f the Prject (attached in Schedule A) and a Table f Cnditins (Schedule B). The EA Certificate specifies a deadline by which the Prject must have substantially cmmenced and is generally at least three years and nt mre than five years after the issue date f the Certificate (the hlder f the certificate may apply t have the deadline extended). Once the Prject has substantially started, the EA Certificate remains in effect fr the life f the Prject unless suspended r cancelled fr breaches f the cnditins. Prpnents may apply t amend their EA Certificate as Prject circumstances change. The BC EAA is supprted by five regulatins. Fur f these are described belw: the Reviewable Prjects Regulatin (BC Reg. 370/2002), the Prescribed Time Limits Regulatin (BC Reg. 372/2002), the Public Cnsultatin Plicy Regulatin (BC Reg. 373/2002), and the Cncurrent Apprval Regulatin (BC Reg. 371/2002). The Transitin Regulatin (BC Reg. 374/2002) applies t prjects prpsed n r befre December 2002 and is nt applicable t this Prject Reviewable Prjects Regulatin (BC Reg. 370/2002) Criteria fr determining whether prjects and activities like mining are subject t the BC EAA are laid ut in the Reviewable Prjects Regulatin (BC Reg. 370/2002). The rder issued under Sectin 10(1)(c) f the BC EAA n February 6, 2013 states the Prject is reviewable pursuant t Part 3 f the Reviewable Prjects Regulatin (BC Reg. 370/2002) since the prpsed Prject wuld have a prductin capacity f greater than r equal t 75,000 tpa f mineral re. The Sectin 10 Order als prhibits the Prpnent frm prceeding with the prpsed Prject withut an assessment because the prpsed Prject may have the ptential fr significant adverse envirnmental, ecnmic, scial, heritage, and health effects Prescribed Time Limits Regulatin (BC Reg. 372/2002) The Prescribed Time Limits Regulatin (BC Reg. 372/2002) establishes time limits at different stages f the assessment prcess. Sectin 2 prescribes a 30-day time limit fr screening f the Applicatin while Sectin 3(a) establishes a 180-day perid t review the Applicatin. There is als a 45-day time limit fr making a decisin after the Applicatin has been referred t Ministers. This regulatin als specifies time limits t prvide infrmatin and cnditins arund suspending time limits Public Cnsultatin Plicy Regulatin (BC Reg. 373/2002) The Public Cnsultatin Plicy Regulatin (BC Reg. 373/2002) applies t reviewable prjects under the BC EAA where a Sectin 10 Order has been issued. The regulatin requires prpnents t undertake a public cnsultatin prgram, as well as prvide a summary and evaluatin f public cnsultatin activities during the pre-applicatin stage f the assessment prcess. The regulatin als utlines the bligatins f the Prpnent and the executive directr in prviding adequate time fr public cnsultatin and review in accrdance with the Prescribed Time Limits Regulatin (BC Reg. 372/2002), as well as the need fr a public cmment perid n the Applicatin f between 30 and 75 days, as established by the executive directr Cncurrent Apprval Regulatin (BC Reg. 371/2002) The Cncurrent Apprval Regulatin (BC Reg. 371/2002) prvides the mechanism fr reviewable prjects under the BC EAA t apply fr cncurrent review and apprval f eligible prvincial apprvals needed t cnstruct, perate, mdify, dismantle, abandn, r therwise undertake all r part f a reviewable prject that is underging assessment. 2-2 ERM RESCAN PROJ# REV C.1 JUNE 2014

3 ASSESSMENT PROCESS The Prpnent intends t apply fr cncurrent review f selected prvincial apprvals in accrdance with the criteria and timeframes identified in the Cncurrent Apprval Regulatin Guidance Dcuments This Applicatin/EIS has been prepared by fllwing the prvincial guidance dcuments listed belw: Envirnmental Assessment Office User Guide (BC EAO 2010a); Guide t Invlving Prpnents when Cnsulting First Natins in the Envirnmental Assessment Prcess (BC EAO 2013b); Prpnent Guide fr Prviding First Natin Cnsultatin Infrmatin (Nn-Treaty First Natin; BC EAO 2010b); Prpnent Guide fr Prviding First Natin Cnsultatin Infrmatin (Treaty First Natin; BC EAO 2010c); Guidelines fr the Selectin f Valued Cmpnents and Assessment f Ptential Effects (BC EAO 2013c); Applicatin Infrmatin Requirements Template (BC EAO 2013a); and Public Cmment Plicy (BC EAO n.d.) Canadian Envirnmental Assessment Requirements Canadian Envirnmental Assessment Act, 2012 The Prject is subject t the CEAA 2012, under which tw types f EAs may be required: a standard EA r a review panel. This Prject is subject t a standard EA prcess. 1 Prhibitins under the CEAA prevent prpnents frm carrying ut designated prjects, in whle r in part, until an assessment is cnducted if activities may cause envirnmental effects in areas f federal jurisdictin (e.g., fish and fish habitat, aquatic species as defined under the Species at Risk Act (2002c), migratry birds, r Abriginal persns). A 10-day perid t determine the adequacy f the Prject Descriptin is prescribed, fllwed by a 45-day screening perid t determine whether an assessment fr the Prject is required. If the Canadian Envirnmental Assessment Agency (CEA Agency) determines an assessment is required, a decisin under Sectin 10(1) (b) is taken and a Ntice f Envirnmental Assessment Determinatin is issued. Under Sectin 27(2) f the CEAA 2012, nce it has been determined an EA is required and a Ntice f Cmmencement is psted, a time limit f 365 days is established t make a decisin n whether the Prject shuld prceed and t issue an EA Decisin Statement. The federal decisin t apprve r reject the EA fr a majr resurce prject is made by the Minister f the Envirnment. In making their ministerial referral, the CEA Agency cnsiders the infrmatin presented in the EIS, alng with any issues raised thrughut the review prcess, t infrm their cnclusins regarding the ptential fr the Prject t result in significant adverse envirnmental effects. Prpnents may nly carry ut Prjects if they are in cmpliance with cnditins cntained in an EA Decisin Statement, issued fr a Prject under Sub-sectin 31(1); decisin statements are enfrceable 1 The CEAA 2012 als cntains substitutin and/r equivalency prvisins fr prjects subject t a standard EA prcess whereby if cnditins cntained in Sectin 34 are met, a prvincial EA prcess can be substituted fr the federal assessment prcess; the Brucejack Gld Mine Prject is nt subject t a substituted EA prcess. PRETIUM RESOURCES INC. 2-3

4 APPLICATION FOR AN ENVIRONMENTAL ASSESSMENT CERTIFICATE / ENVIRONMENTAL IMPACT STATEMENT and carry a maximum fine f up t $400,000 per day fr nn-cmpliance. Federal authrities are als prhibited frm exercising any pwer r perfrming any duty r functin that culd permit a designated prject t be carried ut in whle r in part unless the Decisin Statement indicates the designated prject is nt likely t cause significant adverse envirnmental effects r that significant adverse envirnmental effects are justified in the circumstances. The CEAA 2012 is further supprted by the regulatins, peratinal plicy statements, and guidance dcuments described belw. Cst Recvery Regulatins are als in place under the CEAA 2012 but d nt apply t prjects underging a standard EA review prcess Regulatins Designating Physical Activities (SOR/ ) Federally, the Prject is cnsidered a designated prject under Sectin 16 (c) f the Regulatins Designating Physical Activities (SOR/ ), as the Prject invlves the cnstructin, peratin, decmmissining, and abandnment f a gld mine, ther than a placer mine, with an re prductin capacity f 600 tpd r mre. Prpnents that have Prjects described in these regulatins must submit a Prject Descriptin describing the Prject s cmpnents and physical activities t the CEA Agency. The CEA Agency then screens the Prject Descriptin t determine whether a federal assessment is required Prescribed Infrmatin fr the Descriptin f a Designated Prject Regulatins (SOR/ ) This regulatin specifies the infrmatin that is required in the Prject Descriptin t determine whether a federal EA is required. The Prject Descriptin fr the Brucejack Gld Mine Prject was accepted fr screening by the CEA Agency n February 8, Plicy Statements and Guidance Dcuments This Applicatin/EIS has been prepared using the plicy statements and guidance dcuments referenced and prvided by the CEA Agency and ther federal gvernment agencies. Sme f these dcuments prvide guidance fr the cnduct f EAs subject t the frmer Canadian Envirnmental Assessment Act (1992) and have nt been updated t reflect the CEAA 2012 prvisins; they are included here fr general reference purpses. CEAA 2012 Cnsidering Abriginal Traditinal Knwledge in Envirnmental Assessments Cnducted under the Canadian Envirnmental Assessment Act, 2012 (CEA Agency 2013a). Operatinal Plicy Statement: Addressing Purpse f and Alternative Means under the Canadian Envirnmental Assessment Act, 2012 (CEA Agency 2013b); Operatinal Plicy Statement: Assessing Cumulative Envirnmental Effects under the Canadian Envirnmental Assessment Act, 2012 (CEA Agency 2013c); and Practitiners Glssary fr the Envirnmental Assessment f Designated Prjects under the Canadian Envirnmental Assessment Act, 2012 (CEA Agency 2013d). Frmer CEAA (1992; last amended in 2010) Assessing Envirnmental Effects n Physical and Cultural resurces under the Canadian Envirnmental Assessment Act, 1992 (CEA Agency 1996); Cumulative Effects Assessment Practitiners Guide (Hegmann et al. 1999); 2-4 ERM RESCAN PROJ# REV C.1 JUNE 2014

5 ASSESSMENT PROCESS Determining Whether a Prject is Likely t Cause Significant Adverse Envirnmental Effects (CEA Agency 1994); Operatinal Plicy Statement: Adaptive Management Measures under the Canadian Envirnmental Assessment Act (CEA Agency 2009); Operatinal Plicy Statement: Fllw-up Prgrams under the Canadian Envirnmental Assessment Act (CEA Agency 2011); Public Participatin Guide: A Guide fr Meaningful Public Participatin in Envirnmental Assessments under the Canadian Envirnmental Assessment Act (CEA Agency 2008). 2.2 ENVIRONMENTAL ASSESSMENT PROCESS The Prject is subject t a crdinated 2 prvincial-federal EA prcess cnducted under the principles f the nw expired Canada British Clumbia Agreement fr Envirnmental Assessment Cperatin (the Agreement; CEA Agency 2004). The Agreement aligns key aspects f the assessment prcess t minimize duplicatin and imprve efficiency (e.g., cnducting jint public cmment perids, crdinating Abriginal cnsultatin, using cmmn dcuments that meet the requirements f bth gvernments, and establishing cmmn wrking grups t facilitate the review prcess). The prvincial and federal phases f the EA prcess fr the Brucejack Gld Mine Prject are described belw Prvincial Envirnmental Assessment Prcess The phases and steps f the prvincial EA prcess are shwn in Figure The EA prcess is divided int three perids: the Pre-Applicatin stage, an Applicatin Review Stage, and the Decisin. Activities undertaken by the Prpnent prir t the start f the EA (i.e., pre-ea activities) were initiated t prepare fr the assessment prcess. This included cnducting field and desk-based technical studies, and develping and implementing cnsultatin and engagement prgrams with Abriginal grups and the public Pre-Applicatin Stage Pretivm entered the Pre-Applicatin stage f the prvincial prcess with the submissin f a Prject Descriptin (Rescan 2013) in January 2013 t the BC EAO. Pretivm submitted a draft Prject Descriptin t the BC EAO n December 20, 2012 t supprt early feedback n prvincial infrmatin requirements; the Prject Descriptin was subsequently updated and a revised submissin was issued t the BC EAO n January 28, After reviewing the Prject Descriptin, an Order under Sectin 10(1)(c) f the BC EAA (2002a) was issued by the BC EAO n February 6, 2013 indicating the Prject was reviewable. The Order stated that the Prject required an EA Certificate and that the Prpnent may nt prceed with the Prject withut an assessment. On July 4, 2013 the BC EAO issued an Order pursuant t Sectin 11 f the BC EAA, which prescribed the scpe, prcedures, and methds t undertake the prvincial EA, including public, gvernment agency, Treaty Natins, and First Natins cnsultatin requirements. 2 Under Sectin 18 f the CEAA 2012, the Minister f Envirnment must ffer t cnsult and cperate with respect t the envirnmental assessment f the designated prject with any jurisdictin that has pwers, duties r functins in relatin t an assessment f the envirnmental effects f the designated prject. Under Sectin 86 f the CEAA 2012, the Minister f the Envirnment can enter int agreements t prmte cperatin and crdinated actin between federal and prvincial gvernments with respect t the assessment f the envirnmental effects f designated prjects f cmmn interest. PRETIUM RESOURCES INC. 2-5

6 Figure Prvincial Envirnmental Assessment Prcess fr the Brucejack Gld Mine Prject Prject Descriptin Minister(s) may cnsider any ther matters that they cnsider relevant t the public interest in making their decisin Determinatin that Prject is Reviewable (Sectin 10 Order) Cmpliance Management begins here Develp Requirements Certificate Issued with set cnditins Prject Authrized t Prceed t Permitting Mnitring, cmpliance, and enfrcement Scpe and Prcess fr Review Determined (Sectin 11 Order) Applicatin Infrmatin Requirements Applicatin Prepared and Submitted Applicatin Evaluated fr Cmpleteness Applicatin Review Assessment Reprt ED Referral T Ministers Prject Decisin by Ministers Apprved Nt Apprved Public Cmment Perid Public Cmment Perid Further Assessment Required Certificate Refused Prject Cannt Prceed Pre-Applicatin Stage (n timeline) (30 days) Applicatin Review Stage (180 days) Wrking Grup Review Decisin (45 days) First Natin Cnsultatin Surce: BC EAO Website, PRETIUM RESOURCES INC. Prj # Graphics # BJP

7 ASSESSMENT PROCESS Scpe f Prject The scpe f the Prject defined in the Sectin 11 Order includes the fllwing n-site and ff-site cmpnents: undergrund mine and ancillary cmpnents and activities; mineral prcessing facility and ancillary cmpnents and activities; waste management and ancillary cmpnents and activities, including waste rck and tailings; water management and ancillary cmpnents and activities; and ther infrastructure and ancillary cmpnents and activities, including mdificatin r expansin f the existing explratin rad frm Highway 37 t the Brucejack Mine Site, transprtatin frm Highway 37 t the Brucejack Mine Site, transmissin line and pwer supply, camps and ffices, truck shp, fuel strage, explsives, and cncentrate strage. Applicatin Infrmatin Requirements In accrdance with the EA prcess, the Prpnent prepared draft Applicatin Infrmatin Requirements (AIR) fr the Prject; the AIR (frmerly referred t as a Terms f Reference) identifies the infrmatin required t be submitted in the Applicatin. A first draft f the AIR was submitted t the BC EAO n May 31, 2013 and distributed t the EA Wrking Grup fr review. Cmments were cmpiled int an issues-tracking table fr respnse by Pretivm. Respnses t issues raised and an updated draft AIR were re-submitted t the BC EAO. The BC EAO initiated a 30-day public cmment perid n the AIR, held frm Nvember 13 until December 13, 2013 and public cmments were psted t the BC EAO s e-pic website. A summary f the issues raised during the review f the AIR are prvided in Chapter 3, Infrmatin Distributin and Cnsultatin, f the Applicatin/EIS. The final AIR was issued by BC EAO n May 2, 2014 (BC EAO 2014), fllwing the feedback received frm the EA wrking grup, First Natins, and the public. Preparatin f the Applicatin After receiving the final AIR (BC EAO 2014), an effects assessment was cmpleted fr each intermediate and receptr valued cmpnent t address requirements f the AIR and fllwing the assessment methdlgy described in Chapter 6. Public and Abriginal cnsultatin activities als cntinued during this perid. An Abriginal Cnsultatin Plan and a Public Cnsultatin Plan were submitted t the BC EAO fr apprval within 60 days f the issuance f the Sectin 11 Order. The Abriginal Cnsultatin Plan specified the Abriginal grups that Pretivm planned t cnsult with and the BC EAO assessed the plan t determine the adequacy f the prpsed cnsultatin activities. Issues raised by Abriginal grups relating t the EA were cmpiled int tw summary reprts prvided t Abriginal grups fr initial review and cmment n December 16, 2013 and April 17, This infrmatin is als summarized within Chapter 3 f the Applicatin (Infrmatin Distributin and Cnsultatin). Screening f the Applicatin After Pretivm submits the Applicatin, a 30-day screening perid (required by the BC EAA [2002a]) will be initiated (which may be extended at the discretin f the BC EAO r as requested by the prpnent). A Table f Cncrdance submitted as part f the Applicatin will be used by the EA Wrking Grup t screen the Applicatin against the AIR t determine whether the required PRETIUM RESOURCES INC. 2-7

8 APPLICATION FOR AN ENVIRONMENTAL ASSESSMENT CERTIFICATE / ENVIRONMENTAL IMPACT STATEMENT infrmatin has been adequately prvided. If the BC EAO determines the Applicatin t be insufficient, Pretivm will be required t address the infrmatin deficiencies. If the Applicatin cntains all f the required infrmatin, the BC EAO will ntify Pretivm that the Applicatin has been accepted fr a frmal, detailed review by the EA Wrking Grup Applicatin Stage 180-Day Review f the Applicatin Under the BC EAA (2002a), if the Applicatin is accepted fr review by the BC EAO, a legislated 180-day review perid cmmences. The prpnent prvides paper and electrnic cpies f the Applicatin/EIS t the EA Wrking Grup, Abriginal grups, public libraries, and ther stakehlders as directed by the BC EAO. The Applicatin is als upladed t the BC EAO s e-pic website t supprt public cnsultatin requirements. During the review perid, a public cmment perid n the Applicatin will be held t prvide the public with an pprtunity t review and cmment n the Applicatin. Pretivm will cmpile, track, and respnd t public cmments using an issues-tracking table. Cmments received during the public cmment perid will be psted t the BC EAO s e-pic website. Pretivm will be required t submit a public cnsultatin reprt within 30 days f the clse f the Applicatin cmment perid. Wrking Grup meetings will als be held thrughut the 180-day perid t discuss substantive technical issues and t prvide advice t Pretivm. Wrking grup members will submit technical written cmments fr respnse by Pretivm, which can take the frm f technical memrandums, issues-tracking tables, and/r addendums t the Applicatin. Pretivm will be invited t participate in, and present infrmatin at the Wrking Grup technical sub-cmmittee meetings. Abriginal cnsultatin activities will cntinue thrughut the review f the Applicatin by bth the prvincial Crwn and Pretivm. A cnsultatin reprt summarizing the issues raised thrughut the Applicatin review stage by Abriginal grups and hw these have been reslved by Pretivm needs t be submitted t the BC EAO within 120 days f the cmmencement f the Applicatin review stage. Pursuant t Sectin 27(6) f the BC EAA (2002a), the BC EAO may suspend the 180-day review perid if additinal infrmatin is required frm the prpnent. Assessment Reprt During the latter half f the Applicatin review stage, the BC EAO prepares an Assessment Reprt that summarizes the residual effects f the prpsed Prject, identifies prpsed mitigatin measures, evaluates the significance f residual, adverse effects, and summarizes all public cncerns and hw they have been addressed. A summary f all Abriginal cnsultatin issues that were raised during the EA prcess is als included, alng with the identificatin f any unreslved technical r cnsultatin issues. The assessment reprt cntains recmmendatins fr the relevant Ministers t cnsider when deciding if an EA Certificate shuld be granted. The BC EAO will als request that Pretivm cmpile a Certified Prject Descriptin (CPD) and Table f Cnditins (TC) t supprt the EA Certificate. The CPD is a descriptin f the physical wrks f the Prject and describes hw the Prject must be cnstructed, perated, decmmissined, and reclaimed. Envirnmental management plans fr key issues may als be cntained within the CPD. The TC identifies cnditins that the Prpnent must adhere t, in additin t identifying key mitigatin measures and mnitring requirements that the Prpnent must fllw during different phases f the Prject. 2-8 ERM RESCAN PROJ# REV C.1 JUNE 2014

9 ASSESSMENT PROCESS All f these reprts are prvided t the Wrking Grup, Abriginal grups, and t the Prpnent fr their review and cmment prir t being finalized and referred t Ministers fr a decisin. Minister s Decisin The BC EAO will cmpile a referral package fr the Minister f the Envirnment and the Minister f Energy and Mines that includes the Assessment Reprt and a draft EA Certificate. The Ministers decisin is made within 45 days f a referral and is psted t the BC EAO s e-pic website. Once issued, the EA Certificate is a legally binding dcument granting cnditinal apprval fr the Prject t prceed Federal Standard Envirnmental Assessment Prcess While there are n prescribed phases f the standard EA prcess under the CEAA 2012, a descriptin f imprtant milestnes is prvided belw. Prject Descriptin The federal EA prcess, presented in Figure 2.2-2, begins with the submissin f a Prject Descriptin t the Respnsible Authrity (i.e., the CEA Agency). The Brucejack Gld Mine Prject Descriptin was submitted t the CEA Agency in January 2013 (Rescan 2013). As described abve, the Prject Descriptin was screened and accepted fr a 45-day review perid by the CEA Agency fr the purpses f determining whether a federal EA was required fr the Prject. A federal public cmment perid n the Prject Descriptin was held between February 8 t 29, 2013 t seek cmments frm the public n the Prject and its ptential effects n the envirnment. During this perid, the Prject Descriptin was circulated t ther federal gvernment agencies fr review and input; these agencies were invited t jin their cunterparts t sit n the technical Wrking Grup fr the Brucejack Gld Mine Prject. Ntice f Cmmencement A Ntice f Cmmencement (NC) was issued by the CEA Agency n March 26, 2013 and psted t the Canadian Envirnmental Assessment Registry Internet Site (CEARIS) stating that a federal EA f the Prject was required. The psting f the NC initiated the beginning f a 365-calendar day, gvernment time limit; the clck can nly be stpped by the CEA Agency if it is deemed there is insufficient infrmatin available fr the purpse f cnducting the envirnmental assessment r preparing the reprt with respect t the envirnmental assessment f the designated prject. Envirnmental Impact Statement Guidelines The CEA Agency issued draft EIS Guidelines fr the Prject n March 26, 2013, which was fllwed by a mandatry public cmment perid f 30 days, which ran frm March 26 t April 25, The purpse f the EIS Guidelines is t identify the minimum infrmatin requirements fr the preparatin f an EIS in accrdance with the CEAA 2012 and specifies the scpe f the assessment and factrs t be cnsidered. Fllwing the public review perid, final EIS Guidelines fr the Prject were issued n May 24, 2013 (BC EAO 2013c). This EIS cnstitutes a submissin in accrdance with the federal EIS Guidelines fr the prject. Scpe f Prject As specified in Sectin 6.0 f the EIS Guidelines (BC EAO 2013c), the CEA Agency defines the scpe f the Brucejack Gld Mine Prject t be assessed as the cnstructin, peratin, and decmmissining f the fllwing prject cmpnents: mine prtal; PRETIUM RESOURCES INC. 2-9

10 Figure The Standard Envirnmental Assessment Prcess under CEAA, 2012 Abriginal cnsultatin is integrated int the EA t the extent pssible Gvernment timeline f 365 days* PD Review (10 days) Prpnent submits PD Agency accepts PD r Agency requests mre infrmatin frm prpnent Prject Descriptin Determinatin f EA (up t 45 days) 20-day public cmment perid n PD Agency determines whether EA is required Agency issues Ntice f Determinatin Agency discusses cperatin with prvince N EA EA: Envirnmental Assessment EIS: Envirnmental Impact Statement PD: Prject Descriptin NOC: Ntice f Cmmencement Prceed with ther federal decisins r apprvals, if required Yes t EA EA Cmmencement Agency issues NOC Public cmment perid n draft EIS Guidelines Minister refers prject t Review Panel if warranted (within 60 days f NOC) Agency issues final EIS Guidelines t prpnent : Public Participatin Opprtunity : Deliverable * With pssibility f extensin Timelines d nt include time required by the prpnent t prvide infrmatin EA by the Agency EIS Guidelines EA by Review Panel Analysis Prpnent submits EIS Gvernment reviews EIS - public cmment perid Prpnent supplements EIS as needed Analysis Prpnent submits EIS Gvernment reviews EIS - public cmment perid Prpnent supplements EIS as needed Public cmment perid n Panel Terms f Reference EA Reprt Agency prepares draft EA Reprt Public cmment perid n draft EA Reprt Agency finalizes EA Reprt Review by Panel Minister appints the Panel Panel reviews EIS t determine sufficiency - public cmment perid if needed Panel hlds public hearing Panel submits EA Reprt t the Minister Gvernment timeline f 24 mnths* EA Decisin Minister determines significance f envirnmental effects Cabinet decides if significant effects, if any, are justified Minister issues EA Decisin Statement with enfrceable cnditins EIS EA Reprt EA Decisin Statement EIS EA Reprt EA Decisin Minister determines significance f envirnmental effects Cabinet decides if significant effects if any are justified Minister issues EA Decisin Statement with enfrceable cnditins EA Decisin Statement Fllw-up and Enfrcement Surce: Canadian Envirnmental Assessment Agency. PRETIUM RESOURCES INC. Prj # Graphics # BJP

11 ASSESSMENT PROCESS ventilatin shafts; waste rck transfer pad; run-f-mine re stckpile; re cnveyr; surface and undergrund crushers; mill/cncentratr; backfill paste plant; tailings pipeline; subaqueus dispsal f waste rck and tailings; backfill f waste rck and tailings undergrund; diversin channels; back-up pwer plant; transmissin line and ancillary cmpnents; warehuse; truck shp; helicpter pad; sewage treatment plant and related activities (e.g., sludge dispsal); water treatment plant; incineratr; electric inductin furnace; landfill; mine site haul rads and activities related t transprtatin alng access rads up t Highway 37; aerdrme; transfer statin; fuel strage tanks; surface and undergrund explsives strage; up t a 550-persn mdular camp; and administratin ffices. Since the issuance f the final EIS Guidelines (BC EAO 2013c), the prpsed landfill has been remved frm the Prject design. Participant Funding Pursuant t Sectin 58(1) f the CEAA 2012, the CEA Agency must establish a participant funding prgram t facilitate the invlvement f the public and t supprt cnsultatin activities fr ptentially affected Abriginal grups. Tw funding envelpes are established: a Regular Funding Envelpe t supprt members f the public and an Abriginal Funding Envelpe. The Regular Funding PRETIUM RESOURCES INC. 2-11

12 APPLICATION FOR AN ENVIRONMENTAL ASSESSMENT CERTIFICATE / ENVIRONMENTAL IMPACT STATEMENT Envelpe is established t prvide funding fr individuals, Abriginal grups, and incrprated nt-frprfit rganizatins t participate in the EA review prcess. Funding frm the Abriginal Funding Envelpe may be prvided t Abriginal grups whse rights may be ptentially affected by the prpsed prject. Funds can be used t review key EA dcuments r t supprt their engagement in cnsultatin activities. Parties applying t either funding envelpe must meet certain eligibility criteria and must describe what the funding will be used fr. An independent Funding Review Cmmittee is established t assess funding applicatins and recmmend funding allcatins. On June 6, 2013 the CEA Agency annunced that funds were available under the Participant Funding Prgram fr the Brucejack Gld Mine Prject. Applicatins were pen fr a perid f 30 days until July 6, On August 14, 2013 the CEA Agency annunced an allcatin f $60, t enable tw applicants t participate in the upcming steps f the EA prcess, including review and cmment n the EIS and the draft Envirnmental Assessment Reprt. The allcated funds are identified in Table Table Participant Funding Prgram Allcatins Applicant Allcatin Nisga a Natin, as represented by the Nisga a Lisims Gvernment $49, Métis Natin British Clumbia $10, Ttal $60, Envirnmental Impact Statement After receiving the final EIS Guidelines, the Prpnent prepares an EIS (referred t as the Applicatin in the prvincial prcess) that presents an assessment f ptential effects, which is supprted by field baseline studies and publically available infrmatin. Fllwing analysis f the data results, mitigatin measures that are required t avid, reduce, cntrl, r cmpensate fr any adverse effects are identified; this can be an iterative prcess f applying mitigatin, re-mdelling, reviewing results, and adjusting the mitigatin techniques. Envirnmental mnitring and management plans are develped t address adverse effects and are prvided in the EIS. Once the EIS is submitted, the CEA Agency and federal Wrking Grup members may crdinate with the BC EAO t screen the EIS fr cnfrmity against the EIS Guidelines; hwever, the screening step is nt a legislated requirement. Technical review cmments n the EIS frm the federal Wrking Grup will be prvided t Pretivm fr respnse. Public and Abriginal cnsultatin activities will cntinue during the review f the EIS and be supprted by a third pprtunity fr the public t cmment n the EIS. Envirnmental Assessment Reprt Like the prvincial prcess, the CEA Agency prepares an assessment reprt that summarizes the key findings, mitigatin, and cnsultatin issues related t the EA prcess fr the Prject. The EA Reprt is subject t a furth and final public cmment perid prir t being submitted t the federal Minister f the Envirnment fr their review and decisin. Minister s Decisin After taking int cnsideratin the EA Reprt, public cmments, and the adequacy f cnsultatin activities cnducted with Abriginal grups by the CEA Agency, the Minister f the Envirnment is required t issue an EA Decisin Statement. Under Sectin 53(1) f the CEAA 2012, if the Minister finds that the Prject is nt likely t cause significant adverse effects, then, as required by Sectin 54(1), 2-12 ERM RESCAN PROJ# REV C.1 JUNE 2014

13 ASSESSMENT PROCESS the Minister will issue an EA Decisin Statement that describes the mitigatin and fllw-up cnditins that the Prpnent must cmply with. The milestnes that have been achieved thrugh the EA prcess t date are summarized in Table Table Assessment Prcess Milestnes fr the Brucejack Gld Mine Prject EA Prcess Milestnes BC EAO receives Prject Descriptin January 28, 2013 CEA Agency receives Prject Descriptin January 28, 2013 BC EAO issues Sectin 10 Order February 6, 2013 CEA Agency accepts Prject Descriptin fr Review February 8, 2013 CEA Agency psts Prject Descriptin fr Public Cmment February 8, 2013 CEA Agency issues Ntice f Determinatin March 25, 2013 CEA Agency issues Ntice f Cmmencement March 26, 2013 CEA Agency psts draft EIS Guidelines fr Public Cmment March 26, 2013 CEA Agency issues Final EIS Guidelines May 24, 2013 BC EAO issues Sectin 11 Order July 4, 2013 Jint Envirnmental Assessment Wrking Grup Meeting and Site Tur September 4 and 5, 2013 BC EAO psts draft AIR fr Public Cmment Nvember 5, 2013 Open Huse Gitlaxt aamiks (New Aiyansh), BC Nvember 25, 2013 Open Huse Stewart, BC Nvember 26, 2013 Open Huse Hazeltn, BC Nvember 27, 2013 Open Huse Dease Lake, BC Nvember 28, 2013 Open Huse Iskut, BC Nvember 28, 2013 BC EAO issues apprved AIR May 2, 2014 Applicatin submitted fr Screening t the BC EAO June 2014 Date Jint Envirnmental Assessment Wrking Grup The BC EAO and the CEA Agency established the EA Wrking Grup and began t hld Prject-related meetings n September 4, The purpse f the Wrking Grup is t review and cmment n key EA dcuments, including the AIR, the EIS Guidelines, the Applicatin/EIS, and the BC EAO and CEA Agency assessment reprts. Typical membership f an EA Wrking Grup includes representatives frm all levels f gvernment (federal, prvincial, reginal, and municipal), ptentially affected Abriginal grups, and ther stakehlders as required. The members f the Brucejack Gld Mine Prject Wrking Grup are identified in Table Table Membership f the Brucejack Gld Mine Prject Envirnmental Assessment Wrking Grup Membership f the Brucejack Gld Mine Prject Envirnmental Assessment Wrking Grup Abriginal Affairs and Nrthern Develpment Canada BC Envirnmental Assessment Office BC Ministry f Envirnment Alaska Department f Natural Resurces BC Ministry f Energy and Mines BC Ministry f Frests, Lands and Natural Resurce Operatins (cntinued) PRETIUM RESOURCES INC. 2-13

14 APPLICATION FOR AN ENVIRONMENTAL ASSESSMENT CERTIFICATE / ENVIRONMENTAL IMPACT STATEMENT Table Membership f the Brucejack Gld Mine Prject Envirnmental Assessment Wrking Grup (cmpleted) Membership f the Brucejack Gld Mine Prject Envirnmental Assessment Wrking Grup BC Ministry f Jbs, Turism and Skills Training Canadian Envirnmental Assessment Agency Fisheries and Oceans Canada Natural Resurces Canada Nrthern Health Tahltan Central Cuncil Transprt Canada US Envirnmental Prtectin Agency Regin 10 BC Ministry f Transprtatin and Infrastructure Envirnment Canada Health Canada, BC Regin Nisga a Lisims Gvernment Reginal District f Kitimat-Stikine Tahltan Heritage Resurces Envirnmental Assessment Team Skii km Lax Ha (Represented by Big Sky Cnsulting) United States Frest Service - Department f Agriculture 2.3 AUTHORIZATIONS The Prpnent is intending t pursue cncurrent permitting under the Cncurrent Apprval Regulatin (BC Reg. 371/2002) fr key prvincial authrizatins that wuld enable cnstructin f the transmissin line cmpnent f the Prject t begin as sn as pssible fllwing the issuance f an EA Certificate, as well as authrizatins under the Water Act (1996h) related t mine site water management and under the Mineral Tenure Act (1996d) fr a mining lease. The Prpnent anticipates that the transmissin line applicatins wuld include prvincial authrizatins such as a Licence f Occupatin under the Land Act (1996c), an Occupant Licence t Cut under the Frest Act (1996a), and ptable water authrizatins under the Drinking Water Prtectin Act (2001) fr the Knipple Transfer Area and Tide Staging Area camps. The specific list f permits that wuld be sught cncurrently will be cnfirmed thrugh with the Majr Prjects Office f the Gvernment f BC, and representatives f the apprpriate permitting authrities. In additin t pursuing cncurrent permitting f the abve referenced authrizatins, Pretivm will engage in the prvince s crdinated authrizatins prcess t apply fr multiple prject-specific authrizatins required frm the varius natural resurce agencies. The Prpnent anticipates that this wuld include prvincial authrizatins under the Mines Act (1996e), the Envirnmental Management Act (2003), the Water Act (1996h), the Land Act (1996c), the Mining Right f Way Act (1996f), and the Transprtatin Act (2004a). Table belw lists prvincial authrizatins ptentially required fr the varius Brucejack Gld Mine Prject cmpnents. The list is nt intended t be exhaustive due t the cmplexity f gvernment regulatry prcesses and the large number f minr permits, licences, apprvals, cnsents and authrizatins, and ptential amendments that will be required thrughut the life f the mine. Table Ptential Prvincial Authrizatins Required Permit Required Enabling Legislatin Applicable Prject Cmpnent Occupant Licence t Cut Frest Act (1996a) Prject areas requiring vegetatin remval, including the transmissin line ROW suth f the Knipple Glacier, the Knipple Transfer Area and the Bwser Aerdrme (cntinued) 2-14 ERM RESCAN PROJ# REV C.1 JUNE 2014

15 ASSESSMENT PROCESS Table Ptential Prvincial Authrizatins Required (cntinued) Permit Required Enabling Legislatin Applicable Prject Cmpnent Wildlife Salvage and Remval Wildlife Act (1996j) General mine site r access rad, hwever need fr this permit is unlikely as there is nt currently expected t be a need fr wildlife relcatin Licence f Occupatin Land Act (1996c) Suthern part f the transmissin line, suth f Bwser River Waterwrks Cnstructin Permit Drinking Water Prtectin Act (2001) Water System Operatin Permit Drinking Water Prtectin Act (2001) Sewage Registratin Amendment Water License Hazardus Waste Registratin Amendment Air Emissins Discharge Permit Permit Apprving Wrk System and Reclamatin Prgram License f Occupatin and Statutry Right-f-Way Envirnmental Management Act (2003) - Municipal Wastewater Regulatin (BC Reg. 27/2012) Water Act (1996h) and Water Prtectin Act (1996i) Hazardus Waste Regulatins (BC Reg. 63/88) Envirnmental Management Act (2003) Mines Act (1996e) Land Act (1996c) New ptable water supply systems New ptable water supply systems Brucejack Camp sewage treatment plant Infrastructure and facilities that stre, use and/r divert surface water Amendment f existing registratin t address additinal wastes and/r changes in quantities Amend current permit fr applicable air emissins at mine site area All areas within the Mines Act Permit area disturbed by mining unless exempted; includes mine site, quarry, access rad, nrthern sectin f the transmissin line, Knipple Transfer Area, Bwser Aerdrme Transmissin line ROW suth f the Bwser River Mining Lease Mineral Tenure Act (1996d) General Prject areas within which minerals/ aggregate will be prduced Explsives Strage and Use Permit Mines Act (1996e) Surface and undergrund explsive strage Effluent discharge permit Envirnmental Management Act (2003) Fuel Strage Registratin Envirnmental Management Act (2003) - Petrleum Strage and Distributin Facilities Strm Water Regulatin (BC Reg. 168/94) Mine water treatment plant and peratins sewage treatment plant discharges, and tailings management Fuel strage with >100,000 L stred per lcatin; includes mine site and Knipple Transfer Area Sectin 14 Inspectin Permit Heritage Cnservatin Act (1996b) Areas f archaelgical imprtance; renewal when necessary Temprary Use Permit Land Act (1996c) Pre-cnstructin site investigatins n transmissin line sectins ff f Pretivm mineral claims, unless written permissin is btained frm the tenure hlder Mining Right f Way Permit Mining Right f Way Act (1996f) Right f way access within Crwn r private lands Fd Premises Permit Public Health Act (2008) - Fd Premises Regulatin (BC Reg. 210/99) and Drinking Water Prtectin Act (2001) On-site catering facilities; amendment fr Prject, new fr Knipple Transfer Area (cntinued) PRETIUM RESOURCES INC. 2-15

16 APPLICATION FOR AN ENVIRONMENTAL ASSESSMENT CERTIFICATE / ENVIRONMENTAL IMPACT STATEMENT Table Ptential Prvincial Authrizatins Required under the Cncurrent Permitting and Crdinated Authrizatins Prcesses (cmpleted) Permit Required Enabling Legislatin Ptentially Impacted Prject Cmpnent Filing f Certificatin Letter Access Permit Public Health Act (2008) - Sewage Dispsal Regulatin Transprtatin Act (2004a) and Mtr Vehicle Act (1996g) Camps < 100 persns Access rad intersectin with Highway 37; pssible amendment f existing permit Public Highway Permit Transprtatin Act (2004a) Access rad intersectin with Highway 37; highway signs Apprval r Ntificatin f changes in r abut a stream Water Act (1996h) and Water Regulatin (BC Reg. 204/88 ) Cmpnents that invlve wrk in r abut a stream and that are nt already addressed via the Mines Act Permit Burning Permit Wildfire Act (2004b) General Grundwater well Registratin Water Act (1996h) Grundwater wells Special Waste Generatr Permit Envirnmental Management Act (2003) Municipal Wastewater Regulatin (BC Reg. 27/2012) Waste ils Prvincial Authrizatins Cncurrent Apprvals Framewrk The Cncurrent Apprval Regulatin (BC Reg. 371/2002) sets ut the prvisins related t cncurrent permit apprvals. Statutry permit apprval prcesses are nrmally mre specific than thse required fr the EA level f review and, fr example, may require detailed and pssibly final engineering design infrmatin fr certain permits. Under the Cncurrent Apprval Regulatin (BC Reg. 371/2002), an applicant must submit cncurrent permit applicatins within seven days f ntificatin f the acceptance f the EA Applicatin fr review by the BC EAO. The prvincial ministry respnsible fr the permit must identify any additinal infrmatin required fr the permit(s) within 75 days f the ntificatin f acceptance f the Applicatin. The ministry respnsible fr the permit must make a decisin t issue, reject, r pstpne the decisin, within 60 days f the EA Certificate being issued. T be eligible fr cncurrent review, the apprval must be required t cnstruct, perate, mdify, dismantle, abandn, r therwise undertake part r all f the reviewable prject that is the subject f the EA. Any such authrizatin is eligible fr cncurrent review except a Certificate f Public Cnvenience and Necessity under the Utilities Cmmissin Act (1996j). Pretivm is prpsing t apply under the Cncurrent Apprval Regulatin (BC Reg. 371/2002) fr authrizatins required t cnstruct the prtin f the 55-km lng pwer transmissin line extending generally suthward frm the Bwser River crssing, t cnnect with the prvincial grid at the Lng Lake Hydr Prject near Stewart. Pretivm is als prpsing t apply cncurrently fr Mining Leases and Water Licences required at the Brucejack Mine Site, and fr ptable water related authrizatins fr the Knipple Transfer Area and Tide Staging Area camps Crdinated Authrizatin Framewrk In 2011, under a Memrandum f Understanding between the BC Ministry f Energy and Mines (BC MEM) and the BC Ministry f Frests, Lands and Natural Resurce Operatins (BC MFLNRO), which was amended in 2012 and again in 2013, it was agreed that, nce a majr mine prject advanced t a stage 2-16 ERM RESCAN PROJ# REV C.1 JUNE 2014

17 ASSESSMENT PROCESS where multiple authrizatins were required, the Chief Inspectr f Mines culd establish a prjectspecific Mine Review Cmmittee (MRC) t crdinate and review the applicatins and prvide advice t statutry decisin makers. As well, the Chief Inspectr f Mines culd request that the BC MFLNRO chair the cmmittee and lead First Natins cnsultatins n behalf f the BC MEM. Once a prjectspecific MRC is established, MFLNRO assigns a prject manager t manage the review prcess and a cnsultatin advisr t lead First Natins cnsultatins. Under the Memrandum f Understanding, the crdinated authrizatins prcess is defined as a prcess initiated by the MRC aimed at harmnizing First Natins cnsultatin and crdinating the review f multiple authrizatins that may be required frm the varius natural resurce agencies fr new r expanding majr mines. The crdinated authrizatin prcess is meant t imprve cnsistency, and eliminate verlap and duplicatin in prcess and infrmatin requirements by the varius natural resurce agencies. The MRC is strictly an advisry cmmittee, and the Statutry Decisin Makers maintain respnsibility fr their respective individual permitting decisins (BC MFLNRO 2013). Pretivm will engage in the crdinated authrizatins prcess t apply fr mst f the prvincial authrizatins required t prgress the Prject, including authrizatins under the Mines Act (1996e) and the Envirnmental Management Act (2003). The Prpnent anticipates that this will be carried ut in phases, with specific applicatins fr permits, licences, and ther authrizatins being effectively bundled tgether t allw fr a crdinated review by the varius natural resurce agencies invlved Federal Authrizatins Table presents a list f federal authrizatins that are anticipated t be required t develp the Prject. Other federal legislatin Species at Risk Act (2002b), Migratry Birds Cnventin Act, 1994 (1994) and the Metal Mining Effluent Regulatin (SOR/ ), may be relevant in terms f evaluating, managing, mnitring, and reprting n envirnmental effects f the Prject, but there are n specific permitting requirements. As there are n crssings with the ptential t cause serius harm t fish r fish habitat as a result f the Brucejack Gld Mine Prject, n Fisheries Act (1985b) authrizatins are anticipated. There are n anticipated authrizatins required under the Navigatin Prtectin Act (NPA; 1985d) as n effects n listed waterbdies are anticipated, and the Prpnent is nt pting-in under the NPA. It is assumed that Brucejack Lake will be cnsidered nn-navigable and an exemptin under Sectin 23 f the NPA will nt be required fr the depsitin f tailings int Brucejack Lake. Cnstructin at stream crssings alng the access rute has already been addressed under an existing Mines Act (1996e) permit and NPA authrizatins. It is als expected that the Prject will nt trigger the flw threshlds identified in Sectin 3(1)(a) and 3(1)(b) f the Internatinal River Imprvement Regulatin (CRC, c 982) and that the Prject will be exempted frm btaining an authrizatin. Other permits under the Explsives Act (1985a), Radicmmunicatin Act (1985e), and Nuclear Safety and Cntrl Act (1997)are required and are listed in Table Table Anticipated Federal Authrizatin Requirements Federal Authrizatins Legislatin/Regulatins Prject Cmpnent Emergency Respnse Assistance Plan Envirnmental Assessment Decisin Statement Transprtatin f Dangerus Gds Act (1996j) Canadian Envirnmental Assessment Act (1992) Transprt f dangerus gds t and frm the site Designated physical activities and prject cmpnents Explsives Magazine Licence Explsives Act (1985a) Strage f pre-packaged explsives Radi Licences Radicmmunicatin Act (1985e) On-site radi cmmunicatin system Radiistpe Licence (Nuclear Density Gauges/X-ray analyzer) Nuclear Safety and Cntrl Act (1997) Flw meters (i.e., within discharge pipes) PRETIUM RESOURCES INC. 2-17

18 APPLICATION FOR AN ENVIRONMENTAL ASSESSMENT CERTIFICATE / ENVIRONMENTAL IMPACT STATEMENT 2.4 TRANSBOUNDARY EFFECTS Sectin 2 f the Internatinal River Imprvement Act (IRIA; 1985c) defines internatinal river imprvement as a dam, bstructin, canal, reservir, r ther wrk with the purpse r effect which is: t increase, decrease, r alter the natural flw f an internatinal river; and t interfere with, alter, r affect the actual r ptential use f the internatinal river utside Canada. Sectins 3(1) (a) and 3(1) (b) f the IRIA s Internatinal Rivers Imprvement Regulatins (CRC, c 982) allw fr the tw fllwing exemptins frm the IRIA: if the imprvement has an effect f less than 3 cm r 0.3 m 3 /s n the flw f water at the Canadian bundary; r if the imprvement is temprary in nature, t be perated fr a perid nt exceeding tw years. The Brucejack Mine Site will be lcated immediately adjacent t Brucejack Lake. Brucejack Lake and Brucejack Creek will be the receiving envirnment f Prject discharges. Brucejack Creek drains t the Unuk River, which crsses the Canadian/United States (US) brder apprximately 45 km dwnstream f the Prject. Brucejack Lake has a watershed area f 10.1 km 2. At the Canadian/US brder, the Unuk River has a watershed area f 1,480 km 2. While it is prbable that the Prject will be exempted under the IRIA, as the tw flw change threshlds are unlikely t be met, imprvements under the IRIA in assciatin with the prpsed Prject will include: tailings pipeline (including lake water recirculatin when nt in use); nn-cntact water diversin ditches; cntact water drainage ditches; effluent discharge frm a mine water treatment plant and sewage treatment plant; stream crssing acrss Brucejack Creek (clear-span, built t 100-year fld level); depsitin f waste rck and tailings int Brucejack Lake; and a weir at the lake utlet t supprt accurate discharge measurement (nt intended fr lake strage). Apprvals frm federal Canadian and US custms authrities may be required shuld the Prject transprt materials acrss the brder. Pretivm has included Alaskan and federal US fficials in discussins regarding Prject develpment, including a meeting n April 5, The BC EAO and CEA Agency have als cmmunicated with Alaska and US federal fficials regarding participatin in the EA Wrking Grup. It is expected that Alaska and US federal fficials will review and cmment n this Applicatin/EIS and that their cmments will be cnsidered by bth the BC EAO and CEA Agency when making their recmmendatins t their respective ministers n a final decisin regarding whether t issue an EA apprval fr the Prject. N issues have been raised by US gvernment agencies t date. 2.5 REGIONAL STUDIES There are n reginal studies in the vicinity f the Prject as cntemplated under s. 73 and s. 74 f the CEAA ERM RESCAN PROJ# REV C.1 JUNE 2014