KAMI CONCENTRATE STORAGE & LOAD-OUT FACILITY, Québec

Transcription

1 KAMI CONCENTRATE STORAGE & LOAD-OUT FACILITY, Québec Kami Iron Ore Project Environmental Impact Statement Alderon Iron Ore Corp. 10 Fort William Place, 8th Floor St. John s, NL A1C 5W2 Tel: Fax: (709) (709) Kami Concentrate Storage and Load-Out Facility, Québec Plain Language Summary Prepared by Stassinu Stantec Limited Partnership Kami Iron Ore Project Environmental Impact Statement PLAIN LANGUAGE SUMMARY September 2012

2 Kami Iron Ore Project Environmental Impact Statement Plain Language Summary Kami Iron Ore Project. a summary of the environmental impact statement ii

3 Foreword This document is intended to be a non-technical summary of the Environmental Impact Statement (EIS) for the Kami Concentrate Storage and Load-out Facility (Kami Terminal) in Sept-Îles, Québec proposed by Alderon Iron Ore Corp (Alderon). The purpose of this document is to provide an overview of key findings of the EIS with respect to potential environmental effects as well as commitments to managing those effects to acceptable levels over the life of the Project. This document is intended to support Aboriginal engagement and public consultation and is available in English and French. Readers are encouraged to review the full EIS document for additional details on the assessment. Kami Iron Ore Project Environmental Impact Statement Plain Language Summary Printed on EarthChoice (Rainforest Alliance Certified and FSC Certified) Paper iii

4 Kami Iron Ore Project Environmental Impact Statement Plain Language Summary iv

5 Table of Contents 1.0 INTRODUCTION Project Overview Environmental Assessment Process Purpose of the EIS Federal Requirements Provincial Requirements Cooperative EA Process PROJECT DESCRIPTION Purpose of and Need for the Project Project Description Location Components Activities Schedule Labour Force Requirements SCOPE OF THE ASSESSMENT Scope of the Project Factors to be Considered Scope of the Factors Identification of VECs Spatial and Temporal Boundaries PROJECT ALTERNATIVES Alternatives to the Project Alternative Means of Carrying out the Project CONSULTATION Public and Aboriginal Consultation and Engagement Activities undertaken for the EA EXISTING ENVIRONMENT ENVIRONMENTAL EFFECTS ASSESSMENT Method and Approach Valued Ecosystem Components Atmospheric Environment Landforms, Soils, Snow and Ice Water Resources Wetlands Freshwater Fish, Fish Habitat and Fisheries Birds, Other Wildlife and Their Habitats and Protected Areas Species at Risk and Species of Conservation Concern Historic and Cultural Resources Current Use of Lands and Resources for Traditional Purposes by Aboriginal Persons Other Current Use of Lands and Resources Community Services and Infrastructure Health and Community Health Economy, Employment and Business Effects of the Environment on the Project Method and Approach Issues Potential Environmental Effects Mitigation Measures Residual Environmental Effects Kami Iron Ore Project Environmental Impact Statement Plain Language Summary v

6 Kami Iron Ore Project Environmental Impact Statement Plain Language Summary 7.4 Effects of Possible Accidents or Malfunctions Method and Approach Issues Potential Environmental Effects Residual Effects Effects on Capacity of Renewable Resources Cumulative Environmental Effects Approach Scoping Issues Potential Cumulative Effects Mitigation Measures Residual Effects FOLLOW-UP PROGRAM BENEFITS OF THE ENVIRONMENTAL ASSESSMENT TO CANADIANS OVERALL CONCLUSIONS OF THE PROPONENT REFERENCES APPENDIX A: VEC Summary Tables and Residual Effects Summary Matrices APPENDIX B Complete Record of all Comments Identified During Consultation and Engagement Activities with Responses...75 vi

7 1.0 INTRODUCTION Alderon Iron Ore Corp. (Alderon) is proposing to develop and operate an iron ore mine on the Kamistiatusset (Kami) Property in western Labrador, which will have a nominal capacity of 16 million metric tonnes of iron ore concentrate each year that will be transported by existing rail lines to the Pointe-Noire Terminal that is part of the Port of Sept-Îles, Québec (the Project). Alderon is committed to taking a responsible approach to social, economic and environmental performance that is consistent with the priorities of our stakeholders. Alderon s goal is to build and maintain positive and long-term relationships with stakeholders of the proposed Project. Alderon is committed to building relationships, based on mutual trust and respect and collaborating with Aboriginal groups that may be affected by the Project and that have asserted or established Aboriginal rights, Aboriginal title or treaty rights or whose traditional land and resource use activities may be affected by the Project. This document describes the environmental effects of the Kami Concentrate Storage and Load-out facility that Alderon proposes to build at the Port of Sept-Îles (Kami Terminal). A separate summary document has been prepared to describe Alderon s proposed mines and facilities in western Labrador (Kami Mine). 1.1 Project Overview Alderon is proposing to develop an iron ore mine on the Kami Property located in western Labrador. The mine property is located south of the towns of Wabush and Labrador City in Newfoundland and Labrador and east of Fermont, Québec. The Kami Iron Ore Mine and Rail is located entirely within Labrador. The mine will produce a nominal capacity of 16 million metric tonnes of iron ore concentrate per year. Concentrate will be transported by existing rail to the Kami Terminal where Alderon s goal is to build and maintain positive and long term relationships with stakeholders of the proposed Kami Project. the concentrate unloading, stacking, storage and reclaiming facility, and associated rail infrastructure will be located on land within the jurisdiction of the Sept-Îles Port Authority. Kami Iron Ore Project Environmental Impact Statement Plain Language Summary 1

8 Kami Iron Ore Project Environmental Impact Statement Plain Language Summary ± Ungava Bay Sept-Îles _ ^ Terminal Site Nain AT L A N T I C Natuashish OCEAN Hopedale Schefferville Postville Tshiuetin Railway Smallwood Rigolet Reservoir Churchill Falls Labrador City _ Fermont ^ Cartwright Sheshatshiu Happy Valley-Goose Bay Wabush Charlottetown Kami Mine Site Forteau Quebec North Shore and Labrador Railway Sept Îles _ ^ Terminal Site FIGURE ID : ALD_ST_697 Gulf of St. Lawrence 0 50 Kilometres 2 100

9 Kami Iron Ore Project General Location ± FIGURE ID: ALD_ST_ The Kami Terminal consists of a rail loop and a concentrate unloading, stacking, storage, and reclaiming facility designed to store and transport the ore before shipping it to market. Arnaud Company Railway Existing Conveyor Baie des Sept-Îles ^_ Port of Sept-Îles Property Terminal Site Golfe du St - Laurent Île Manowin Île Grande Basque Sept-Îles Québec North Shore and Labrador Railway QUÉBEC Île Petite Boule Kamistiatusset Mine Site ^_ ^_ Terminal Site ATLANTIC OCEAN LABRADOR Kami Iron Ore Project Environmental Impact Statement Plain Language Summary Kilometres Île Corossol 3

10 Kami Iron Ore Project Environmental Impact Statement Plain Language Summary 1.2 Environmental Assessment Process Purpose of the EIS The submission of the Environmental Impact Statement (EIS) is an important step in the environmental assessment review process. The EIS is a careful and detailed consideration of how the Kami Terminal could affect the residents, communities, and natural environment surrounding the site. The EIS addresses the issues raised by regulators, the public and Aboriginal through Alderon s public consultation process. The EIS will be reviewed by the EA Committee, including subject area experts from government and regulatory agencies and is available for public review. Review comments of the EA Committee and the public will be considered when a determination of the environmental implications of the Project is made by the federal and provincial governments. The EIS consists of a Plain Language Summary, an Executive Summary, Volume 1 (Kami Iron Ore Mine and Rail Infrastructure) and Volume 2 (Kami Concentrate Storage and Load-out Facility) Federal Requirements Federal approvals will be required from: Fisheries and Oceans Canada (DFO) (Fisheries Act); Transport Canada (Navigable Waters Protection Act); Natural Resources Canada (Explosives Act); and Canadian Transportation Agency (Canada Transportation Act). Under CEAA, a comprehensive study level of assessment will be required since the Kami mine will have an iron ore capacity of 3,000 t/d or more. An environmental assessment is a decisionmaking tool used to promote sustainable development by evaluating the potential environmental effects of major developments before they are constructed. This process involves various government agencies as well as public, stakeholder and Aboriginal consultation and engagement. 4

11 1.2.3 Provincial Requirements Because the mine will be located entirely within Newfoundland and Labrador, and the facilities at the Port of Sept-Îles will be located on federal lands, the Kami Terminal is not subject to an environmental assessment under the laws of the province of Québec, as confirmed by the ministère du Développement durable, de l Environnement et des Parcs (MDDEP). However, Alderon has committed to maintaining continued communication with MDDEP to ensure that updates and information is provided on an ongoing basis Cooperative EA Process The Kami Iron Ore Mine and Rail Infrastructure will require approvals from provincial and federal governments, including environmental assessment approval under the Newfoundland and Labrador Environmental Protection Act and federal Canadian Environmental Assessment Act (CEAA). Both governments are working together to use one environmental assessment to satisfy their respective regulatory requirements. An environmental assessment is a decisionmaking tool used to promote sustainable development by evaluating the potential environmental effects of major developments before they are constructed. This process involves various government agencies as well as public, stakeholder and Aboriginal consultation and engagement. The proposed Kami Terminal is required to allow for the transportation of the Project s iron ore products to market. Because the facilities at the Port of Sept-Îles will be located on federal lands, the Kami Terminal is not subject to environmental assessment under the laws of the province of Québec, as confirmed by the MDDEP. Kami Iron Ore Project Environmental Impact Statement Plain Language Summary 5

12 Kami Iron Ore Project Environmental Impact Statement Plain Language Summary 2.0 PROJECT DESCRIPTION 2.1 Purpose of and Need for the Project The purpose of the Project is to develop the iron ore deposits located at the Kami Mine Property in Labrador, and in doing so, to produce iron ore concentrate suitable for sale to international markets. There is currently a very high level of demand for iron ore and steel worldwide, which is creating and maintaining relatively strong markets and good prices for iron and steel. The proposed Kami Terminal, as described in this chapter, is required to allow for the transportation of the Project s iron ore products to market, and are therefore vital to the overall technical and economic viability of the Project. 2.2 Project Description Location The proposed Kami Terminal will be located at the Pointe-Noire Terminal in the Port of Sept-Îles, which is within the region known as the Québec North Shore, along the Gulf of St. Lawrence Components The Kami Terminal components and activities will include the construction and operation of the following key elements: A concentrate unloading, stacking, storage and reclaiming facility; and Associated rail infrastructure (rail loop). Concentrate Unloading, Stacking, Storage and Reclaiming Facility This facility will be designed to receive iron ore concentrate from Labrador, store it and then transport it to the ship loader for eventual shipment to markets. A storage yard will be built measuring approximately 160 m by 340 m in size and will house two piles of iron ore. The substrate of the yard will contain a liner that will act as a barrier to ensure that water from rain and snow (i.e., runoff water) is collected and treated to prevent red water issues. Red water is the term used for water that contains fine particles of iron oxide / hydroxide. A stacker-reclaimer will be designed to meet yard and ship loading requirements. Supply conveyors will be constructed in the yard to feed concentrate from the rail car dumper to a transfer house and from there to the stacker-reclaimer. The yard will also include maintenance facilities, offices, and administrative areas. 6

13 Kami Terminal Components ± Port of Sept-Îles Property Existing Conveyor FIGURE ID: ALD_ST_ Metres Existing Railway Consolidated Thompson Conveyor Line Proposed Rail for Project Begins Proposed Port Authority Common Offload Point Switch Yard Control Room Conveyor Line Proposed By Alderon Re-routed Railway Alderon Concentrate Stockpiles CT Stockpile Baie des Sept-Îles ^_ Storm Water Retention Pond andtreatment Building Railcar Unloading Building Transmission Line Terminal Site Sept-Îles Proposed Alderon Rail Loop Re-routed Access Road Stockpile Yard Rail Loop Approximately 3.5 km of new (single) rail track will be required to connect with the existing Arnaud Company Railway (Chemin de fer Arnaud CFA) railway track at a point several hundred meters southwest of the proposed Terminal. The rail will loop around the site of the existing and future expansion of the Cliffs unloading and concentrate stockpile area. The rail loop will be designed to accommodate a minimum of 120 cars full of iron ore concentrate and will be used exclusively for the unloading of Alderon iron ore concentrate. Kami Iron Ore Project Environmental Impact Statement Plain Language Summary Activities The Kami Terminal will involve the construction, operation and eventual closure and decommissioning of each of the components described above. Construction activities for the Kami Terminal will include the following: Movement of equipment, materials and personnel to, within and from the site; Mobilization and installation of required construction infrastructure; Site preparation (including vegetation clearing, grubbing and excavation as required); Establishing site buildings and other components; Installation of associated systems, equipment and utilities. The main tasks and general sequencing of the construction phase will include, initially, the transportation of equipment and construction materials to and within the site, and the development of lay down areas. Construction lay down areas will be established at strategic locations near the proposed conveyors, rail loop and elsewhere within the Kami Terminal area / footprint. Operations activities will include offloading of iron ore concentrate from railcars. A rail car dumper will be used to unload the iron ore concentrate from rail cars 7

14 Kami Iron Ore Project Environmental Impact Statement Plain Language Summary and conveyor belts will then move the concentrate to the storage yard where it will be stockpiled by a stacker-reclaimer. The conveyor system will also be used to transport the concentrate to an ocean vessel shiploader. In addition to this equipment, a small building will be constructed to store equipment, spare parts, and supplies, and to contain offices for workers Schedule Construction of the Kami Terminal at the Port will begin after the Project has received all the necessary government approvals and permits. The proposed start date of construction is late 2013 with completion by the end of The Kami Terminal is expected to begin operating in fall 2015 and continue until approximately Phase/Activity Feasibility and Detailed Engineering EA and Permitting Construction Operations Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q Labour Force Requirements Projected construction staff numbers will range from approximately 30 to nearly 300 workers at the peak periods. Staffing will include construction management, engineering, labourers, millwrights, iron workers, carpenters, heavy equipment operators, electricians, masons and other trades as necessary to carry out the construction tasks. Most if not all of these positions will be full-time in nature. The phase of construction is expected to occur between approximately late 2013 and The operations phase of the Project will commence upon completion of construction and associated commissioning, and is expected to extend from approximately 2015 to Projected operation staff numbers will be approximately 17 workers, most if not all of which will be full-time employees. 8

15 3.0 SCOPE OF THE ASSESSMENT 3.1 Scope of the Project The scope of the Project for the purpose of the environmental assessment includes all activities and physical works associated with construction, operation, rehabilitation and closure of the proposed Project. 3.2 Factors to be Considered The following factors have been considered as a part of the environmental assessment: The need for the Project; Alternatives to the Project; The purpose of the Project; Alternative means of carrying out the Project that are technically and economically feasible and the environmental effects of any such alternative means; The environmental effects of the Project, including the environmental effects of malfunctions or accidents that may occur in connection with the Project and any cumulative environmental effects that are likely to result from the Project in combination with other projects or activities that have been or shall be carried out; The significance of the environmental effects referenced above; Comments arising from the public and Aboriginal consultation and engagement; Local knowledge and Aboriginal traditional knowledge; Measures that are technically and economically feasible and that would mitigate (lessen) any significant adverse environmental effects of the Project; The requirements of a follow-up program for the Project; The capacity of renewable resources that are likely to be significantly affected by the Project to meet the needs of the present and those of the future. Kami Iron Ore Project Environmental Impact Statement Plain Language Summary 3.3 Scope of the Factors The assessment of environmental effects focuses on Valued Ecosystem Components (VECs). A VEC is a component or attribute that is important for its ecological, legal, scientific, cultural, economic or aesthetic values. VEC specific factors are discussed in Section 7. 9

16 Kami Iron Ore Project Environmental Impact Statement Plain Language Summary Identification of VECs A total of 13 VECs were identified in the EIS Guidelines for review as a result of government, Aboriginal persons, stakeholders and general public interests and concerns. Each VEC is discussed in detail in Section 7. Natural environment VECs are: Atmospheric Environment (air quality, climate, vibration and noise); Landforms, Soils, Snow and Ice (landforms, terrain stability, soil quality and quantity, snow and ice as well as the potential for Acid Rock Drainage (ARD) and metal leaching); Water Resources (quality and quantity of groundwater and surface water resources); Wetlands (lands having the water table at, near, or above ground surface, or are saturated long enough to promote wetland aquatic processes); Freshwater Fish, Fish Habitat, and Fisheries (freshwater fish species and the habitat upon which they depend and fisheries activities); Birds, Other Wildlife and their Habitats, and Protected Areas (migratory and non-migratory species that are potentially feeding, breeding, moving and/or migrating through the Project area, their habitat, and Protected Areas); Species at Risk and Species of Conservation Concern (species of plant or animal, and/or its critical habitat, that is of provincial, national or international importance, particularly where the species and/or its critical habitat is protected under federal or provincial legislation). A VEC is a component or attribute that is important for its ecological, legal, scientific, cultural, economic or aesthetic values. 10

17 Human environment VECs are: Historic and Cultural Resources (archaeological sites, paleontological fossil sites, cultural or spiritual sites and historic buildings and properties); Current Use of Land and Resources for Traditional Purposes by Aboriginal Persons (lands and resources of specific social, cultural or spiritual value to the Aboriginal persons that are currently used for traditional purposes); Other Current Use of Lands and Resources (other industrial, residential or commercial uses of the land); Community Services and Infrastructure (employment, transportation, social, education and health services, safety and security, and housing and accommodation); Health and Community Health (human health and wellness and family life); Economy, Employment, and Business (new economic activity, workers and local businesses) Spatial and Temporal Boundaries Spatial and temporal boundaries are the study areas and time frames used to investigate potential environmental effects of the Kami Terminal. Spatial boundaries are also known as the study area. The spatial boundaries consider the geographic extent over which the Kami Terminal s environmental effects may occur, recognizing that some environmental effects may extend beyond the Project Development Area (footprint). Spatial boundaries differ by VEC depending on the nature of predicted effects. Temporal boundaries consider timing and scheduling of Kami Terminal activities, and the time required for recovery from an environmental effect. In general, temporal boundaries for assessment include the construction, operation and maintenance and decommissioning and reclamation phases of the Kami Terminal. For most of the VECs, the temporal boundaries for each Project phase consider a construction period of approximately two years, and operation and maintenance for approximately 17 years. There are currently no intention to close or decommission the Kami Terminal. Upon conclusion of Alderon operations, the infrastructure will be transferred (sold) to another owner. The facilities will be maintained throughout operations with the assumption that it will be operated on a continual basis, even after Alderon has ceased operation. Kami Iron Ore Project Environmental Impact Statement Plain Language Summary 11

18 Kami Iron Ore Project Environmental Impact Statement Plain Language Summary 4.0 PROJECT ALTERNATIVES The EIS Guidelines require consideration of alternatives to the Project and alternative means of carrying out the Project that are technically and economically feasible. 4.1 Alternatives to the Project The need for and purpose of this Project is to develop the iron ore deposits within the Kami Property and to produce iron ore concentrate suitable for sale to international markets. Addressing the overall, worldwide requirement for iron ore could potentially be addressed through other development projects or initiatives, which may also provide associated economic benefits to the regions and jurisdictions in which they are developed. With the exception of this proposed Project, however, no other such alternatives are within the ability and responsibility of Alderon. The only alternative to Alderon s construction and operation of the Project is a decision to not proceed with this development the no-go decision. The proposed Project provides a technically feasible, economically viable and attractive, and environmentally and socially responsible means of addressing the identified need for and purpose of the development and one which can and will be planned and implemented in a manner that avoids or reduces potential adverse environmental effects and optimizes socio-economic benefits. 4.2 Alternative Means of Carrying out the Project Description of Alternative Means The EA process allows for the identification, analysis, and evaluation of different project concepts and approach options and includes environmental considerations into project planning at an early stage so it may potentially influence the Project design. The EIS considers possible alternative means of carrying out the Project that are technically and economically feasible, and the potential environmental effects of any such alternative means. Alderon investigated different port locations and alternative methods to transport the iron ore concentrate from the Kami Mine in Labrador to steel refineries around the world (shown in table below). 12

19 Environmental Effects of Technically and Economically Feasible Alternative Means Project Component Location of the terminal facility Alternative Considered Option 1: facility located at the Pointe- Noire Terminal that is part of the Port of Sept-Îles Option 2: facility located at Pointe-Noire terminal south-east of Option 1 Option 3: facility located at Seven Lands Development Corp. near mouth of Moisie River Option 4: build a new port in Labrador Use existing rail lines at Port of Sept-Îles Build new rail lines at Port of Sept-Îles Option 1: Work with Cliff Bloom Lake to build a new rail loop using some of their existing track Option 2: Build a new rail loop that circles outside of Cliff Bloom Lake rail loop Option 3: Build a new rail loop located west of the Pointe-Noire Road Transport iron ore concentrate by truck to Port Transport iron concentrate by new railroad through Labrador and Québec Economic & Technical Feasibility Installation costs are less because located closer to the shiploader Technically feasible Port of Sept-Îles is a very active industrial port site and has been in operation for decades Moving concentrate a shorter distance could reduce energy use and the amount of dust released Little to no loss of habitat Greater installation costs Technically feasible Moving concentrate a longer distance could increase energy use and the amount of dust released Option 3 location has no access to the shore and additional facilities would need to be constructed. Not economically feasible. Technically feasible Would require construction activity and works in the marine environment which would decrease potential marine habitat Building a new port in Labrador is not economically feasible Technically feasible Would require construction activity and works in the marine environment which would decrease potential marine habitat Has economic risk Dead-end line requires train to be broken down for unloading Breaking the train cars into smaller sections uses more locomotive fuel, releases higher emissions and creates more noise Has economic and operational risk Grading and a stream crossing required Less economic and operational risks Grading and a stream crossing required Costly construction Landscape would need to be dramatically altered Construction would require substantial rock cutting, blasting and other earth-moving efforts Ruisseau à la Baleine would need to be redirected Not economically feasible Shipping goods by truck burns more fuel, releases more emissions and creates more traffic on the highway Not economically feasible Building a new railroad would alter habitat Construction would require more resources than using already existing rail line Preferred Option Kami Iron Ore Project Environmental Impact Statement Plain Language Summary Selection of a Preferred Alternative Means The selected Project components, noted above, were identified as the preferred technically and economically preferred option with the least potential for effects to the environment from Project activities. The environmental effects of the preferred options are assessed in the EIS. 13

20 Kami Iron Ore Project Environmental Impact Statement Plain Language Summary 14

21 5.0 CONSULTATION 5.1 Public and Aboriginal Consultation and Engagement Activities undertaken for the EA Since the acquisition of the Kami Property in Labrador in December 2010, Alderon has worked to establish open and transparent communication with various potentially interested or affected individuals and organizations. Alderon s approach includes engagement with Aboriginal groups, public stakeholders and regulatory agencies. The objectives of this consultation and engagement program were identified in accordance with the EIS Guidelines (CEA Agency and DOEC 2012), the Newfoundland and Labrador Environmental Protection Act (NLEPA), and the Canadian Environmental Assessment Act (CEAA). The overall objectives of the consultation and engagement program are to: Provide Project information and updates on a regular basis; Engage Aboriginal groups and stakeholders throughout the environmental assessment (EA) process and during the life of the Project; Identify issues of concern with the Project early in the process; Adapt the Project design, where possible, to avoid and mitigate adverse environmental effects; and Demonstrate how issues and concerns raised during engagement activities have been addressed in the EIS. Kami Iron Ore Project Environmental Impact Statement Plain Language Summary Alderon s consultation and engagement program for the EA includes five phases shown below in an overview of the EA timeline, including associated consultation and engagement phases and program milestones. Timeline for Consultation and Engagement Program Pre-Project Regitration Initial information sharing and relationship building Ongoing Post-Regitration Project Registration October 17, 2011 EA Notice of Commencement January 27, 2012 Project information sessions Receive comments on the Project Identify issues EIS Pre-Submission Project information sessions Receive comments on the Project Identify issues EIS Submission EIS Post-Submission Project information sessions Respond to issues and concerns EA Approval Post-EA Share information and address concerns throughout the life of the Project Ongoing Aboriginal Engagement and Public Consultation 15

22 Kami Iron Ore Project Environmental Impact Statement Plain Language Summary Public and Regulatory Consultation Activities Public stakeholders engaged by Alderon include residents of the towns of Labrador City, Wabush, Fermont and Sept-Îles. In addition to stakeholders within these boundaries, Alderon has also engaged other potentially affected and/or interested stakeholders including provincial and federal government agencies and departments, non-governmental organizations, economic development organizations, and outdoor recreation users and outfitters. Public consultation activities include information sharing, general consultation with community members, and key stakeholder meetings. In particular: Public notices were created to share information with the general public and those potentially affected by the Project; A Project website was created to provide Project information, EA documentation, notifications, and consultation materials and provided an area for stakeholders to submit contact information and comments; Public Information Sessions were held to provide information to the general public and other interested stakeholders and receive feedback; Key stakeholder meetings were held to inform key stakeholders on Project design and EIS studies, and identify issues with the Project to be included in the EIS. Consultation with federal and provincial regulatory agencies is an important component of EIS development. Alderon s approach to regulatory consultation is to establish and maintain transparent dialogue with federal and provincial regulators throughout development of the EIS. Consultation activities include ongoing information updates and meetings, including sharing stakeholder and Aboriginal issues as they arise. In addition, Alderon met with reviewing agencies during the development of the EIS to present baseline studies, study methodology and effects assessment for each component chapter. This approach is aimed at informing reviewers, and obtaining feedback early in the process. Issues identified most frequently in relation to the Kami Terminal during public and regulatory consultation include: Availability of housing for workers; Water quality; Dust; Visual Aesthetics; and Cumulative effects on community services and infrastructure. 16

23 Frequency of Issues Identified during Public Consultation Activities Consultation / EA Process Water Resources Economy, Employment and Business Community Services and Infrastructure Project Description / Registration EA Jurisdiction Public Participation Aboriginal Engagement Project Schedule Translation of Project Information Waterbodies Water Quality Water Management Cumulative Effects on Water Resources Local Businesses Apprenticeship and Training Availability of Local Workers Local Economy Cumulative Effects on Economy, Employment and Business Availability of Housing for Workers Community Services Cumulative Effect on Community Services and Infrastructure Wildlife Species Frequency of Issues Kami Iron Ore Project Environmental Impact Statement Plain Language Summary Wildlife, Habitat, and Protected Areas Waterfowl 2 Parks and Protected Areas 1 Project Design and Location Economic Feasibility Location of Concentrate Storage Facility Accidents and Malfunctions Secondary Processing of Iron Ore 1 Location of Waste Rock Piles 1 Atmospheric Environment Dust Air Quality 1 3 Project Phases Monitoring and Follow-Up Post Closure 2 2 Current Use of Lands and Resources Current Use of Lands and Resources for Traditional Purposes by Aboriginal Persons Visual Aesthetics Potential Interaction with Existing Aboriginal Rights/Title Fish Habitat Freshwater Fish, Fish Habitat and Fisheries Species at Risk and Species of Conservation Concern Wetlands Fish Population Cumulative Effects on Fish and Fish Habitat Species at Risk Wetlands

24 Kami Iron Ore Project Environmental Impact Statement Plain Language Summary Aboriginal Engagement Activities Alderon recognizes the importance of building relationships based on mutual trust and respect with Aboriginal groups which may be affected by the Project in order to achieve mutually beneficial outcomes. Alderon is committed to ensuring that potentially affected Aboriginal groups and communities are appropriately engaged so that Alderon can identify, understand and address any potential adverse effects of the Project on those groups and communities and their current use of land and resources for traditional purposes. Alderon s approach to engagement with Aboriginal groups is guided by its Aboriginal Relations Policy. Pursuant to the Aboriginal Relations Policy, Alderon will: Acknowledge potential or established Aboriginal or treaty rights and comply with the requirements of any applicable treaties, laws, regulatory measures and governmental policies; Provide opportunities for Aboriginal groups to share traditional knowledge and information on traditional land and resource use in the project area; Develop an effective, respectful and meaningful engagement process; and Work cooperatively and collaboratively with Aboriginal groups to identify Project effects and develop and implement appropriate mitigation measures, including, where appropriate, the negotiation of agreements to address adverse effects and provide access to benefits. Alderon has engaged with those Aboriginal groups and communities who have treaty rights or recognized or asserted Aboriginal rights or Aboriginal title (collectively referred to as Aboriginal Interests ) and who may be affected by the Project. In order to determine the existence of such Aboriginal Interests, Alderon has reviewed a broad range of information in order to gain a general understanding of the nature of known Aboriginal Interests in the Project and to identify the Aboriginal groups and communities which will be engaged by Alderon. Alderon has identified five Aboriginal groups with Aboriginal Interests which may be affected by the Project. These groups which form the participant list for Alderon s Aboriginal engagement program are: Innu Nation; NunatuKavut Community Council; Uashat mak Mani-Utenam; Matimekush-Lac John; and Naskapi Nation of Kawawachikamach. Alderon has made significant efforts to engage with each of these Aboriginal groups. These efforts are based on Alderon s Aboriginal Engagement Strategy and Action Plan which establishes the framework for a coordinated and comprehensive engagement process which is consistent with the requirements of any applicable treaties, laws, regulatory measures and governmental policies, including the EIS Guidelines. The engagement process commenced prior to Project registration and will continue throughout the life of the Project until closure and decommissioning. 18

25 These engagement efforts consist of four main initiatives: Information Sharing: Alderon has provided each Aboriginal group with a wide range of Project-related information for review and comment, including the Project registration, explanatory brochures, corporate policies and permit applications, translated as appropriate, and has offered to meet with each group to discuss this information and to provide Project updates. This information has also been made available on Alderon s website. Alderon will continue to provide clear, userfriendly and relevant Project-related information to each Aboriginal group on a timely and ongoing basis through the life of the Project to enable the ongoing identification of issues and concerns. Community Engagement: Alderon has met with the leadership of each Aboriginal group to discuss the Project, environmental assessment and the engagement process in order to determine the best means of transmitting Project-information and identifying issues and concerns. Alderon has also made repeated efforts to meet with community members to discuss the Project. As part of community engagement, Alderon has assessed the capacity of each Aboriginal group to participate meaningfully in engagement and where appropriate, has offered to enter into formal engagement arrangements, supported by capacity funding and technical expertise. Alderon has made and will continue to make regular offers to meet with both leadership and the community in order to provide multiple opportunities to each Aboriginal group and community to understand the Project and identify its potential effects upon Aboriginal interests. Traditional land and resource use studies: Alderon has offered to provide funding and technical resources to each Aboriginal group to conduct traditional land and resource use studies and collect traditional knowledge through participant interviews and the mapping of relevant land and resource uses. Where agreements have been concluded, the results of such studies have been used to augment Alderon s understanding of Project effects upon traditional activities. Alderon has also offered to engage directly with those members of Aboriginal communities who may be particularly affected by the Project. Kami Iron Ore Project Environmental Impact Statement Plain Language Summary Mitigation and Avoidance: Alderon will provide opportunities to Aboriginal groups to be consulted on the development of mitigation or avoidance measures where, as a result of information generated through engagement, it is determined that the Project is likely to have adverse effects upon Aboriginal Interests or otherwise adversely affect traditional land and resource use. Such mitigation or avoidance measures may include environmental monitoring, land and cultural protection measures and the negotiation of benefits agreements. Alderon will incorporate information gained during engagement into Project planning and execution and will adapt plans as necessary to take into account the views of Aboriginal groups and communities. 19

26 Kami Iron Ore Project Environmental Impact Statement Plain Language Summary Alderon s engagement efforts have enabled the various Aboriginal groups to identify issues of particular concern. Only one Aboriginal group identified a specific issue in relation to the Kami Terminal. That group was Uashat mak Mani-Utenam which identified as an issue the need to be consulted in relation to the Project as a whole and not simply in relation to the Kami Terminal site. Alderon s approach to engagement with Uashat mak Mani-Utenam and all other potentially affected Aboriginal groups has been a comprehensive one which includes both the Kami Mine and the Kami Terminal. Post-Submission of EIS Following submission of the EIS, Alderon will continue Aboriginal engagement, and public and stakeholder consultation activities. Alderon will continue efforts to engage with potentially affected and/or interested Aboriginal communities, including outreach to Band Councils, capacity building, and community meetings where identified as appropriate by community leaders. 20

27 6.0 EXISTING ENVIRONMENT The Kami Terminal lies within the Municipality of Sept-Îles on Port Authority of Sept-Îles Lands, adjacent to similar load-out operating facilities (Pointe-Noire Terminal). The Pointe-Noire Terminal has been in operation for many decades and contains several industrial and port facilities similar to the Kami Terminal. The region has long been the center of natural resource exploitation and the main resource industries are hydroelectricity generation and mining. Although the wide range of habitats in the Côte-Nord region makes the region attractive to a variety of bird and wildlife species, the Kami Terminal site is in an industrialized area with few natural habitats. Remaining habitat at the Kami Terminal site consists mainly of patches of young mixed forest stands and mature coniferous stands. While freshwater fish habitat is present on the Peninsula, there is none in the Kami Terminal footprint. No species at risk, or species of conservation concern, were observed during field surveys. According to the Centre de données sur le patrimoine naturel du Québec (CDPNQ) database, no flora species with special status are reported for the Port site area (personal communication, MDDEP, July 2011). In 2009, Québec s Côte-Nord Region was home to a population of approximately 96,000, accounting for 1.2 percent of the Québec population. In 2009, Sept-Îles had a population of 25,686 inhabitants. The closest residential and recreational land uses is located approximately 1.5 km from the Kami Terminal site, in the low density Val Sainte-Marguerite. Kami Iron Ore Project Environmental Impact Statement Plain Language Summary There are two Aboriginal reserves in the vicinity of the Kami Terminal site: Uashat and Maliotenam, which are located approximately 10 and 26 km, respectively, to the east of the Kami Terminal site. The Kami Terminal is located within the traditional territory of two Aboriginal groups: the Innu of Uashat mak Mani- Utenam and the Innu of Matimekush-Lac John. Though located near Schefferville approximately 500 km north of Sept-Îles, the Innu of Matimekush-Lac John share their ancestral territory with the Innu of Uashat mak Mani-Utenam. Based on the information available, there is no evidence of current use of lands and resources specifically for traditional purposes by Aboriginal Persons in the Kami Terminal area. Additionally, no Historic and Cultural Resources have been identified in the Kami Terminal area. 21

28 Kami Iron Ore Project Environmental Impact Statement Plain Language Summary The EIS provides detailed descriptions of the existing biophysical and socioeconomic environments that could be affected by the Kami Terminal for each VEC. Details on each specific environmental component are found in the VEC analysis in Chapters 14 through 26. In addition, baseline studies were completed on the following topics: Freshwater fish, fish habitat and fisheries; Water resources; Air quality dispersion modelling; and Socio-economic (including housing, labour force, community services, employment demands, local infrastructure). These stand-alone baseline studies support the evaluation of environmental effects, the development of mitigation measures and monitoring and follow up programs. During the development of these baseline studies government and nongovernment agencies have been engaged in the design and methodology for the collection of data to help ensure a thorough and comprehensive basis for the environmental assessment. 22

29 7.0 ENVIRONMENTAL EFFECTS ASSESSMENT 7.1 Method and Approach Activities associated with each Kami Terminal phase and with accidental events were identified to evaluate potential environmental effects. The potential environmental effects of each phase (construction, operations and maintenance, decommissioning and reclamation) have been assessed for each VEC, based on the pre-existing conditions of each VEC and existing knowledge about the environmental effects of similar projects. Effects remaining after mitigation measures have been applied, also known as residual effects are characterized using specific criteria (direction, magnitude, geographic extent, duration, frequency, and reversibility) that are defined for each VEC. The significance of environmental effects was then determined based on predefined criteria or thresholds for determining the significance of the residual effect. Residual Effects Assessment Summary Matrices are provided in Appendix A. Alderon has undertaken a public consultation program and has engaged with potentially affected Aboriginal groups to understand the issues and concerns of stakeholders and Aboriginal groups. The environmental assessment focuses on these issues and concerns, using an issues-based approach to help stakeholders and Aboriginal groups identify how their issues have been addressed. The main categories in which issues were raised are presented in the figure below on an overall proportionate basis. Kami Iron Ore Project Environmental Impact Statement Plain Language Summary 23

30 Kami Iron Ore Project Environmental Impact Statement Plain Language Summary Proportion of Issues Identified During Aboriginal Engagement and Public Consultation Activities Species at Risk and Species of Conservation Concern 2% Current use of lands and resources for traditional purposes by Aboriginal persons 2% Current Use of Lands and Resources 6% Freshwater Fish, Fish Habitat and Fisheries 8% Birds, Other Wildlife and Their Habitat, and Protected Areas 13% Wetlands 2% Community Services and Infrastructure 21% Water Resources 21% Atmospheric Environment 8% Economy, Employment and Business 17% 24

31 Overview of Environmental Assessment Method Scoping of the Assessment Existing Conditions STEP 1 STEP 2 STEP 3 STEP 4 STEP 5 STEP 6 VEC Selection Rationale for Selection, Issues Identification, Regulatory Setting Project Interactions with the Environment Identification of Environmental Effects Screening of Project-Environment Interaction Selection of Measurable Parameters Identification of EA Boundaries Establish Standards or Thresholds for Determining (also known as Significance Criteria) Describe Existing Conditions Assessment of Project-Related Environmental Effects Description of Project Environmental Effects Mitigation of Project Environmental Effects Characterization of Residual Project Environmental Effects Assess and Respond to Issues Raised by Stakeholder Groups Ongoing Consultation and Issue Scoping Kami Iron Ore Project Environmental Impact Statement Plain Language Summary Assessment STEP 7 Assessment of Cumulative Effects Screening of Cumulative Effects Identification of Other Projects and Activities Characterization of Residual Cumulative Effects Repeat for Each VEC and Environmental Effect STEP 8 Determination of Significance Residual Project-Related Environmental Effects Residual Cumulative Effects Conclusions STEP 9 STEP 10 Follow-Up and Monitoring Summary 25

32 Kami Iron Ore Project Environmental Impact Statement Plain Language Summary 7.2 Valued Ecosystem Components The environmental effects of the Kami Terminal have been assessed in accordance with all applicable environmental assessment regulations, the EIS Guidelines and accepted industry best practices. A summary of the results of the environmental assessment for each VEC is presented below Atmospheric Environment The Atmospheric Environment considers effects of the Kami Terminal on ambient air quality and the acoustic environment (noise). It also takes into consideration Kami Terminal related greenhouse gases (GHGs), vibrations and change in light emissions. Existing information for the study areas was first examined for the assessment and included local climate conditions, existing air pollution, noise and vibration sources, as well as results from recent provincial government air quality monitoring. In addition to using data from existing monitoring stations, the assessment drew largely from an air quality dispersion modeling study conducted for the EIS. Currently, the industrial activities at the Port of Sept-Îles present a source of noise, light and air emissions however, noise and air emissions remain below levels recommended by provincial and federal regulations and guidelines. There are no known sources of vibrations and light pollution levels are considered low. 26

33 Atmospheric Environment Local and Regional Study Areas ± Gallix Clarke Val Sainte-Marguerite Air Quality Study Area ^_ Baie Ste - Marguerite Ferland Baie des Sept-Îles Noise Monitoring Local Study Area Terminal Site Noise Monitoring Regional Study Area Sept Îles Plages Golfe Catallan du St - Laur ent Moisie FIGURE ID: ALD_ST_ GHG emissions have the potential to cause environment effects on a large scale. Therefore the spatial boundary used for reviewing GHG emissions from the Kami Terminal is the province of Québec Issues Issues raised by the public and other stakeholders during engagement activities included dust and air quality. In response to these issues, Alderon is implementing various mitigation measures to control fugitive dust emissions during construction and operations, including enclosed conveyors and dust collectors. Alderon will also participate in the air quality monitoring effort that originated in Sept-Îles. A complete record of all comments with responses is included in Appendix B. Kilometres Kami Iron Ore Project Environmental Impact Statement Plain Language Summary Frequency of issues raised during engagement activities 4 Number of Times Issue was Raised Dust Air Quality 27

34 Kami Iron Ore Project Environmental Impact Statement Plain Language Summary Potential Environmental Effects Construction activities will result in emission of air contaminants such as dust and gas emissions from the combustion of fuel in construction equipment. These emissions will be temporary in nature and are expected to be within regulatory objectives, standards, and guidelines. During the operations phase, rail transportation will release emissions from the diesel-powered engines and dust will be released during the transfer and stockpiling of iron ore. Emissions and dust are expected to occur infrequently and be low in quantity, as well as remain close to the Kami Terminal site. Vibrations and sound emissions will result from construction activities and the transfer of concentrate from rail to container ships. The communities of Val Sainte-Marguerite and Sept-Îles are separated from the facility by 5 and 10 km respectively, and are unlikely to experience noise resulting from activities at Kami Terminal. Due to the distance from the Kami Terminal site to the nearest communities, vibrations from the operation of heavy construction equipment will generally not be of concern. Artificial lighting will be used at the Kami Terminal site during construction and operations and could potentially result in effects on ambient light and the night sky. However, construction activities will be short in duration and during operations, permanent lighting will be installed using the local landscape as a shield. Mitigation Measures Rail car dumping will occur in a closed building, conveyors will be enclosed, dust suppressants and a dust collector system will be used to minimize the release of dust particles. Also operations will adhere to a comprehensive equipment maintenance program, monitoring programs and proper light installation will help to minimize effects. Residual Environmental Effects Given the implementation of mitigation measures, the Kami Terminal is not likely to result in significant adverse environmental effects under normal operating conditions. 28

35 7.2.2 Landforms, Soils, Snow and Ice Landforms, Soils, Snow and Ice includes consideration of landforms, terrain stability, soil quality and quantity, snow and ice as well as the potential for acid rock drainage and metal leaching. The effects of the Kami Terminal on Landforms, Soils, Snow and Ice are mainly discussed under Atmospheric Environment and Water Resources in the EIS. For acid rock drainage and metal leaching, existing information was analyzed, including results from bedrock geology testing, photointerpretation and terrain mapping. Issues No issues were raised during Aboriginal engagement and public consultation activities regarding Landforms, Soils, Snow and Ice at the Kami Terminal. Potential Environmental Effects There are no sensitive or valuable landforms within the Kami Terminal site. Most of the soils within the Kami Terminal area are already disturbed by previous or ongoing industrial activities. No natural undisturbed soils are present in the Port area other than a hillside where part of the concentrate unloading, stacking, storage and reclaiming facility will be located. The hillside will need to be leveled using specialized blasting techniques. The rock material from the blasting will be crushed and used for construction purposes at the site. Early ice breakup is also not considered to be an issue since there are no lakes that freeze-up within or close to the Kami Terminal area that could be affected by airborne dust particles from activities at the Port. In consideration of the absence of valuable landforms and the irrelevance of snow and ice to the Kami Terminal, no assessment of Landforms, Soils, Snow and Ice was conducted in the EIS. Acid rock drainage and metal leaching are assessed in the Water Resources VEC. Kami Iron Ore Project Environmental Impact Statement Plain Language Summary Mitigation Measures As described further in the Water Resources assessment, mitigation measures for soils include erosion control measures which will be implemented during construction. 29

36 Kami Iron Ore Project Environmental Impact Statement Plain Language Summary Residual Environmental Effects The residual environmental effects of the Kami Terminal on Landforms, Soils, Snow and Ice are discussed in Chapters 14 (Atmospheric Environment) and 16 (Water Resources) of the EIS. The assessments conducted for red water, acid rock drainage, metal leaching and dust emissions show that the Kami Terminal is not likely to result in significant adverse residual effects on Landforms, Soils, Snow and Ice under normal operating conditions Water Resources Water Resources include the quality and quantity of groundwater and surface water resources for the area surrounding the Kami Terminal. In June 2012, Alderon collected surface water samples from Kami Terminal area streams as well as from the baie des Sept-Îles. The samples were analyzed for water quality and the results were compared to the provincial and federal standards. Concentrations of water pollutants were significantly below the water quality criteria in the MDDEP Directive 019 for the mining industry, with the exception of ph and total suspended solids. Concentration of metals such as aluminum, copper and iron exceeding the Canadian Council of Ministers of the Environment Canadian Water Quality Guidelines for the Protection of Aquatic Life and/or the Québec Surface Water Criteria were detected. Considering that the ore concentrate storage area and the stormwater retention pond will be lined and that runoff in the Kami Terminal area will be contained and treated before being released into the environment, gathering groundwater was deemed unnecessary for assessment purposes. Water Resources Local and Regional Study Areas ± Regional Study Area Ferland Clarke Baie des Sept-Îles Sept Îles Plages Catallan Moisie Municipality of Sept-Îles Boundary Val Sainte-Marguerite Local Study Area ^_ Gallix Baie Ste - Marguerite Terminal Site Golfe du St - Laur ent FIGURE ID: ALD_ST_ Kilometres 30

37 Issues Issues identified by participants related to Water Resources included effects on waterbodies, water quality, water management at the Kami Terminal site, and cumulative effects. In response to these issues, Alderon will implement mitigation measures such as a water management plan, water treatment including treatment of red water, and dust control. A complete record of all comments with responses is included in Appendix B. Frequency of issues raised during engagement activities Number of Times Issue was Raised Waterbodies Water Quality Water Management 2 2 Cumulative Effects on Water Resources Potential Environmental Effects Construction phase activities will require a stream diversion and installation of watercourse crossings. The rerouting will change the local drainage pattern over a short distance. Testing of geologic materials was conducted to assess the potential for acid rock generation and metal leaching resulting from site preparation activities such as blasting and site preparation. Results of geologic testing suggest that acid rock drainage will not likely arise from the Kami Terminal activities, or use of materials from the site. Kami Iron Ore Project Environmental Impact Statement Plain Language Summary Mitigation Measures Local water quality and quantity will be protected by complying with all regulations and guidelines and implementation of best management practices for spill prevention, surface water management, materials handling, erosion, and sediment control planning. Slopes will be stabilized and engineered to reduce erosion. As part of design, the concentrate storage yard will also be lined and water runoff will be collected and treated before release in order to protect local water quality Residual Environmental Effects Given the implementation of mitigation measures, the Kami Terminal is not likely to result in significant adverse environmental effects under normal operating conditions. 31

38 Kami Iron Ore Project Environmental Impact Statement Plain Language Summary Wetlands Wetlands were included in the EIS Guidelines because wetland environments are important habitat for many wildlife and plant species, water quality and quantity as well as in recognition of the federal and provincial policies concerning wetlands. Wetlands were also raised as an issue during the consultation process. However, no wetlands were identified within the Kami Terminal site, and for that reason it was determined that no assessment of the VEC was necessary. Issues An issue was raised regarding the presence of a protected wetland in the Pointe Noire area. This potential wetland does not overlap with the Kami Terminal and is unlikely to be affected Freshwater Fish, Fish Habitat and Fisheries The EIS Guidelines state that Freshwater Fish, Fish Habitat and Fisheries must be considered as a VEC. Freshwater fish and fish habitat means freshwater fish species and the habitat upon which they depend. Two freshwater streams are located in the local study area however neither of these streams provide habitat that supports freshwater fish populations. As there are no fish present at the Kami Terminal, there is no potential for fisheries. Due to the lack of fish, fish habitat and fisheries, it was determined that assessment of the VEC was not necessary. Issues Issues were raised by participants regarding cumulative effects on fish in the marine environment. Issues associated with freshwater fish concerned the ruisseau à la Baleine and rivière Nipississ, which is located more than 40 km north of the Kami Terminal site. Frequency of issues raised during engagement activities 3 Number of Times Issue was Raised Cumulative Effects on Fish and Fish Habitat 1 1 Fish Habitat Fish Population 32

39 7.2.6 Birds, Other Wildlife and Their Habitats and Protected Areas Birds, Other Wildlife and Their Habitats, and Protected Areas include migratory and non-migratory birds, amphibians, small mammals, ungulates, and furbearers. Protected Areas are also considered as a component because of the potential for interactions between Kami Terminal activities and existing or planned designated protected areas, and the need to protect ecosystems, species diversity, important habitats, and ecosystems. Information on existing conditions was collected and analyzed through a literature review, review of government databases, and habitat mapping. This information was used to determine the likelihood of a presence of bird and other wildlife species and wildlife habitat within the study area. Field studies for birds, reptiles, and amphibians were also conducted by qualified biologists in the Kami Terminal area in The Port of Sept-Îles is a highly disturbed industrial area and provides poor quality habitat for wildlife. Such conditions are not favourable to large mammals such as bears, moose, or caribou, as they prefer large, undisturbed habitats. All of the 33 species of birds and 4 species of amphibians observed during the field studies are common in Québec. Birds, Other Wildlife and their Habitats and Protected Areas Local and Regional Study Areas ± Municipality of Sept-Îles Boundary Regional Study Area Sept-Îles Kami Iron Ore Project Environmental Impact Statement Plain Language Summary Baie des Sept-Îles Port of Sept-Îles Property ^_ Local Study Area Terminal Site Waterfowl Gathering Area Baie Ste - Marguerite Golfe du St - Laurent FIGURE ID: ALD_ST_ Kilometres Issues Issues identified by participants related to Birds, Other Wildlife and Their Habitats, and Protected Areas included effects on wildlife species, waterfowl, and parks and protected areas. An issue was raised regarding the presence of a protected wetland in the Pointe-Noire area. This potential wetland does not overlap with the Kami Terminal site and is unlikely to be affected. In response to the issues associated with wildlife and waterfowl, Alderon conducted field surveys to identify habitat and species potentially affected by the Kami Terminal. Alderon will also implement 33

40 Kami Iron Ore Project Environmental Impact Statement Plain Language Summary mitigation measures to minimize dust emissions, and will implement standard best practice as well as avifauna and wildlife protection measures. A complete record of all comments with responses is included in Appendix B. Frequency of issues raised during engagement activities Number of Times Issue was Raised Wildlife Species Waterfowl Parks and Protected Areas Potential Environmental Effects All Kami Terminal activities during the operation and maintenance, and decommissioning and reclamation phases (site clean-up and transfer of equipment to another company) will occur within areas that are mostly already disturbed and are unlikely to result in a change in habitat. Additional disturbance to habitats created by the Kami Terminal is unlikely to result in significant environmental effects on wildlife and their habitat. Construction activities will, through sensory disturbance (such as noise), have an effect on distribution and movement of birds and other wildlife. However, these activities will occur in an industrial area that is already a source of noise. Nearby wildlife are already exposed to noise levels at the Port. Changes in mortality risk will mostly be linked to direct mortality from collision with construction vehicles. However, this activity would mostly occur in disturbed areas of an active port site, by relatively slow-moving vehicles. Airborne contaminants emitted during construction and operations may potentially cause changes in health of birds and wildlife. 1 Mitigation Measures Effects on birds, other wildlife and their habitat, and protected areas will be mitigated through a series of measures designed to limit the area disturbed by the Project and then to control the emissions and discharges. The primary mitigation measures for Project-related effects include an Avifauna Management Plan, restricting clearing to the period outside the breeding bird season (where feasible), and no harassment of wildlife on the Project site. Residual Environmental Effects Given the implementation of mitigation measures, the Project is not likely to result in significant adverse environmental effects under normal operating conditions. 34

41 7.2.7 Species at Risk and Species of Conservation Concern Species at risk and species of conservation concern include any particular species of plant or animal, or its critical habitat, that is of provincial, national or international importance, particularly where the species or its critical habitat is afforded protection under federal or provincial legislation. Historical records, literature reviews, and databases provided information to determine if species at risk or species of conservation concern are likely to exist in or near the Kami Terminal site. In addition, aerial photographs and digital mapping was used to interpret habitat type and distribution. General habitat conditions were confirmed during the 2011 field studies. Various field surveys and habitat assessments completed during the 2011 and 2012 field seasons found no species at risk or species of conservation concern in the Kami Terminal area. While a few mammal and bird species, such as woodland caribou and Canada Warbler, have been reported in the region, habitat conditions in the Kami Terminal area are not suitable for these species. Species at Risk and Species of Conservation Concern Local and Regional Study Areas ± Municipality of Sept-Îles Boundary Regional Study Area Baie des Sept-Îles Sept-Îles Kami Iron Ore Project Environmental Impact Statement Plain Language Summary Port of Sept-Îles Property ^_ Local Study Area Terminal Site Waterfowl Gathering Area Baie Ste - Marguerite Golfe du St - Laurent FIGURE ID: ALD_ST_ Kilometres Issues One issue was raised regarding the presence of bird species at risk and migratory birds. Although the Kami Terminal site does overlap with the geographic range of some bird species at risk, the field surveys did not identify any rare bird species in the vicinity of the Kami Terminal. Potential Environmental Effects Approximately 45 percent of the land at the Kami Terminal site was previously developed (22.6 ha). Site preparation for construction of the Kami Terminal will alter less than 1 percent of the land on the Marconi Peninsula, excluding previously developed areas. Therefore, it is unlikely that there would be any change in the amount of (potential) critical or important habitat of species at risk or species of conservation concern. 35

42 Kami Iron Ore Project Environmental Impact Statement Plain Language Summary Mitigation Measures Effects on species at risk and species of conservation concern will be mitigated through the development of protection measures and environmental management techniques based on site-specific conditions. This will include avoiding sensitive species or habitats, if found, and complying with existing legislation. Residual Environmental Effects Given the implementation of mitigation measures, the Project is not likely to result in significant adverse environmental effects under normal operating conditions Historic and Cultural Resources Historic and Cultural Resources include sites, materials, landscapes, or places of historic, archaeological, cultural / spiritual, palaeontological, and architectural importance. Archaeological sites and materials have been identified throughout the majority of Québec including the Côte-Nord region and Sept-Îles. The provincial inventory of archaeological resources for Québec reports the existence of 14 sites of archaeological significances within the Regional Study Area. No sites were identified in the Kami Terminal area. 36

43 ± Historic and Cultural Resources Local and Regional Study Areas Gallix Regional Study Area Clarke Val Sainte-Marguerite Baie Ste - Marguerite ^_ Ferland Baie des Sept-Îles Local Study Area Sept Îles Terminal Site Plages Golfe du St - Laur ent Catallan FIGURE ID: ALD_ST_ Kilometres Moisie Municipality of Sept-Îles Boundary Issues No issues related to Historical and Cultural Resources were reported during Aboriginal engagement and public consultation. Potential Environmental Effects Although no archaeological sites have been found to date within the Local Study Area, Kami Terminal activities could potentially unearth archaeological sites during construction activities. However, because there are no known archaeological sites within the Local Study Area, the Kami Terminal is not likely to affect, or physically disturb sites of archaeological importance. Kami Iron Ore Project Environmental Impact Statement Plain Language Summary Mitigation Measures In the event of the unexpected discovery of historical and cultural resources during construction, mitigation measures will be implemented in accordance with the Cultural Property Act (2006) and with the Cultural Heritage Act which will come in effect in October Residual Environmental Effects The Kami Terminal is not likely to result in significant adverse environmental effects under normal operating conditions. 37

44 Kami Iron Ore Project Environmental Impact Statement Plain Language Summary Current Use of Lands and Resources for Traditional Purposes by Aboriginal Persons The Current Use of Land and Resources for Traditional Purposes by Aboriginal Persons is defined as per the EIS Guidelines as the use of lands and resources of specific social, cultural or spiritual value to Aboriginal communities of Labrador and Québec, with focus on current direct and indirect use by Aboriginal people for traditional purposes (i.e., fishing, hunting, and gathering). A number of Aboriginal groups undertake traditional land and resource use activities in areas of Québec and Labrador. The land claims of these groups are at varying stages of negotiation and settlement. The Current Use of Land and Resources for Traditional Purposes by Aboriginal Persons and the potential effects of the Kami Terminal on these activities are a key element of the EA, given the overall socio-economic importance of these activities to Aboriginal peoples. This is further reflected in the CEAA definition of environmental effect, which specifically includes: (a) any change that the project may cause in the environment,.[and] (b) any effect of any change referred to in paragraph (a) on (iii) the current use of lands and resources for traditional purposes by Aboriginal persons.... As reflected in the title of this VEC, the associated environmental effects assessment focuses upon the current (existing) use of land and resources by Aboriginal persons for traditional purposes, and potential changes to these activities that may occur either directly or indirectly as a result of the Kami Terminal. 38

45 Current Use of Land and Resources for Traditional Purposes by Aboriginal Persons Local and Regional Study Areas ± Kawawachikamach ( ( Matimekush - Lac John (Naskapi Nation) (Québec Innu) Tshiuetin Railway Labrador City Fermont Kami Mine Site ^_ Wabush Natuashish ( (Labrador Innu) Local Study Area ^_ A T L A N T I C O C E A N ( Sheshatshiu (Labrador Innu) Terminal Site Kami Iron Ore Project Environmental Impact Statement Plain Language Summary Terminal Site ^_ Quebec North Shore and Labrador Railway Sept Îles (( Uashat Mak Mani-Utenam (Québec Innu) Golfe du St - Laurent Regional Study Area FIGURE ID : ALD_ST_ Kilometres Issues Alderon has been making significant efforts to engage with each of the relevant Aboriginal communities and organizations in Québec and Labrador in order to gather information on current land and resource use, Aboriginal knowledge and community issues, and concerns regarding the Project including its potential environmental effects, for consideration and incorporation into the EIS. Where Aboriginal groups have chosen to participate in such initiatives, the information and insights obtained through these processes have been extremely valuable and have been considered and incorporated throughout the environmental assessment. In other cases, the EIS uses existing and publicly available information. During Aboriginal engagement activities, the Innu of Uashat mak Mani-Utenam identified that they should be engaged on the Project as a whole, and not only the components at the Port of Sept-Îles. 39

46 Kami Iron Ore Project Environmental Impact Statement Plain Language Summary Potential Environmental Effects The construction and operation phases of the Kami Terminal will alter some of the existing landscape. However, the area upon which Alderon s proposed Kami Terminal at the Port of Sept-Îles will be constructed and operated has been the site of on-going industrial activity for several decades. The Kami Terminal is located in an industrial area designated for large-scale industry. This industrial area has been the site of substantial and long-standing industrial activity. Likely as a result of these factors, available information does not indicate that traditional land and resource use activities occur within the Kami Terminal site. There are also no known sites of historical, cultural, or spiritual importance to the Aboriginal communities within the Kami Terminal site. Assessments of the potential implications of the Kami Terminal for vegetation, fish, wildlife, and other resources have been assessed in detail for the other VECs. These assessments conclude that the Kami Terminal is not likely to cause significant adverse environmental effects on any aspect of the natural environment. Additionally, since key resources such as caribou are not found in the area or likely to be affected, the Kami Terminal is not likely to have any effect upon the distribution (location or timing) of the current use of land and resources for traditional purposes by Aboriginal persons. Mitigation Measures The consideration of environmental issues from the earliest stages of project planning and design has been a key part of Alderon s approach to its proposed facility. This approach allows potential environmental issues and interactions to be identified early, so that they can be addressed. The objective is to attempt to avoid adverse environmental effects where possible and practical, or at least, to put in place mitigation measures to ensure that they are maintained at acceptable levels. For example, siting of Kami Terminal components and activities entirely within an existing industrial zone will limit the effects of the Kami Terminal on Current Use of Land and Resources for Traditional Purposes by Aboriginal Persons. Residual Environmental Effects The Kami Terminal is not likely to result in significant adverse environmental effects under normal operating conditions Other Current Use of Lands and Resources Other Current Use of Lands and Resources is focused on current (1990 to present) land use and activities, including industrial uses, undertaken by non-aboriginal persons or communities in or around the Kami Terminal site. In order to assess how the Kami Terminal could affect industrial development and activities in the Pointe- Noire industrial area as well as surrounding residential and recreational properties, Alderon gathered information on current industrial users, future industrial expansion plans and the location of residential and recreational lands. Six iron ore companies use the Port of Sept-Îles facilities and have plans for increased production. Alderon s ore storage terminal is included in the Port s development plans and the site location for the storage yards was determined by the Port Authority. The closest residential and recreational land is the Val Sainte- Marguerite area located about 1.5 km away from the Kami Terminal site. 40

47 Other Current Use of Lands and Resources Local and Regional Study Areas ± Regional Study Area Gallix Clarke Val Sainte-Marguerite ^_ Baie Ste - Marguerite Ferland Baie des Sept-Îles Local Study Area Sept Îles Terminal Site Plages Golfe du St - Laur ent Catallan Moisie Municipality of Sept-Îles Boundary FIGURE ID: ALD_ST_ Issues Issues identified by participants related to visual aesthetics of the port facilities including the concentrate stockpiles. It is important to note that the residential area of Sept-Îles is located several kilometers from the kami Terminal and will be virtually indistinguishable from other existing industrial port facilities. A complete record of all comments with responses is included in Appendix B. Kilometres Kami Iron Ore Project Environmental Impact Statement Plain Language Summary Potential Environmental Effects The environmental assessment of other current use of lands and resources is focused on changes to industrial development and changes to residential and recreational property. Assessment of effects on industrial development considered activities that would lead to the exclusion or promotion of industrial activity at the port. Effects to residential and recreational property were considered in terms of the effects of potential changes in air quality, noise, vibrations and light quality. Potential VEC interactions for these two effects are associated with the two-year Kami Terminal construction phase, and the operations and maintenance phase. Changes to viewscapes were considered to be not significant due to the distance between vantage points from the existing infrastructure at Pointe-Noire. Construction of the Kami Terminal will require realignment of an access road and underground water main in the Pointe-Noire industrial area. Site preparation and construction may also result in changes to the atmospheric environment, mainly air and noise emissions, light quality and vibrations. This has the potential to disturb residential and recreational users in the near Val Sainte-Marguerite area. Mitigation Measures Mitigation measures to minimize adverse effects include the realignment of an access road, water main and stockpile rocks to minimize effects on the Aluminerie Alouette aluminum smelter; use of dust suppressants, enclosed conveyor systems, and transfer points; and adherence to comprehensive equipment maintenance and monitoring programs. 41

48 Kami Iron Ore Project Environmental Impact Statement Plain Language Summary Residual Environmental Effects Given the implementation of mitigation measures, the Kami Terminal is not likely to result in significant adverse environmental effects under normal operating conditions Community Services and Infrastructure Community Services and Infrastructure was selected as a VEC because the Kami Terminal has the potential to reduce access to housing and increase traffic congestion in the City of Sept-Îles. Information on the current housing supply and housing costs, potential increases in the number of workers, existing employment conditions, trends in the construction sector, and local traffic conditions and trends was collected for the assessment of effects. Currently there is a shortage of both skilled and unskilled construction labour in Sept-Îles. In addition, housing has been identified as a major issue in the city because there is a lack of new housing construction. Traffic congestion has been identified as a problem on Highway 138 during shift changes at the nearby smelter and pellet plant. Community Services and Infrastructure Regional Study Area ± Regional Study Area Quebec North Shore and Labrador Railway Existing Roads Local Study Area ^_ Sept Îles Terminal Site Golfe du St - Laurent FIGURE ID : ALD_ST_ Kilometres 42

49 Issues Issues identified by participants related to availability of housing for workers, potential effects on community services, and cumulative effects. In response to local concerns, Alderon has engaged with local authorities to address issues related to infrastructure, as needed. A complete record of all comments with responses is included in Appendix B. Frequency of issues raised during engagement activities Number of Times Issue was Raised Availability of Housing for Workers 3 3 Potential Effects on Community Services Cumulative Effect on Community Services and Infrastructure Potential Environmental Effects Potential effects of the Kami Terminal on community services and infrastructure are only expected in association with the construction phase since the operations and decommissioning phases will not have large staffing requirements. An influx of between 30 and 300 workers, depending on construction activities, is expected during the approximately two-year construction phase of the Kami Terminal, including 50 workers required for the construction of the Kami Terminal rail components by CFA. A large part of the workforce required for construction will have to be recruited from outside the region due to the limited availability of qualified workers in the Sept-Îles area. The arrival of a number of workers from outside the region is expected to contribute to the ongoing scarcity of available housing and to put additional upward pressure on housing costs in the region. The transportation of personnel associated with this influx of workers could also worsen traffic congestion on Highway 138 between the downtown area of Sept-Îles and Kami Terminal. Kami Iron Ore Project Environmental Impact Statement Plain Language Summary Workforce requirements during operations will be approximately 17 workers. It is anticipated that this will not result in substantial additional demand on community services and infrastructure. Mitigation Measures To minimize the effects of construction activities in the Kami Terminal area on regional housing supply, Alderon will engage with local authorities and other stakeholders to address issues related to community services and infrastructure as needed. Residual Environmental Effects Given the implementation of mitigation measures, the Kami Terminal is not likely to result in significant adverse environmental effects under normal operating conditions. 43

50 Kami Iron Ore Project Environmental Impact Statement Plain Language Summary Health and Community Health Although Health and Community Health was identified in the EIS Guidelines for assessment, given the characteristics of the Kami Terminal and its distance from the main population center in Sept-Îles, the atmospheric environment is considered as being the only pathway for potential effects on human health. Potential health effects could occur through dust generation, increased noise levels and vibrations. Health issues associated with the atmospheric environment are assessed in the Atmospheric Environment VEC (Section of this summary). Issues No issues related to Health and Community Health were reported Economy, Employment and Business Economy, Employment and Business was selected as a VEC due to the potential for improved economic conditions, increased levels of employment, and increased business activity in the city of Sept-Îles and Municipalité régionale de comté (MRC) de Sept-Rivières, in the Côte-Nord administrative region and in the province of Québec as a whole. In order to understand current economic conditions, information was gathered on employment, income, and businesses for the Côte-Nord Administrative Region, MRC de Sept-Rivières, City of Sept-Îles, and Innu communities near Sept-Îles. The principle resource-based industries in the Côte-Nord Administrative Region are based on the extraction and processing of mineral and forest resources. The mining sector also plays an important role in employment and income in Sept-Îles. The main employer for Innu communities of Sept-Îles is the Band Council although construction training programs enable younger generations to acquire marketable skills. 44

51 Economy, Employment and Business Local and Regional Study Areas ± U n g a v a B a y Tshiuetin Railway Local Study Area ^_ Labrador City Wabush Fermont Kami Mine Site ^_ Schefferville Quebec North Shore and Labrador Railway Sept Îles Terminal Site A T L A N T I C O C E A N Kami Iron Ore Project Environmental Impact Statement Plain Language Summary Regional Study Area U.S.A FIGURE ID : ALD_ST_ Kilometres Issues Issues identified by participants related to effects on local businesses, cumulative effects, apprenticeship and training, availability of local workers, and potential effects on the local economy. Alderon will collaborate with the regional economic forum, coordinate disruptions to utilities and infrastructure to minimize effects as well as promote regional subcontracting clauses for materials and services. A complete record of all comments with responses is included in Appendix B. 45

52 Kami Iron Ore Project Environmental Impact Statement Plain Language Summary Frequency of issues raised during engagement activities Number of Times Issue was Raised Potential Effects on Local Businesses Cumulative Effects on Apprenticeship and Training Availability of Local Workers Economy, Employment and Business Potential Effects on Local Economy Potential Environmental Effects The potential environmental effects of the Kami Terminal on the economy, employment and business relate to the construction and operations and maintenance phases. It is expected that the construction phase will result in a positive effect on regional employment. Though a large part of the workforce required for construction will have to be recruited from outside the region due to the limited availability of qualified workers in the Sept-Îles area, it will increase opportunities for unemployed workers or young apprentices from the surrounding regions of eastern Québec and elsewhere that are affected by high levels of unemployment. The construction phase may also produce positive effects for regional business. Mitigation Measures Alderon will collaborate with a newly-created regional economic forum to find the most appropriate approaches to optimizing regional employment and business opportunities during the construction phase of the Kami Terminal. Residual Environmental Effects Given the implementation of mitigation measures, the Kami Terminal is not likely to result in significant adverse environmental effects under normal operating conditions. 46

53 7.3 Effects of the Environment on the Project Method and Approach For the purpose of assessing the effects the environment may have on the Project, researchers selected a local study area which includes the Marconi Peninsula, the surrounding coastal area, and the baie des Sept-Îles. To evaluate how environmental factors such as climate and seismic events may affect the Project, a larger geographic area was selected because these environmental factors are generally more widely felt Issues No comments or issues related to effects of the environment on the Project were raised during Alderon s engagement activities. A complete record of all comments with responses is included in Appendix B Potential Environmental Effects The assessment of effects of the environment on the Kami Terminal considers how local conditions and natural hazards, such as severe and/or extreme weather conditions and external events such as flooding, ice jams, rock slides, landslides, fire, outflow conditions and seismic events could adversely affect the Kami Terminal and how this in turn could affect the environment, for example through environmental emergencies due to extreme environmental conditions. Environmental Condition Severe Weather Long Term Climate Change Seismicity Potential Effects Tidal storm surge and sea water level changes could result from severe weather. Equipment and structures of the Kami Terminal are installed at elevations above sea level that will prevent possible damage due to severe storms. Wind driven on-shore ice flows could occur however equipment location and harbor barrier islands will minimize the potential for damage. Over the next 100 years, Atlantic Canada will likely experience warmer temperatures, a greater frequency of storm events, increasing storm intensity, rising sea level, storm surges, coastal erosion and flooding. Potential effects of climate change on operation of the Kami Terminal would be primarily related to increases in the frequency of adverse weather events and changes in precipitation. Increases in extreme weather events could potentially affect operation of the Project by increasing unscheduled maintenance due to storm damage. A tsunami related event could potentially damage pier and shore area facilities, depending on the wave height, but is low probability due to water depth and the protection offered by the barrier islands. Kami Iron Ore Project Environmental Impact Statement Plain Language Summary Mitigation Measures The primary mitigation is sound planning. All engineering design will adhere to national and international standards. Building codes consider physical environmental criteria such as temperature, wind, snow, and ice loading, and drainage. In addition, the design life is taken into consideration so that materials are chosen with sufficient durability and corrosion resistance. 47

54 Kami Iron Ore Project Environmental Impact Statement Plain Language Summary Residual Environmental Effects Planning and design of the Kami Terminal has and will continue to consider extreme climatic, hydrologic, and geo-hazard criteria. Experience of other iron ore transportation companies in the area combined with prescribed codes and standards provide a high level of confidence that environmental conditions are not likely to significantly affect the Kami Terminal. Site monitoring will be undertaken to identify potential problems and verify effective mitigations. As such, no significant adverse effects of the environment on the Kami Terminal are anticipated. 7.4 Effects of Possible Accidents or Malfunctions Method and Approach The potential environmental effects of each potential Accident and Malfunction was assessed for each VEC, based on the existing conditions of each VEC and existing knowledge about the environmental effects of the accidental events. Five accidental event scenarios were developed for the Kami Terminal EIS including train derailment, forest fire, stormwater retention pond overflow or breach, product spill at port, and premature shutdown Issues During Aboriginal engagement and public consultation, Alderon listened to questions and concerns expressed by stakeholders and the public. One concern regarded the overflow of the retention pond and its impacts on operations (no use of water). A complete record of all comments with responses is included in Appendix B Potential Environmental Effects Potential accidents and malfunctions that may occur as a result of Kami Terminal activities are identified and assessed for the five reasonable worst case scenarios. Train Derailment Alderon will rely on rail service providers (QNS&L Railway and CFA Railway) to ensure that the risks of train derailments are minimized. QNS&L and CFA have good safety records and their performance suggests that the likelihood of a rail spill of fuel or derailment is low. Regular vehicle maintenance and efficient route planning will be encouraged. Forest Fire The terminal facility is located next to a forested area. Although unlikely, Kami Terminal activities involving the use of heat or flame could result in a fire. The extent and duration of a resulting fire would be dependent on response efforts and weather conditions. Staff will be trained to prevent and control fires. A plan for preventing and combating forest fires will be incorporated into the Emergency Response Plan. Storm Water Retention Pond Breach or Overflow A storm water retention pond will be created in order to collect site runoff, potentially including red water, generated from precipitation water runoff from the iron ore stockpiles. Red water from the pond will be treated before it is released 48

55 into the ruisseau à la Baleine. However, in the unlikely event of a breach or overflow at the storm water retention pond, red water could be released to the downstream environment. In such an event, the receiving waters should rapidly recover. Mitigation measures in order to prevent/address a breach or an overflow of the stormwater retention pond include: Continuous monitoring of the water level in the pond, and generally maintained at minimum levels; and, Regular inspection of containment structures. The stormwater retention pond will be lined in order to prevent red water from leaking into the underlying soils and into to the groundwater. The liner will be designed, installed, and quality-controlled using standard and best practices in order to minimize the risks of leakage and will conform to Port requirements. Mitigation measures include regular sampling of treated water. Product Spill at Port Iron ore concentrate will be carried from the stockpiles at the terminal facility to the proposed Port Authority common offload point at the Port of Sept-Îles using enclosed conveyors. Product loading of ships will be managed by the Port, which will comply with all applicable laws and regulations. Conveyors are designed and built in order to prevent spillage of product. Premature or Permanent Shutdown It is currently planned that the mine will be operational until approximately the end of 2033, at which time the facility would be transferred to the Port of Sept-Îles for use by other clients. Premature shutdown could also occur following changes in market conditions or other factors that result in the premature shutdown of the mine. Kami Iron Ore Project Environmental Impact Statement Plain Language Summary In the unlikely event of any of these scenarios, adverse environmental effects could result. An Emergency Response Plan will be developed prior to initiation of construction activities and will include detailed measures for responding to the accidents and malfunctions listed above Residual Effects Accidents and malfunctions could generate significant effects. However, by definition they have a very low likelihood of occurring. Prevention and emergency response measures will be implemented. 49

56 Kami Iron Ore Project Environmental Impact Statement Plain Language Summary 7.5 Effects on Capacity of Renewable Resources A required component of a comprehensive study is to address the capacity of renewable resources that are likely to be significantly affected by the project to meet the needs of the resent and the future. Renewable resources that may be affected by the Kami Terminal are: Water resources; and, Waterfowl and other wildlife. Considering the design and the implementation of mitigation measures, no significant negative effects are likely to occur, and as a result, negative Kami Terminal effects on the capacity of renewable resources to meet the needs of the present and those of the future are not anticipated. 7.6 Cumulative Environmental Effects Approach The overall effect on each VEC as a result of the Kami Terminal s residual environmental effects in combination with the environmental effects of other relevant projects and activities that have been or will be carried out was assessed. Cumulative effects were assessed in the Regional Study Area specific to each VEC (i.e., the spatial boundaries in which cumulative effects are predicted to occur), and the assessment focuses on the degree of change from baseline VEC conditions resulting from the Kami Terminal acting in combination with other relevant ongoing and future projects Scoping On-going and reasonably foreseeable future projects with environmental effects that are likely to overlap in space and time with those of the Kami Terminal include: Pointe-Noire Port Expansion; CFA and QNS&L; Aluminerie Alouette Aluminum Smelter Project; Second Port-Cartier Pellet Plant; Bloom Pointe-Noire Terminal; and, Arnaud Apatite-Magnetite Mine Issues Issues identified during Aboriginal engagement and public consultation activities that relate to cumulative effects are presented in Appendix B. The mitigation and effects management measures proposed by Alderon will mitigate the overall cumulative effect of the Kami Terminal in combination with other projects and activities. 50

57 7.6.4 Potential Cumulative Effects Ongoing and reasonably foreseeable future projects that are likely to overlap in space and time with those of the terminal facility are identified in the table below as a Y to represent a cumulative effect on the VEC. Name of Project/ Activity Atmospheric Environment Landforms, Soils, Snow and Ice Water Resources Wetlands Freshwater Fish, Fish Habitat and Mortality and Fisheries Birds, Other Wildlife and Their Habitats, and Protected Areas Species at Risk and Species of Conservation Concern Historic and Cultural Resources Current Use of Lands and Resources for Traditional Purposes by Aboriginal Persons Pointe-Noire Port Expansion Y N/A Y N/A N/A Y Y N N Y Y N/A Y CFA and QNS&L Y N/A N N/A N/A Y Y N N Y Y N/A Y Alouette Aluminum Smelter Project Y N/A N N/A N/A Y Y N N Y Y N/A Y Second Port-Cartier Pellet Plant N N/A N N/A N/A N N N N N Y N/A Y Bloom Pointe-Noire Terminal Y N/A Y N/A N/A Y Y N N Y Y N/A Y Arnaud Apatite- Magnetite mine Y N/A Y N/A N/A Y Y N N Y Y N/A Y Other Current Use of Lands and Resources Community Services and Infrastructure Health and Community Health Economy, Employment and Business Kami Iron Ore Project Environmental Impact Statement Plain Language Summary N/A=Cumulative effects not considered due to lack of interaction with VEC and/or addressed under associated VECs Mitigation Measures The mitigation and effects management measures proposed by Alderon will mitigate the overall cumulative effect of the Project in combination with other projects and activities Residual Effects For most VECs the cumulative effects of other projects and activities with the Kami Terminal were deemed not significant. Current and future activities are subject to regulatory approval processes and standard mitigation measures which would limit adverse effects. Positive cumulative effects are predicted to occur for Economy, Employment and Business. 51

58 Kami Iron Ore Project Environmental Impact Statement Plain Language Summary 8.0 FOLLOW-UP PROGRAM A follow-up and monitoring program will be designed and conducted, as appropriate, during all phases of the Kami Terminal. The purpose of the follow-up program is to verify the accuracy of the predictions made in the EA as well as the effectiveness of the mitigation measures. Follow-up programs are proposed in those cases where there is uncertainty about the effects prediction. This uncertainty may be due to a lack of information or the nature of the effect, for instance if it is unique. Follow-up programs will be used to improve mitigation measures and apply adaptive management measures associated with the Kami Terminal. 52

59 The proposed follow-up and monitoring programs are summarized below. VEC Atmospheric Environment Landforms, Soils, Snow and Ice Water Resources Wetlands Fish, Fish Habitat and Fisheries Birds, Other Wildlife and Their Habitats, and Protected Areas Species at Risk and Species of Conservation Concern Historic and Cultural Resources Current Use of Lands and Resources by Aboriginal Persons for Traditional Purposes Other Current Use of Lands and Resources Community Services and Infrastructure Health and Community Health Economy, Employment and Business Commitment Monitoring of CO emissions from blasting near Kami Terminal site with portable monitors. Noise monitoring. No follow-up or monitoring required. Monitoring of water quality of the stormwater retention pond discharge to ensure compliance with the MDDEP Directive 019 guidelines, CCME water quality requirements for the protection of aquatic life and Québec surface water criteria for the protection of aquatic life. No follow-up or monitoring required. No follow-up or monitoring required. On-Site monitoring for compliance with the EPP. On-Site monitoring for compliance with the EPP. Adhere to all federal and provincial archaeological legislation. On-site monitoring for compliance with the EPP. Any follow-up and monitoring programs that have been identified and proposed for other VECs (particularly for the biophysical environment) will be indirectly applicable to land and resource use. Participate in air quality monitoring program initiated in Sept-Îles. Monitor local housing indicators (vacancy rates, rental prices, sale prices, etc.). No follow-up or monitoring required. Promote opportunities for local and Aboriginal businesses and workers. Promote regional subcontracting for materials and services. Kami Iron Ore Project Environmental Impact Statement Plain Language Summary 53

60 Kami Iron Ore Project Environmental Impact Statement Plain Language Summary 9.0 BENEFITS OF THE ENVIRONMENTAL ASSESSMENT TO CANADIANS In addition to meeting regulatory requirements, this environmental assessment process has resulted in various benefits to Canadians. This includes maximized environmental benefits, supporting sustainable development, public participation, increases in scientific knowledge and community and social benefits. Examples of how the environmental assessment process for the Kami Terminal benefits Canadians is presented below. Factors of EA Process Providing Benefits to Canadians Maximized Environmental Benefits Supporting Sustainable Development Public Participation Increases in Scientific Knowledge Community and Social Benefits Commitment The Kami Terminal conveyor systems are covered to minimize dust generation as well as noise. The rail loop was located adjacent to the future Consolidated Thompson rail loop in order to minimize the combined footprint of both infrastructure. The length of the rail loop was minimized and located almost entirely on highly artificialized port land. The Kami Terminal is being designed and will be constructed and operated in consideration of maximizing the future value of the facility for eventual transfer at the end of the life of mine. The Kami Terminal will provide workers and companies with new experience and capabilities that will make them competitive for employment and business opportunities on other projects and, in some cases, other industries. Project-related investments in infrastructure, education, training and possibly research and development that will facilitate and fuel the sustainable economic development of the Province as a whole. Public input has influenced the design of the Project in several major ways. The understanding of the existing environment within and surrounding the Kami Terminal area has been greatly improved as a result of baseline studies conducted in support of the EA. Local expenditures and employment will result in community and social benefits. 54

61 The Kami Project will result in positive effects to the local and provincial economy, employment and business OVERALL CONCLUSIONS OF THE PROPONENT The Kami Terminal has been designed and will be undertaken to mitigate adverse environmental effects to acceptable levels. Concerns raised by Aboriginal groups and the public and requirements prescribed in the EIS Guidelines have been addressed by assessing the environmental effects that will or may result from the construction, operation and maintenance, and decommissioning and reclamation of the Project. In summary, the Kami Terminal will not result in likely adverse residual significant effects either in isolation or cumulatively with other projects and activities. Accidents and malfunctions, should they occur, may result in significant effects for some VECs. However, these effects are not likely to occur given the planning that has been undertaken and the standards that have been prescribed. Kami Iron Ore Project Environmental Impact Statement Plain Language Summary 55

62 Kami Iron Ore Project Environmental Impact Statement Plain Language Summary 11.0 REFERENCES Institut de la Statistique du Québec (ISQ) Évolution du marché du travail dans les MRC. Décembre Available online at: publications/regions/flash_regions.htm. Accessed in February Statistics Canada Community Profiles (various tables) Census. Statistics Canada Catalogue no XWE. Ottawa. Released March 13, Accessed 25 April Available online at: www12.statcan.ca/censusrecensement/2006/dp-pd/prof/92-591/index.cfm?lang=e Ville de Sept-Îles, Population et scène économique. Available online at : Accessed June 28th,

63 Appendix A VEC Summary Tables and Residual Effects Summary Matrices Kami Iron Ore Project Environmental Impact Statement Plain Language Summary A 57

64 Kami Iron Ore Project Environmental Impact Statement Plain Language Summary Table A.1 Summary of Project Residual Environmental Effects: Atmospheric Environment Project Phase Mitigation / Compensation Measures Change in Air Quality Construction Use approved dust suppressant or road watering as needed. Enforceable low speed standards on-site. Use drilling machinery equipped with dust collector Operation and Maintenance Decommissioning and Reclamation or water dust suppression. Use CO monitors during blasting activities at nearby receptors. Adjust blast surface as needed. Enclose car-dumping in building equipped with dust collector. Enclosed conveyors. Equip transfer points with dust collectors. Design stacker to include adjustable height. Routine inspections of dust collectors. Spraying water over ground surface to minimize wind erosion as needed. Direction Magnitude Residual Environmental Effects Characteristics Geographic Extent Duration Frequency Reversibility Environmental or Socio- Economic Context Significance Prediction Confidence A M L ST S R D N H A M L LT R R D N H A L S ST S R D N H Change in GHG Emissions Construction Use low CO 2 hydroelectricity for infrastructure operation. A L R ST S R D L H Operation and Maintenance A M R LT R R D M H Decommissioning and Reclamation A L R ST S R D L H Change in Acoustic Environment Construction Enclosing conveyors and conveyor transfer points; A L L ST R R D N H Operation and Proper muffler installation. Maintenance Comprehensive and regular A L L LT C R D N H Decommissioning and Reclamation Vegetation buffers by minimizing the disturbed area. maintenance of vehicles. A L L ST R R D N H Change in Vibrations Construction None recommended A L S ST S R D N H Operation and Maintenance Decommissioning and Reclamation A L S LT S R D N H A L S ST S R D N H Recommended Follow up and Monitoring Monitor CO emissions from blasting near Project site with portable monitors; Participate in air quality monitoring program initiated in Sept-Îles None recommended None recommended None recommended A 58

65 Project Phase Change in Ambient Light Quality Construction Operation and Maintenance Decommissioning and Reclamation Key: Mitigation / Compensation Measures Direct light where needed Retain a vegetation screen where possible Locate portable lighting equipment where not visible in surrounding urban areas Use of full horizontal cut off light fixtures, as appropriate Direction: P Positive A Adverse N Neutral Magnitude: N Negligible: no measurable adverse effect anticipated; L Low: effect occurs that is detectable but is within normal variability of baseline conditions; M Moderate: effect occurs that would cause an increase with regard to baseline but is within regulatory limits and objectives; H High: effect occurs that would singly or as a substantial contribution in combination with other sources cause exceedances of objectives or standards beyond the Project boundaries. Geographic Extent: S Site-specific: effect restricted to the Project footprint within the LSA L Local: within the LSA R Regional: within the RSA G Global: Provincial, National or Global scale (GHG Emissions only). Direction Magnitude Residual Environmental Effects Characteristics Geographic Extent Duration Frequency Reversibility Environmental or Socio- Economic Context Significance Prediction Confidence A L S ST S R D N H A L L LT R R D N H A L S ST S R D N H Duration: Author to use quantitative measure; or ST Short term: effect occurs for less than three years MT Medium term: effect occurs for between 3 and 15 years; LT Long-term: effect persists beyond 15 years Frequency: Author to use quantitative measure; or O Once: effect occurs once; S Sporadic: effect occurs at sporadic intervals; intervals R Rarely: effect occurs on a regular basis and at regular intervals; or, F Frequently: effect occurs continuously throughout the Project life Reversibility: R Reversible I Irreversible Recommended Follow up and Monitoring None recommended Environmental or Socio-economic Context: U Undisturbed: Area relatively or not adversely affected by human activity D Developed: Area has been substantially previously disturbed by human development or human development is still present N/A Not Applicable Significance: S Significant N Not Significant Significance (GHG only): L less than 10 5 t CO 2 eq per annum M between 10 5 t and 10 6 CO 2 eq per annum H greater than 10 6 t CO 2 eq per annum Prediction Confidence: Based on scientific information and statistical analysis and effectiveness of mitigation or effects management measure L Low level of confidence M Moderate level of confidence H High level of confidence Kami Iron Ore Project Environmental Impact Statement Plain Language Summary A 59

66 Kami Iron Ore Project Environmental Impact Statement Plain Language Summary A 60 Table A.2 Summary of Project Residual Environmental Effects: Water Resources Project Phase Change in Surface Water Quality Construction Operation and Maintenance Decommissioning and Reclamation Mitigation / Compensation Measures Apply standard and best practices and general environmental protection measures. Use of silt fencing downstream of the work area and at the limits of the work zone to reduce the carriage of silt and fines in any water runoff from the area. Avoid unnecessary encroachments in the riparian habitat on either side of streams. No debris will be disposed in the aquatic environment and any debris introduced will be removed as soon as possible. No earth-moving or excavation work will be carried out near streams during high water periods or heavy rains. Use machinery that is in proper operating condition in order to avoid any oil or fuel leaks. Clean, maintain and store work site machinery and vehicles on a site designated for this purpose at a distance of over 30 m from streams and ensure an on-site supply of absorbent materials in case of accidental spills as well as properly identified sealed recipients for collecting petroleum products and waste materials. Stabilize slopes as soon as possible using recognized bioengineering techniques that take into account instability, sensitivity to erosion, slope and height of the embankment. Concentrate storage area will contain a liner in conformance with Port requirements. Stormwater collection in the concentrate storage area and drainage directed toward a retention pond with liner. Water treatment before release to the environment to respect Directive 019 and ensure that receiving water will not exceed the CCME water quality guideline for the protection of aquatic life. Direction Magnitude Residual Environmental Effects Characteristics Geographic Extent Duration Frequency Reversibility Environmental or Socio- Economic Context Significance Prediction Confidence A N S ST S R D/U N H A L L MT R R D/U N H A N S ST S R D/U N H Recommended Follow up and Monitoring Monitoring of water quality of the stormwater retention pond discharge to ensure compliance with the MDDEP Directive 019 guidelines, CCME water quality requirements for the protection of aquatic life and Québec surface water criteria for the protection of aquatic life.

67 Project Phase Mitigation / Compensation Measures Change in Surface Water Drainage Patterns Construction None required Operation and Maintenance Decommissioning and Reclamation Change in Ground Water Quality Construction Operation and Maintenance Decommissioning and Reclamation Apply standard and best practices and general environmental protection measures. Use machinery that is in proper operating condition in order to avoid any oil or fuel leaks. Clean, maintain and store work site machinery and vehicles on a site designated for this purpose at a distance of over 30 m from streams and ensure an on-site supply of absorbent materials in case of accidental spills as well as properly identified sealed recipients for collecting petroleum products and waste materials. Concentrate storage area will contain a liner in conformance with Port requirements. Stormwater collection in the concentrate storage area and drainage directed toward a retention pond with liner. Direction Magnitude Residual Environmental Effects Characteristics Geographic Extent Duration Frequency Reversibility Environmental or Socio- Economic Context Significance Prediction Confidence A L L MT R R D/U N H A N S ST S R D/U N H A N S ST S R D/U N H A L L MT R R D/U N H A N S ST S R D/U N H A N S ST S R D/U N H Recommended Follow up and Monitoring No monitoring required No monitoring required Kami Iron Ore Project Environmental Impact Statement Plain Language Summary A 61

68 Kami Iron Ore Project Environmental Impact Statement Plain Language Summary Key: Direction: P Positive: condition of the Water Resources is improving in comparison to baseline conditions and trends N Neutral: no change in the condition of the Water Resources compared to baseline conditions and trends A Adverse: condition of Water Resources is worsening in comparison to baseline conditions and trends Magnitude: N Negligible: no measurable adverse effect anticipated; L Low: effect occurs that is detectable but is within normal variability of baseline conditions; M Moderate: effect occurs that would cause an increase with regard to baseline but is within regulatory limits and objectives; H High: effect occurs that would singly or as a substantial contribution in combination with other sources cause exceedances of objectives or standards beyond the Project boundaries. Geographic Extent: S Site within PDA L Local: within the LSA R Regional: within the RSA Duration: ST Short term: effect occurs for less than three years; MT Medium term: effect occurs for between three and 20 years; LT Long-term: effect persists beyond 20 years. Frequency: O Once: effect occurs once; S Sporadic: effect occurs at sporadic intervals R Rarely: effect occurs on a regular basis C and at regular intervals Frequently: effect occurs continuously throughout the Project life Continuous Reversibility: R Reversible: effect ceases when Project operations cease I Irreversible: effect continues after Project operations cease. Environmental or Socio-economic Context: U Undisturbed: Area relatively or not adversely affected by human activity D Developed: Area has been substantially previously disturbed by human development or human development is still present Significance: S Significant N Not Significant Prediction Confidence: Based on scientific information and statistical analysis and effectiveness of mitigation or effects management measure L Low level of confidence M Moderate level of confidence H High level of confidence A 62

69 Table A.3 Summary of Project Residual Environmental Effects: Birds, Other Wildlife and their Habitats, and Protected Areas Project Phase Change in Habitat Construction Change in Distribution and Movement Construction idem Change in Mortality Risk Construction idem Change in Health Construction Mitigation / Compensation Measures Apply standard and best practices and general environmental protection measures. Environmental monitoring during construction. Avoid clearing during the breeding bird season, where feasible. Develop an avifauna management plan. Flag boundaries of sensitive areas or buffers. Proper muffler installation. Comprehensive and regular maintenance of vehicles. Site erosion protection and sediment control measures. Survey area for presence of sensitive wildlife prior to blasting. Direct storm water, wastewater or surface water away from wildlife habitat. No harassment of wildlife. Provincial and federal regulations will be followed in the storage and handling of materials. Implement EPP. Implement forest fire prevention and response plan Oil Spill Contingency planning. Product spill contingency planning up to the proposed Port authority common load-out point. Provide employee training. idem Direction Magnitude Residual Environmental Effects Characteristics Geographic Extent Duration Frequency Reversibility Environmental or Socio- Economic Context Significance Prediction Confidence A L S ST C I D N H A L L ST C I D N H A L L ST C I D N H A L L ST C I D N H Recommended Follow up and Monitoring On-site monitoring for compliance with the EPP. On-site monitoring for compliance with the EPP. On-site monitoring for compliance with the EPP. On-site monitoring for compliance with the EPP. Kami Iron Ore Project Environmental Impact Statement Plain Language Summary A 63

70 Kami Iron Ore Project Environmental Impact Statement Plain Language Summary Key: Direction: P Positive A Adverse Magnitude: L Low: the residual Project (alteration / loss) are not expected to exceed 5% of the known population in the RSA. No measurable effect M Moderate: the residual Project effects (alteration / loss) are expected to be greater than 5% and not exceed 25% of the known populations in the RSA. Effect can be measured H High: the residual Project effects (alteration / loss) are expected to exceed 25% of the known population in the RSA. Geographic Extent: S Site including PDA L Local: within the LSA R Regional: within the RSA Duration: ST Short term - Effect occurs during the site preparation or construction phase of the Project (i.e., 1 to 2 years) MT Medium term - Effect extends throughout the construction and operation phases of the Project (up to 15 years) LT Long-term - Effect is greater than 15 years P Permanent will not change back to original condition Frequency: O S R C Effect occurs occasionally, or once during the life of the Project (e.g., clearing) Occurs sporadically at irregular intervals Occurs on a regular basis and at regular intervals Continuous Reversibility: R Reversible I Irreversible Environmental or Socio-economic Context: U Undisturbed: Area relatively or not adversely affected by human activity D Developed: Area has been substantially previously disturbed by human development or human development is still present N/A Not Applicable Significance: S Significant N Not Significant Prediction Confidence: Based on scientific information and statistical analysis and effectiveness of mitigation or effects management measure L Low level of confidence M Moderate level of confidence H High level of confidence A 64

71 Table A.4 Summary of Project Residual Environmental Effects: Species at Risk / Species of Conservation Concern Project Phase Mitigation / Compensation Measures Direction Magnitude Residual Environmental Effects Characteristics Geographic Extent Duration Frequency Reversibility Environmental or Socio- Economic Context Change in Critical or Important Habitat Construction Comply with existing legislated mitigation. Avoid activities near or/at sensitive species and/or habitats, where possible. Develop protection measures and environmental management techniques based on site-specific conditions. Rehabilitate or restore affected environment. Provide substitute resources or environments through seed collection / sowing, direct transplantation or diaspore dispersal. Provincial and federal regulations should be followed in the storage and handling of materials. Implement EPP. Provide employee training. A L S ST C I D N H Change in Distribution and Movement Construction idem A L S ST C I D N H Change in Mortality Risk Construction idem Change in Health Construction idem Significance Prediction Confidence A L S ST C I D N H A L S ST C I D N H Recommended Follow up and Monitoring On-site monitoring for compliance with the EPP. On-site monitoring for compliance with the EPP. On-site monitoring for compliance with the EPP. On-site monitoring for compliance with the EPP. Kami Iron Ore Project Environmental Impact Statement Plain Language Summary A 65

72 Kami Iron Ore Project Environmental Impact Statement Plain Language Summary Key: Direction: P Positive A Adverse Magnitude: L Low: the residual Project (alteration / loss) are not expected to exceed 5% of the known population in the RSA. No measurable effect M Moderate: the residual Project effects (alteration / loss) are expected to be greater than 5% and not exceed 25% of the known populations in the RSA. Effect can be measured H High: the residual Project effects (alteration / loss) are expected to exceed 25% of the known population in the RSA. Geographic Extent: S Site including PDA L Local: within the LSA R Regional: within the RSA Duration: ST Short term - Effect occurs during the site preparation or construction phase of the Project (i.e., 1 to 2 years) MT Medium term - Effect extends throughout the construction and operation phases of the Project (up to 15 years) LT Long-term - Effect is greater than 15 years P Permanent will not change back to original condition Frequency: O S R C Effect occurs occasionally, or once during the life of the Project (e.g., clearing) Occurs sporadically at irregular intervals Occurs on a regular basis and at regular intervals Continuous Reversibility: R Reversible I Irreversible Environmental or Socio-economic Context: U Undisturbed: Area relatively or not adversely affected by human activity D Developed: Area has been substantially previously disturbed by human development or human development is still present N/A Not Applicable Significance: S Significant N Not Significant Prediction Confidence: Based on scientific information and statistical analysis and effectiveness of mitigation or effects management measure L Low level of confidence M Moderate level of confidence H High level of confidence A 66

73 Table A.5 Summary of Project Residual Environmental Effects: Historic and Cultural Resources Project Phase Mitigation / Compensation Measures Disturbance or Loss of Archaeological Sites or Materials Construction Implement EPP in the event of an unexpected discovery. Operation and Maintenance Decommissioning and Reclamation Key: Direction: P Positive A Adverse Magnitude: N No Effect: - no likely effect L Low: disturbance but with prior retrieval of the resource and associated information, and with all necessary regulatory approvals M Moderate disturbance or loss of all or a portion, with retrieval of a portion of the resource and its associated information, or a direct effect on a known Historic and Cultural Resource, which is of interest and concern to the associated community, but which does not reduce the overall integrity and cultural value of the site H High: disturbance or loss, with no retrieval of the resource and its associated information, or a direct effect on a Historic and Cultural Resource, which reduces the overall integrity and cultural value of the site. Direction Magnitude Residual Environmental Effects Characteristics Geographic Extent Duration Frequency Reversibility Environmental or Socio- Economic Context Significance Prediction Confidence Recommended Follow up and Monitoring A A A N/L N/L N/L S S S P P P S S S U/D U/D U/D N N N H H H M M M Adhere to all federal and provincial archaeological legislation. On-site monitoring for compliance with the EPP. Geographic Extent: S Site including PDA and 200 m beyond L Local: within the LSA R Regional: within the RSA Duration: ST Short term MT Medium term LT Long-term P Permanent will not change back to original condition Frequency: O Occasionally, once per month or less S Occurs sporadically at irregular intervals R Occurs on a regular basis and at regular intervals C Continuous Environmental or Socio-economic Context: U Undisturbed: Area relatively or not adversely affected by human activity D Developed: Area has been substantially previously disturbed by human development or human development is still present N/A Not Applicable Significance: S Significant N Not Significant Prediction Confidence: Based on scientific information and statistical analysis and effectiveness of mitigation or effects management measure L Low level of confidence M Moderate level of confidence H High level of confidence Kami Iron Ore Project Environmental Impact Statement Plain Language Summary A 67

74 Kami Iron Ore Project Environmental Impact Statement Plain Language Summary Table A.6 Summary of Project Residual Environmental Effects: Current Use of Land and Resources for Traditional Purposes by Aboriginal Persons Project Phase Mitigation / Compensation Measures Change in Activity Distribution (Location and/or Timing) Construction The design and siting of the Québec terminal facility (concentrate storage and loadout facility and rail loop) within an existing industrial area. Operation and On-going engagement with Aboriginal Maintenance communities and organizations. Possible work rotations / cultural leave provisions for Aboriginal employees Decommissioning and Reclamation Direction Magnitude Residual Environmental Effects Characteristics Geographic Extent Duration Frequency Reversibility Environmental or Socio- Economic Context Significance Prediction Confidence N - - N - - D N H N - - N - - D N H N - - N - - D N H Change in Overall Activity Levels Construction The design and siting of the Québec terminal facility (concentrate storage and loadout facility and rail loop) N - - N - - D N H Operation and Maintenance Decommissioning and Reclamation within an existing industrial area. On-going engagement with Aboriginal communities and organizations Possible work rotations / cultural leave provisions for Aboriginal employees N N N N D D N N H H Resulting Change in Overall Quality and Cultural Value of the Activity Construction The design and siting of the Québec terminal facility (concentrate storage and loadout facility and rail loop) N - - N - - D N H Operation and Maintenance within an existing industrial area. On-going engagement with Aboriginal communities and organizations. N - - N - - D N H Decommissioning and Reclamation N - - N - - D N H Recommended Follow up and Monitoring Any follow-up and monitoring programs that have been identified and proposed for other VECs (particularly for the biophysical environment) will be indirectly applicable to land and resource use. On-going engagement with Aboriginal communities and organizations. Any follow-up and monitoring programs that have been identified and proposed for other VECs (particularly for the biophysical environment) will be indirectly applicable to land and resource use. Any follow-up and monitoring programs that have been identified and proposed for other VECs (particularly for the biophysical environment) will be indirectly applicable to land and resource use. A 68

75 Key: Direction: P Positive A Adverse N Neutral (or No Effect) Magnitude: L Low: affects a small group of users M Moderate: affects less than the majority of users across multiple activities H High: affects the majority of land and resource users across multiple activities Geographic Extent: S Site: includes PDA and 200 m beyond L Local: LSA R Regional: RSA Frequency: N Not likely to occur O Once: Occurs once S Sporadic: occurs sporadically R Regular: occurs on a regular basis C Continuous Duration: S Short term: construction phase only M Medium term: continues through operation and maintenance phase L Long-term: continues beyond operation and maintenance P Permanent Reversibility: R Reversible I Irreversible Environmental or Socio-economic Context: U Undisturbed: Area relatively or not adversely affected by human activity D Developed: Area has been substantially previously disturbed by human development or human development is still present Significance: S Significant N Not Significant Prediction Confidence: Based on scientific information and statistical analysis and effectiveness of mitigation or effects management measure L Low level of confidence M Moderate level of confidence H High level of confidence N/A Not Applicable Kami Iron Ore Project Environmental Impact Statement Plain Language Summary A 69

76 Kami Iron Ore Project Environmental Impact Statement Plain Language Summary Table A.7 Summary of Project Residual Environmental Effects: Other Current Use of Land and Resources Project Phase Mitigation / Compensation Measures Direction Magnitude Residual Environmental Effects Characteristics Geographic Extent Duration Frequency Reversibility Environmental or Socio- Economic Context Changes to Industrial Development Construction Realign access road and water main and stockpile rocks to A L S ST O R D N H minimize effects on the Aluminerie Operation and Alouette aluminum smelter. Maintenance A L S LT O R D N H Decommissioning and Reclamation A L S ST O R D N H Changes to Residential and Recreational Property Construction Proper muffler installation. Comprehensive vehicle and machinery maintenance program. A L L LT S R D N H Enforceable low-speed standards on-site. Operation and Blast design plans Maintenance Use of full horizontal cut A L L LT S R D N H off light fixtures. Locate lateral lighting fixtures Decommissioning on south side of facility. and Reclamation Direct lateral lighting away from the baie des Sept-Îles. A L S ST O R D N H Enclose conveyor transfer points. Vegetation buffers. Significance Prediction Confidence Recommended Follow up and Monitoring No monitoring required. Participate in air quality monitoring program initiated in Sept-Îles. A 70

77 Key: Direction: B Beneficial - condition of other current use of land and resources is improved in comparison to baseline conditions and trends N Neutral - no change in the condition of other current use of land and resources compared to baseline conditions and trends, A Adverse - condition of other current use of land and resources is worsened in comparison to baseline conditions and trends Magnitude: L Low - affects a small group of land and resource users M Moderate - affects less than the majority of land and resource users across multiple activities H High - affects the majority of land and resource users across multiple activities Geographic Extent: S Site-specific effect restricted to the Project footprint within the LSA L Local - effect restricted to within the LSA R Regional - effect extends beyond the LSA but is within the RSA Duration: ST Short term effect occurs for less than three years MT Medium term effect occurs for the life of the Project LT Long-term effect persists beyond the life of the Project P Permanent will not change back to original condition. Frequency: O Occasionally, once per month or less S Occurs sporadically at irregular intervals. R Occurs on a regular basis and at regular intervals. C Continuous. Reversibility: R Reversible effect ceases when Project operations cease I Irreversible effect continues after Project operations cease Environmental and Socio-economic Context: U Undisturbed - Area relatively or not adversely affected by human activity D Developed - Area has been substantially previously disturbed by human development or human development is still present N/A Not Applicable. Significance: S Significant N Not Significant. Prediction Confidence: Based on scientific information and statistical analysis and effectiveness of mitigation or effects management measure L Low level of confidence M Moderate level of confidence H High level of confidence. Kami Iron Ore Project Environmental Impact Statement Plain Language Summary A 71

78 Kami Iron Ore Project Environmental Impact Statement Plain Language Summary Table A.8 Summary of Project Residual Environmental Effects: Community Services and Infrastructure Project Phase Mitigation / Compensation Measures Change to Housing Supply Construction Engage with local authorities and other stakeholders to address issues Operation and related to community services Maintenance and infrastructure as needed. Decommissioning and Reclamation Change to Traffic Conditions Construction Engage with local authorities and other stakeholders to address issues Operation and related to community services Maintenance and infrastructure as needed. Decommissioning and Reclamation Key: Direction: P Positive A Adverse Magnitude: L Low proportion of local or regional population that is affected M Moderate proportion of local or regional population that is affected H High proportion of local or regional population that is affected. Geographic Extent: S Site including PDA and 200 m beyond L Local: within the LSA R Regional: within the RSA Direction Magnitude Residual Environmental Effects Characteristics Geographic Extent Duration Frequency Reversibility Environmental or Socio- Economic Context Significance Prediction Confidence Recommended Follow up and Monitoring A L R ST C R N/A N H Monitor local housing A L R LT C R N/A N H indicators (vacancy rates, rental prices, A L R ST C R N/A N H sales prices, etc.) A L L ST C R N/A N H A L L LT C R N/A N H A L L LT C R N/A N H Duration: ST Short term MT Medium term LT Long-term P Permanent will not change back to original condition. Frequency: O Occasionally, once per month or less S Occurs sporadically at irregular intervals. R Occurs on a regular basis and at regular intervals. C Continuous. Reversibility: R Reversible I Irreversible No monitoring required. Environmental Context: U Undisturbed: Area relatively or not adversely affected by human activity D Developed: Area has been substantially previously disturbed by human development or human development is still present N/A Not Applicable. Significance: S Significant N Not Significant. Prediction Confidence: Based on scientific information and statistical analysis and effectiveness of mitigation or effects management measure L Low level of confidence M Moderate level of confidence H High level of confidence A 72

79 Table A.9 Summary of Project Residual Environmental Effects: Economy, Employment and Business Project Phase Change to Regional Employment Construction Operation and Maintenance Decommissioning and Reclamation Change to Regional Businesses Construction Operation and Mitigation / Compensation Measures Collaborate with the Regional economic forum Promote regional subcontracting for materials and services Promote opportunities for local and Aboriginal businesses and workers Collaborate with the Regional economic forum Promote regional subcontracting for materials and services Direction Magnitude Residual Environmental Effects Characteristics Geographic Extent Duration Frequency Reversibility Environmental or Socio- Economic Context Significance Prediction Confidence P H R ST C N/A N/A S H P L R LT C N/A N/A N H P L R ST C N/A N/A N H Maintenance P H R LT C N/A N/A S H Promote opportunities for local and Decommissioning Aboriginal businesses and workers Coordinate disruptions to utilities and and Reclamation P L R ST C N/A N/A N H infrastructure to minimize effects Key: Direction: P Positive A Adverse Magnitude: No effect - no detectable effect anticipated on economic conditions L Low - detectable effect occurs on economic activity, but is within normal variability of baseline conditions M Moderate - effect occurs that represents a relative increase in economic activity with regard to baseline conditions H High - effect occurs that singly or as a substantial contribution in combination with other sources represents a significant increase in economic activity with regard to baseline conditions. Geographic Extent: S Site - including PDA and 200 m beyond L Local - within the LSA R Regional - within the RSA Recommended Follow up and Monitoring Promote opportunities for local and Aboriginal businesses and workers. P H R ST C N/A N/A S H Promote opportunities for local and Aboriginal Duration: ST Short term - effect occurs for less than three years MT Medium term - effect occurs for the life of the Project LT Long-term - effect persists beyond the life of the Project P Permanent will not change back to original condition. Frequency: O Occasionally, once per month or less S Occurs sporadically at irregular intervals. R Occurs on a regular basis and at regular intervals. C Continuous. Reversibility: R Reversible I Irreversible N/A Not Applicable businesses and workers. Promote regional subcontracting for materials and services. Environmental Context: U Undisturbed: Area relatively or not adversely affected by human activity D Developed: Area has been substantially previously disturbed by human development or human development is still present N/A Not Applicable Significance: S Significant N Not Significant Prediction Confidence: Based on scientific information and statistical analysis and effectiveness of mitigation or effects management measure L Low level of confidence M Moderate level of confidence H High level of confidence Kami Iron Ore Project Environmental Impact Statement Plain Language Summary A 73

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81 APPENDIX B Complete Record of all Comments Identified During Consultation and Engagement Activities with Responses Kami Iron Ore Project Environmental Impact Statement Plain Language Summary B 75

82 Kami Iron Ore Project Environmental Impact Statement Plain Language Summary (this page is deliberately blank, for layout purposes) B 76

83 Table B.1 Atmospheric Environment Issue Community Summary of comments raised during consultation and engagement activities Dust Sept-Îles Two residents enquired about dust emissions associated to rail car dumpers Cumulative impacts of multiple industries on air quality Sept-Îles Sept-Îles Sept-Îles Sept-Îles One resident enquired about dust emissions associated to rock cutting Two residents enquired about dust emissions associated to the loading of boats Two residents asked what mitigation measures were planned to control fugitive dust from the concentrate stockpile One resident indicated its concern about cumulative effects, due to the presence of other industries. A reference to an air quality committee was made, by indicating that it has yet to decide where to install its air quality monitors. Another resident asked if Alderon is installing air quality monitors in Sept-Îles. Response / Location in EIS Rail cars will be emptied inside a building, and emissions will be treated by a dust collector. More information is available in Section Effects of dust emissions associated to the construction will be short-term and activities will be carried out according to construction standards and industry best practices. More information is available in Section Product loading of ships will be managed by the Port, which will comply with all applicable laws and regulations. Measures to control fugitive dust at the concentrate stockpile include adjusting the height of the stacker- reclaimer, and use of water as and when needed. Additional information is provided in Section Alderon will participate to the air quality monitoring effort initiated in Sept-Îles. Additional details are available in Section Kami Iron Ore Project Environmental Impact Statement Plain Language Summary B 77

84 Kami Iron Ore Project Environmental Impact Statement Plain Language Summary Table B.2 Water Resources Issue Potential contamination of water bodies Community Sept-Îles Summary of comments raised during consultation and engagement activities Many companies have discharged directly into the bay. Want to ensure that this project will not carry out the same practice. What measures would be used to avoid contamination of Sept-Îles Bay by red water? Water quality Sept-Îles Resident inquired whether Alderon had tested the quality of water in Sept-Îles Bay. Asked if Alderon will treat water in order to meet standards and regulations or to maintain water quality at its present level. Cumulative effects on water resources CRE Potential effects on water quality in the baie des Sept-Îles There is a lot of pressure around the Bay, concerned about cumulative effects. It would be great if elements of the Kami Project could be located further to the shore. Response / Location in EIS In order to prevent water contamination, the concentrate storage area, will be sealed with liner. Water run-off within the concentrate storage area will be directed toward a stormwater retention pond (with liner) where it will be treated before release to the environment. Final effluent treatment will meet or surpass Directive 019 criteria and will ensure that receiving water within the effluent mixing zone will not exceed the applicable CCME water quality guideline for the protection of aquatic life. More information can be found in Section Water quality in baie des Sept-Îles (anse Brochu) was analyzed for several parameters. More information can be found in Section Final effluent treatment will meet or surpass Directive 019 criteria and will ensure that receiving water within the effluent mixing zone will not exceed the applicable CCME water quality guideline for the protection of aquatic life. More information can be found in Section Product loading of ships will be managed by the Port, which will comply with all applicable laws and regulations. Alderon assessed several alternatives when choosing a site for the Terminal. The selected site was the most economically and technically feasible. More information regarding site selection can be found in Section 2.8. Alderon will minimize its influence on the baie des Sept-Îles including treatment of final effluent treatment will meet or surpass standards. More information can be found in Section B 78

85 Table B.3 Freshwater Fish, Fish Habitat, and Fisheries Issue Cumulative effects on fish and fish habitat Community CRE/CPESI Summary of comments raised during consultation and engagement activities Response / Location in EIS There is a lot of pressure around the Bay, Alderon assessed several alternatives when concerned about cumulative effects. It would be choosing a site for the Terminal. The selected great if elements of the Kami Project could be site was the most economically and technically located further to the shore. feasible. More information regarding site selection can be found in Section 2.8. Alderon will minimize its influence on the baie des Sept-Îles including treatment of final effluent treatment will meet or surpass standards. More information can be found in Section Fish population Sept-Îles Resident asked about the potential effects of the project on fish in ruisseau à la Baleine. Fish habitat Sept-Îles Resident voiced concern about impact of increasing rail traffic on the Nipississ River, particularly its effect on salmon spawning grounds. Discussed how the vibrations from the rail traffic would destroy salmon spawning. Table B.4 Wetland Issue Community Summary of comments raised during consultation and engagement activities Wetlands Sept-Îles There is a protected wetland in the Pointe-Noire area Table B.5 Birds, Other Wildlife and Their Habitats Issue Parks and protected areas Potential effects on wildlife species In response to concerns raised regarding the presence of fish at the Terminal site, Alderon conducted a fish and fish habitat survey. The findings of this survey are provided in Chapter 18. Rail operations in the vicinity of the Nipississ River are beyond the scope of the Project. This activity is the mandate of the QNS&L Railway and all operations are required to comply with all applicable provincial and federal regulations regarding fish and fish habitat. Response / Location in EIS No wetland was identified in the Project Development Area at the Kami Terminal. Information is available in Chapter 17. Community Summary of comments raised during consultation and engagement activities Response / Location in EIS Sept-Îles There is a protected wetland in the area. The Kami Terminal does not overlap with any protected or designated areas. The assessment of the Project on protected areas is provided in Section CRE The baie des Sept-Îles is an important Alderon conducted dispersion modelling for conservation zone for migratory birds and the Kami Terminal, the results of which indicate concerned about the potential effects of the that no substantive changes in air quality are dust generated from the project on the bay. expected on local or regional scales due to emissions from the Project. in the modelling Sept-Îles Resident raised issue of migratory birds and bird species at risk results are presented in Section As part of the EIS, field surveys were conducted to identify habitat and species potentially affected by the Kami Terminal. These surveys did not identify any rare or unique habitats that will be affected by the Kami Terminal. Additional information on bird species, including migratory birds, is provided in Section Kami Iron Ore Project Environmental Impact Statement Plain Language Summary B 79

86 Kami Iron Ore Project Environmental Impact Statement Plain Language Summary Table B.6 Species at Risk Issue Potential effects on SAR Community Sept-Îles Table B.7 Aboriginal Land Use Issue Potential interaction with existing Aboriginal rights/title Table B.8 Other Land Use Community Uashat Summary of comments raised during consultation and engagement activities Resident raised issue of migratory birds and bird SAR Response / Location in EIS In response to concerns related to the presence of bird species, including migratory species, at the Kami Terminal, field surveys were conducted to identify species presence. Although the Kami Terminal site does overlap with the geographic range of some bird species at risk, the field surveys did not identify any rare bird species in the vicinity of the Kami Terminal. Additional information on the distribution of bird species at risk, including migratory birds, is provided in Section Summary of comments raised during consultation and engagement activities Response / Location in EIS Uashat do not consider themselves as Québec Alderon has been engaged with Aboriginal Innu and they want to be involved in the entire groups on an ongoing basis on the Project as a Project, and not only the Québec components in whole (mine site, port infrastructure). Alderon the Port of Sept-Îles. will continue to engage Aboriginal groups throughout the life of the Project. Issue Community Summary of comments raised during consultation and engagement activities Visual Aesthetics Sept-Îles Visual effects of the port facilities, including stockpile Information on Aboriginal engagement is provided in Section Response / Location in EIS No impacts on visual aesthetics (viewscapes) are anticipated for residential areas of Sept- Îles as they are located on the opposite side of the Bay from the Kami Terminal, at a distance of approximately 7 km. They will represent a minimal visual change from other existing industrial port facilities. Additional information can be found in Sections 23.4 and 23.6 B 80

87 Table B.9 Community Services and Infrastructure Issue Cumulative effect on community services and infrastructure Availability of Sept-Îles housing for workers Community Summary of comments raised during consultation and engagement activities Response / Location in EIS CRE Cumulative socio-economic effects Construction activities associated with the Terminal site will require a workforce in the order of 200 to 300 workers over the next few years. Cumulative effects on the housing market and on traffic congestion are considered to be shortterm and will be significant. The assessment of cumulative effects on Community Services and Infrastructure is provided in Section CIM Conference Aren t you concerned that the QNS&L railway is The capacity of the QNS&L has been studied for becoming over utilized? many different potential future traffic volumes, both with and without the proposed Alderon traffic. Infrastructure improvement strategies have been identified from these studies that will maintain acceptable levels of service for all traffic on QNS&L and these strategies have been incorporated into the negotiations for a rail CRE Resident asked where people working on this project would be housed. Followed up with concerns about repercussions on housing in the community. Asked if accommodations will be built to lodge the workers. Noting that housing is an issue, a resident outlined a number of initiatives that have been completed or are being planned to deal with the increase in the housing demand. Access to housing and service industry in Sept- Îles during construction of port facilities. Railway traffic Labrador City The actual railway line and its railway are issues of concern. Has Alderon consulted with QNS&L about the projected total rail traffic in ? M-LJ Increased traffic from the Project may slow down the passenger train and delivery of goods (food and fuel) from Sept-Îles to Schefferville haulage contract. In order to manage the impact of Kami Terminal construction activities on regional housing supply Alderon will engage with local authorities and other stakeholders to address issues related to community services and infrastructure as needed. The assessment of Kami Terminal effects on housing is available in Section The capacity of the QNS&L has been studied for many different potential future traffic volumes, both with and without the proposed Alderon traffic. Infrastructure improvement strategies have been identified from these studies that will maintain acceptable levels of service for all traffic on QNS&L and these strategies have been incorporated into the negotiations for a rail haulage contract. Kami Iron Ore Project Environmental Impact Statement Plain Language Summary B 81

88 Kami Iron Ore Project Environmental Impact Statement Plain Language Summary Issue Community services Community Sept-Îles CRE Summary of comments raised during consultation and engagement activities Resident talked about issues with community services Access to housing and service industry in Sept- Îles during construction of port facilities. Response / Location in EIS In order to manage the impact of Kami Terminal construction activities on regional housing supply Alderon will engage with local authorities and other stakeholders to address issues related to community services and infrastructure as needed. By virtue of the characteristics of the required workforce, it is considered unlikely that these workers would exert additional demand on local employment and social services, health services and social programs, training and education services and programs, public safety and security services, municipal administrative capacity, or municipal services and infrastructure. The assessment of Kami Terminal effects on community infrastructure and services is available in Section In order to manage the impact of Kami Terminal construction activities on regional housing supply Alderon will engage with local authorities and other stakeholders to address issues related to community services and infrastructure as needed. The assessment of Kami Terminal effects on housing are available in Section B 82

89 Table B.10 Economy, Employment and Business Issue Cumulative effects to economy, employment and business Apprenticeship and Training Availability of local workers Local businesses Community Summary of comments raised during consultation and engagement activities Response / Location in EIS CRE Cumulative socio-economic effects Construction activities resulting from various Projects in the area will require an overall workforce in the order of 2,000 to 3,000 workers over the next few years as well as hundreds of additional employees over the life of several projects. Regional businesses are likely to benefit from contracts for materials and services both in the short-term and the long-term. Additional information on cumulative effects to economy, employment and business is provided in Section The Mayor suggested that Alderon contact the Education/Training institutions in the region Are you going to use local workers for operations or go FIFO? CIM Conference Many indications of interest by regional suppliers and contractors. In this regards, I believe we should hold information forums in St. John s and Sept-Îles when our contracting strategy is firmed up. Sept-Îles Involvement of the local communities and businesses in the procurement process for the construction and operation of the mine. Alderon is committed to build and maintain positive and long-term relationship with stakeholders. Alderon will engage with all interested parties. Additional information on consultation completed to-date is provided in Chapter 10. Alderon is committed to promoting regional subcontracting and employment, including local and Aboriginal opportunities. In addition, Alderon will collaborate with the regional economic forum to maximize local employment. Section 26.6 contains the assessment of Kami Terminal effects on employment and business. Alderon is committed to promoting regional subcontracting and employment, including local and Aboriginal opportunities. In addition, Alderon will collaborate with the regional economic forum to maximize local employment. Section 26.6 contains the assessment of Kami Terminal effects on employment and business. Kami Iron Ore Project Environmental Impact Statement Plain Language Summary Potential effects on local economy Sept-Îles State the company s intentions concerning local procurement The Mayor suggested that Alderon contact the CLD which is an entity that supports small and medium size businesses. He also suggested Alderon contact the local Chamber of Commerce and offers to speak at one of their functions. He also recommended a meeting with the Sept-Îles Economic Development Agency that looks after major industries. At the end of the predicted mine life, what are you going to do with your employees? As outlined in its Community Relations Policy, Alderon is committed to build and maintain positive and long-term relationship with stakeholders. Alderon will engage with all interested parties. Alderon will collaborate with the Regional economic forum. Additional information on consultation is provided in Chapter 10. The workforce will be kept informed of Project plans and, as with any other project, will be down-sized as the Project plans warrant. B 83

90 Cautionary Note Regarding Forward-Looking Information This news release contains "forward-looking information" concerning anticipated developments and events that may occur in the future. Forward looking information contained in this news release includes, but is not limited to, statements with respect to (i) future production at the Kami Property; (ii) infrastructure requirements; (iii) the estimation of inferred, indicated and measured mineral resources; (iv) the demand for iron ore and steel; (v) economic benefits and employment opportunities from the Kami Project; (vi) project timelines; and (vii) potential environmental impacts of the Kami Property and remediation measures. In certain cases, forward-looking information can be identified by the use of words such as "plans", "expects" or "does not expect", "is expected", "budget", "scheduled", "estimates", "forecasts", "intends", "anticipates" or "does not anticipate", or "believes", or variations of such words and phrases or state that certain actions, events or results "may", "could", "would", "might" or "will be taken", "occur" or "be achieved" suggesting future outcomes, or other expectations, beliefs, plans, objectives, assumptions, intentions or statements about future events or performance. Forward-looking information contained in this news release is based on certain factors and assumptions regarding, among other things, receipt of governmental and other approvals, the estimation of mineral resources, the realization of resource estimates, iron ore and other metal prices, the timing and amount of future exploration and development expenditures, the estimation of initial and sustaining capital requirements, the estimation of labour and operating costs, the availability of necessary financing and materials to continue to explore and develop the Kami Property in the short and long-term, the progress of exploration and development activities, the receipt of necessary regulatory approvals, the completion of the environmental assessment process, the estimation of insurance coverage, and assumptions with respect to currency fluctuations, environmental risks, title disputes or claims, and other similar matters. While the Company considers these assumptions to be reasonable based on information currently available to it, they may prove to be incorrect. Forward looking information involves known and unknown risks, uncertainties and other factors which may cause the actual results, performance or achievements of the Company to be materially different from any future results, performance or achievements expressed or implied by the forward-looking information. Such factors include risks inherent in the exploration and development of mineral deposits, including risks relating to changes in project parameters as plans continue to be redefined including the possibility that mining operations may not commence at the Kami Property, risks relating to variations in mineral resources, grade or recovery rates resulting from current exploration and development activities, risks relating to the ability to access rail transportation, sources of power and port facilities, risks relating to changes in iron ore prices and the worldwide demand for and supply of iron ore and related products, risks related to increased competition in the market for iron ore and related products and in the mining industry generally, risks related to current global financial conditions, uncertainties inherent in the estimation of mineral resources, access and supply risks, reliance on key personnel, operational risks inherent in the conduct of mining activities, including the risk of accidents, labour disputes, increases in capital and operating costs and the risk of delays or increased costs that might be encountered during the development process, regulatory risks, including risks relating to the acquisition

91 of the necessary licenses and permits, financing, capitalization and liquidity risks, including the risk that the financing necessary to fund the exploration and development activities at the Kami Property may not be available on satisfactory terms, or at all, risks related to disputes concerning property titles and interest, risks related to disputes with Aboriginal groups, environmental risks and the additional risks identified in the Risk Factors section of the Company s Annual Information Form for the most recently completed financial year or other reports and filings with applicable Canadian securities regulators. Although the Company has attempted to identify important factors that could cause actual actions, events or results to differ materially from those described in forward-looking information, there may be other factors that cause actions, events or results not to be as anticipated, estimated or intended. There can be no assurance that forward-looking information will prove to be accurate, as actual results and future events could differ materially from those anticipated in such information. Accordingly, readers should not place undue reliance on forward-looking information. The forward-looking information is made as of the date of this news release. Readers are cautioned that the foregoing lists of factors are not exhaustive. The forward-looking information contained in this news release is expressly qualified by this cautionary statement. Except as required by applicable securities laws, the Company does not undertake any obligation to publicly update or revise any forward-looking information. Note Regarding Production Timelines Alderon has not yet completed a Pre-Feasibility study or Feasibility Study to demonstrate the economic viability of the Kami Property. Furthermore, no Mineral Reserves have been established on the Kami Property. Any statements regarding planned production rates, projected cash flows, payback period, IRR, NPV, construction timelines and production startup at the end of 2015 assume that Alderon is or will be able to complete all of the required steps to bring the Kami Property into commercial production including the completion of a Feasibility Study to demonstrate the economic viability of the Kami Property, the completion of the environmental assessment process, the conclusion of infrastructure agreements for railway transportation, power and access to port facilities and that Alderon obtains the necessary project financing to pay for the capital costs to develop and construct a mine at the Kami Property. There is no certainty that Alderon will be able to complete any or all of these steps and reference should be made to the Risk Factors sections of Alderon s Annual Information Form for the most recently completed financial year

92 Kami Iron Ore Project Environmental Impact Statement Plain Language Summary (this page is deliberately blank, for layout purposes) 10 Fort William Place, 8th Floor St. John s, NL A1C 5W2 Tel: (709) Fax: (709) B 84