Review of the Detour Lake Contingency Power Project Environmental Assessment

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1 Review of the Detour Lake Contingency Power Project Environmental Assessment

2 Review of the Detour Lake Contingency Power Project Environmental Assessment Review prepared pursuant to subsection 7(1) of the Environmental Assessment Act, R.S.O Province of Ontario by the Ontario Ministry of the Environment, Environmental Assessment and Approvals Branch PIBS 7753e 2011, Queen s Printer for Ontario For more information: call or toll free pic .moe@ontario.ca

3 NEED MORE INFORMATION? Public Record Locations The public record for this environmental assessment can be reviewed during normal business hours at the following ministry office: Ministry of the Environment Environmental Assessment and Approvals Branch 2 St.Clair Avenue West, Floor 12A Toronto, Ontario Voice: / Fax: The Review and Notice of Completion are also available at the following locations: Ministry of the Environment Environmental Assessment & Approvals Branch 2 St. Clair Avenue West, Floor 12A Toronto ON M4V 1L / Ministry of the Environment Timmins District Office, Hwy 101 East South Porcupine ON P0N 1H / Ministry of Natural Resources 2 Third Avenue Cochrane ON P0L 1C Detour Gold Corporation Royal Bank Plaza, North Tower 200 Bay St, Suite 2040 Toronto ON M5J 2J Town of Moosonee 5 First Street Moosonee ON P0L 1Y Timmins Public Library 320 Second Avenue Timmins ON P4N 8A This Review is subject to the provisions of Ontario Regulation 616/98 which sets out a deadline for the completion of this document. The deadline for the completion of the Review was September 2, This paragraph and the giving of the Notice of Completion are the notices required by subsection 7(3) of the Environmental Assessment Act. The Review documents the ministry s evaluation of the EA and takes the comments of the government agencies, the public and Aboriginal communities into consideration. Cette publication hautement spécialisée n est disponible qu en anglais en vertu du règlement 441/97, qui en exempte l application de la Loi sur les services en français. Pour obtenir de l aide en français, veuillez communiquer avec le ministère de l Environnement au

4 Table of Contents Executive Summary Environmental Assessment Process Terms of Reference Environmental Assessment Ministry Review The Proposed Undertaking Results of the Ministry Review Conformance with ToR and EAA Ministry Analysis Consultation Conclusion EA Process Key Issues Conclusion Proposed Undertaking Key Issues Conclusion Summary of the Ministry Review What Happens Now? Additional Approvals Required List of Appendices Appendix A Environmental Assessment Act Requirements Appendix B Submissions Received During the Initial Comment Period List of Tables Table 1 Government Review Team Comment Summary Table Table 2 Public Comment Summary Table Table 3 Aboriginal Communities Comment Summary Table

5 Detour Lake Contingency Power Project Environmental Assessment Review Executive Summary WHO Detour Gold Corporation WHAT Ministry Review of an Environmental Assessment (EA) for the proposed undertaking which includes: the construction and operation of 10 megawatts of diesel-fired electricity generation, to support the development of a new mine at Detour Lake. WHEN EA Submitted: June 10, EA Comment Period: June 10, 2011 to July 29, Ministry Review comment period: September 30, 2011 to November 4, WHERE The Detour Lake mine site is located approximately 185 kilometres northeast of the Town of Cochrane. WHY The proponent acquired the mine site in 2007 and is now moving forward with the planning of an open pit gold mine and related processing facilities referred to as the Detour Lake Project. Power for the Detour Lake mine site will eventually be provided by a 230 kilovolt transmission line which will connect the Detour Lake mine site to the Ontario electrical grid at the Pinard transformer station approximately 140 kilometres away; however, because of uncertainties with constructing and energizing the transmission line, a reliable, short term source of power may be required for construction of the Detour Lake Project. CONCLUSIONS The Ministry of the Environment s Review of the EA concluded that it was prepared in accordance with the approved Terms of Reference and contains sufficient information to assess the environmental effects of the proposed undertaking. September 30,

6 Detour Lake Contingency Power Project Environmental Assessment Review 1. Environmental Assessment Process Environmental Assessment (EA) is a proponent driven planning process designed to incorporate the consideration of the environment into decision-making by assessing the effects of an undertaking on the environment. In Ontario, the Environmental Assessment Act (EAA) sets out the general contents for the preparation of an EA, as well as the ministry s evaluation process. For those proponents and undertakings subject the EAA, approval under the EAA is required before the undertaking can proceed. Proponents address a wide range of potential effects on the natural, social, cultural and economic environments to ensure the protection, conservation and wise management of the environment. An EA determines, on the basis of the environmental effects, if an undertaking should proceed, and if so, how environmental effects can be managed. EAs may identify a problem or opportunity, consider alternative ways of addressing the problem or opportunity, evaluate the environmental effects of the alternatives and select a preferred undertaking from the alternatives. The proponent must consider actions to avoid, reduce and mitigate potential environmental effects. In preparing the EA, the proponent completes various studies and consults with interested stakeholders including government agencies, the public and Aboriginal communities to evaluate the alternatives and determine the preferred undertaking. Once the undertaking is approved, the proponent is required to monitor to demonstrate compliance with standards, regulations and the EAA approval. 1.1 Terms of Reference EA Process ToR Approval EA Preparation EA Submission EA Comment Period Ministry Review Review Comment Period Minister s Decision Preparing an EA is a two-step application to the Minister of the Environment (Minister). The first step requires the proponent to prepare and submit a Terms of Reference (ToR) to the Ministry of the Environment (ministry) for review and approval. The ToR is the work plan or framework for how the EA will be prepared. On March 2, 2011, the Minister approved the Detour Lake Contingency Power Project ToR. The ToR set out how the Detour Gold Corporation (Detour Gold) would assess alternatives, assess environmental effects and consult with the public during the preparation of the EA. The ToR outlines that an individual EA was required pursuant to the Electricity Projects Regulation (Ontario Regulation 116/01 under the EAA (Reg. 116/01)), and that the EA would be completed in accordance with subsections 6(2)(c) and 6.1(3) of the EAA. The ToR established the purpose of the undertaking and the preferred September 30,

7 Detour Lake Contingency Power Project Environmental Assessment Review alternative to the undertaking, and outlined the alternative methods of carrying out the undertaking that would be assessed in the EA. The ToR also outlined a consultation plan for the EA process. 1.2 Environmental Assessment Since the ToR has been approved by the Minister, the proponent can proceed to the second step of the EA process and carry out the EA. The EA must be prepared in accordance with the approved ToR and the requirements of the EAA. Once the proponent has carried out the EA, including consultation, the EA is submitted to the ministry for review and approval. On June 10, 2011, Detour Gold submitted the Detour Lake Contingency Power Project EA to the ministry for approval for the proposed construction and operation of 10 megawatts (MW) of diesel-fired electricity generation, to support the development of a new mine at Detour Lake. The proposed power generation is a contingency measure that will be implemented because of uncertainties with the construction and energizing of the new transmission line to the Detour Lake mine site. The EA comment period ended on July 29, Ministry Review The EA was circulated for review to a Government Review Team (GRT). The GRT, including federal, provincial and local agencies, reviewed the EA to ensure that the information and conclusions of the EA were valid, based on their agencies mandates. The public and Aboriginal communities also had an opportunity to review the EA and submit their comments to the ministry. All comments received by the ministry are considered by the Minister before a decision is made about the undertaking. The EAA requires the ministry to prepare a review of the EA, known simply as the Ministry Review (Review). The Review is the ministry s evaluation of the EA. The purpose of the Review is to determine if the EA has been prepared in accordance with the approved ToR and therefore meets the requirements of the EAA and whether the evaluation in the EA is sufficient to allow the Minister to make a decision about the proposed undertaking. The Review outlines whether the information contained in the EA supports the recommendations and conclusions for the selection of the proposed undertaking. Ministry staff, with input from the GRT, evaluates the technical merits of the proposed undertaking, including the anticipated environmental effects and the proposed mitigation measures. The Review also provides an overview and analysis of the public, agency and Aboriginal community comments on the EA and the proposed undertaking. September 30,

8 Detour Lake Contingency Power Project Environmental Assessment Review The Minister of the Environment considers the conclusion of the Review when making a decision; the Review itself is not the EA decision making mechanism. The Minister s decision will be made following the end of the five-week Review comment period. The Minister s decision is subject to the approval of the Lieutenant Governor in Council. The Review comment period allows the GRT, the public and Aboriginal communities to see how their concerns with the EA and the proposed undertaking have been considered. During the Review comment period, anyone can submit comments on the EA, the undertaking and the Review. In addition, anyone can request that the Minister refer the EA, or any matter relating to the EA, to the Environmental Review Tribunal for a hearing if they believe that there are significant outstanding environmental effects that the EA has not addressed. Requests for a hearing can only be made during this comment period. The Minister will consider all requests and determine if a hearing is necessary. A Notice of Completion of the Review will be published in local newspapers indicating that this Review has been completed and is available for a five-week comment period from September 30, 2011 to November 4, The newspapers where the Notice of Completion of the Review was published are: The Timmins Daily Press; The Wawatay News; The Cochrane Times Post; L'express de Timmins; and Cochrane L'Ours Noir. Copies of the Review will be placed in the same public record locations where the EA was available, and copies have been distributed to the GRT members and potentially affected or interested Aboriginal communities. 2. The Proposed Undertaking Detour Gold is seeking EAA approval for the construction and operation of 10 MW of diesel-fired electricity generation, to support the development of a new mine at Detour Lake. The proposed power generation is a contingency measure that will be implemented because of uncertainties with the construction and energizing of the new transmission line to the Detour Lake mine site. The Detour Lake mineral deposit is located approximately 185 kilometres (km) northeast of Cochrane, Ontario (Figure 1). The Detour Lake mine was actively mined by another company from 1983 to 1999 and subsequently decommissioned. The proponent acquired the property in 2007 and is now moving forward with the planning of the redevelopment of the open pit gold mine and related processing facilities referred to as the Detour Lake Project. September 30,

9 Detour Lake Contingency Power Project Environmental Assessment Review A dependable power supply, up to approximately 120 MW of available power, is required for the later stages of construction and operation of the mine. Detour Gold determined that a 230 kilovolt (kv) transmission line would be required to provide a reliable energy source for the mining operations. The construction of the new transmission line and related infrastructure was subject to a separate individual EA process which was approved on December 13, Detour Gold plans to construct the transmission line in two phases and expects the mining operations to commence in early However, because of uncertainties with the construction and energizing of the new transmission line to the Detour Lake mine site, the construction of the mine may not be completed in a timely manner and in keeping with the mine construction schedule. Accordingly, as a contingency measure, Detour Gold is pursuing approvals to construct and operate 10 MW of diesel-fired electricity generation to support construction at the site and help maintain the mine construction schedule. If EAA approval is granted, the Detour Lake Contingency Power Project will be completed in accordance with the terms and provisions outlined in the EA; any proposed conditions of approval; and will include the details outlined above. In addition, Detour Gold must still obtain all other legislative approvals it may require for the undertaking. September 30,

10 Detour Lake Contingency Power Project Environmental Assessment Review Figure 1: Detour Lake Contingency Power Project Environmental Assessment September 30,

11 Detour Lake Contingency Power Project Environmental Assessment Review 3. Results of the Ministry Review The Review provides the analysis of the EA. The Review is not intended to summarize the EA, nor present the information found in the EA. For information on the decision making process, refer to the EA itself. The EA and supporting documentation outlines the EA planning process and demonstrates how the proponent has selected the preferred undertaking and made the final decision. 3.1 Conformance with ToR and EAA Ministry Analysis The ministry coordinated an analysis of the EA with the GRT that, in part, looked at whether the requirements of the ToR have been met. The ministry concludes that the EA followed the framework set out in the approved ToR, addressed the commitments made in the approved ToR, and demonstrated how the required components of the EAA have been met. The purpose of the Ministry Review is to determine whether: The EA has met the requirements of the ToR and the EAA. There are any outstanding issues with the EA. The proposed undertaking has technical merit. Must Haves in the EA: The EA must be prepared in accordance with the approved ToR. EA must include all the basic EAA information requirements. EA demonstrates where all the additional commitments in the ToR were met, including studies and the consultation process. Appendix A summarizes this analysis and identifies how the ToR requirements have been addressed in the EA Consultation Section 5.1 of the EAA states: One of the key requirements of the EAA is pre-submission When preparing proposed consultation completed during the preparation of the EA. This terms of reference and an consultation is the responsibility of the proponent and must be environmental assessment, the undertaken prior to the submission of the EA and in accordance proponent shall consult with such with the consultation plan outlined in the ToR. The persons as may be interested. consultation outlined by Detour Gold in its EA included public information sessions, newspaper notices and advertisements, public mailings, a project web site, meetings with local Aboriginal communities and an opportunity for Aboriginal communities to review and comment on the draft EA. Overall, the ministry is satisfied with the level of consultation that occurred during the preparation and review of this EA and determined that it was generally appropriate for the proposed undertaking. The EA clearly documents the consultation methods utilized by Detour Gold to engage the GRT, the general public, stakeholders and Aboriginal communities in the EA process. September 30,

12 Detour Lake Contingency Power Project Environmental Assessment Review Once the EA is submitted to the ministry, additional ministry driven consultation occurs during the EA comment period. The GRT, the public and affected Aboriginal communities are provided with the opportunity to review the EA and to submit comments to the ministry on whether the requirements of the ToR had been met, on the EA itself and on the proposed undertaking. All comments received by the ministry during the EA comment period were forwarded to Detour Gold for a response. Summaries of the all comments received along with the Detour Gold s responses are included in Tables 1-3. Copies of the submissions are also available in Appendix B. Government Review Team Consultation with the GRT was conducted throughout the EA process. GRT members from various agencies were provided copies of the EA for their review during the sevenweek comment period. Comments were received from the ministry s Water and Wastewater Unit of the Environmental Assessment and Approvals Branch, the ministry s Timmins District Office, and the ministry s Air technical reviewer in Eastern Region. These comments related to spill containment measures and system maintenance. All comments received were forwarded by the ministry to Detour Gold for a response. A summary of the comments received and Detour Gold s responses can be found in Table 1. A summary of the key issues raised can be found in section of this Review. Public Consultation Public consultation during the preparation of the EA included public information sessions in Timmins and Cochrane on May 11 and May 12, 2011 to provide a project update and discuss the results of the EA including mitigation strategies for any adverse effects. The public consultation program also consisted of: Newspaper notices and advertisements; Public mailings; and A project web site. The public was also given the opportunity to review and comment on the final EA once it was submitted to the ministry. One letter was received from a public organization during the seven-week comment period. The letter was in support of the proposed undertaking and no issues were raised. A summary of this letter and Detour Gold s responses can be found in Table 2. Aboriginal Community Consultation In addition to public consultation, there is a legal requirement to consult with Aboriginal communities who have Aboriginal or treaty rights that need to be considered. The Crown has a duty to consult with and accommodate Aboriginal communities when it has knowledge, real or constructive, of the existence or potential existence of an Aboriginal September 30,

13 Detour Lake Contingency Power Project Environmental Assessment Review or treaty right and contemplates conduct that might adversely affect it. However, the Crown may delegate the procedural aspects of consultation to proponents, and recognizes a corresponding responsibility of Aboriginal communities to participate in this process, make their concerns known and respond to efforts to address their concerns. Detour Gold identified that the proposed undertaking overlaps with the traditional territories asserted by Moose Cree First Nation (MCFN), Taykwa Tagamou Aboriginal rights stem from practices, customs or traditions which are integral to the distinctive culture of the Aboriginal community claiming the right. Treaty rights stem from the signing of treaties by Aboriginal peoples with the Crown. Aboriginal rights and treaty rights are protected by section 35 of the Constitution Act, Nation (TTN) and Wahgoshig First Nation (WFN). In addition, Detour Gold identified that the Métis living in northeastern Ontario have asserted Aboriginal rights in the region in which the project is located. As such, the proposed undertaking has the potential to affect traditional land uses. Detour Gold has been consulting with the above noted Aboriginal communities to document and determine any potential effects of the proposed undertaking on traditional uses. Potential effects would include any changes to the environment (i.e. air and noise emissions) that could negatively impact the health or abundance of wildlife or plant populations and the potential to negatively affect human health through consumption and/or use of these animals and/or plants. Impact Benefit Agreements (IBA) have been put in place with First Nation communities whose Aboriginal or Treaty rights may be impacted by the proposed undertaking. IBAs have been signed with MCFN, TTN and WFN. These agreements are intended to cover all members of the potentially impacted First Nations from loss. Detour Gold has also signed a Memorandum of Understanding (MOU) with the Métis Nation of Ontario (MNO) that covers such issues as community consultation and participation in the project. The ministry was not involved in the negotiations between Detour Gold and the Aboriginal communities, however according to Detour Gold, the agreements between the proponent and the Aboriginal communities cover a number of interests, including: Environmental protection; Employment, training and business opportunities; Social and cultural awareness and protection; Dispute resolution; and Other matters. During the preparation of the EA, Detour Gold held meetings with MCFN between March 15 and March 31, 2011; and TTN on March 30 and March 31, An Open House was held with WFN on May 11, Community members were welcome to attend any of the public information sessions. Detour Gold also provided Aboriginal communities with an opportunity to review and comment on the draft EA. September 30,

14 Detour Lake Contingency Power Project Environmental Assessment Review Projects notices and copies of the EA were provided at the MCFN, TTN and WFN Band Offices and the Timmins Métis Council and Northern Lights Métis Council offices for review. Based on their general proximity to the project, Detour Gold also provided project copies of the EA to the MoCreebec Council of the Cree Nation for review and comment. Comments were received from MCFN s Moose Cree Resource Protection (MCRP) related to site clearing, noise levels and air emissions. A summary of the comments received and Detour Gold s responses can be found in Table 3. A summary of the key issues raised can be found in section of this Review. No other Aboriginal communities have provided comments. Through the adoption of agreements and other environmental protection measures described in the EA, the potential effects on traditional land use are expected to be limited Conclusion The EAA requires a proponent to consult with interested persons during the preparation of the EA and report on the results of those consultations. Requirements of the EAA for consultation with the public, Aboriginal communities and the GRT have been met. The ministry is satisfied that Detour Gold appropriately followed the consultation plan outlined in the approved ToR. Overall, the ministry believes that Detour Gold provided sufficient opportunities for the public, interested stakeholders, and Aboriginal communities to be consulted during the preparation of the EA. The EA clearly documents the consultation methods utilized by Detour Gold to engage the public, the GRT and Aboriginal communities during the EA process. The EA clearly sets out the issues and concerns raised and how they were addressed or will be addressed in the future. 3.2 EA Process EA is a planning process that requires the proponent to identify an existing problem or opportunity, consider alternative ways of addressing the problem or opportunity, evaluate the potential environmental effects of the alternatives and select a preferred alternative. Detour Gold has been exploring the previously developed Detour Lake mineral property since The Detour Lake deposit was operated by another mining company from 1983 to 1999, but Detour Gold has now determined that future operation at the site would be viable. Detour Gold determined that the proposed mining activities would require up to approximately 120 MW of available power and that a 230 kv transmission line would be required to provide a reliable energy source for the mining operations. The construction September 30,

15 Detour Lake Contingency Power Project Environmental Assessment Review of the new transmission line and related infrastructure was subject to a separate individual EA process which was approved on December 13, Detour Gold plans to construct the transmission line in two phases and expects the mining operations to commence in early However, because of uncertainties with the construction and energizing of the new transmission line to the Detour Lake mine site, the construction of the mine may not be completed in a timely manner and in keeping with the mine construction schedule. To support construction at the site and help maintain the mine construction schedule, Detour Gold is pursuing approvals to construct and operate 10 MW of diesel-fired electricity generation. Through preliminary planning work, the proponent assessed a range of potential alternatives to provide power to the Detour Lake mine site, including onsite diesel-fired or natural gas generation and hydroelectric or other forms of renewable energy. While a number of these power supply alternatives were theoretically possible, all of the alternatives except for onsite diesel-fired generation were screened out during the preparation of the ToR due to greater costs, environmental impacts, comparatively lower capacity, infrastructure availability, reliability or technical feasibility. The Do Nothing alternative was also brought forward for further consideration to demonstrate the relative advantages and disadvantages of the proposed undertaking. The EA itself evaluated alternative methods of carrying out the undertaking. The methodology for evaluating the alternative methods consisted of the assessment of each alternative based on a number of performance objectives, including: Cost-effectiveness; Technical applicability and/or system integrity and reliability; Ability to service the site effectively; Effects to the natural environment; Effects to the human environment; and Amenability to reclamation. Potential effects on the environment were determined based on a study area for the EA which included: A local study area to assess the natural and biophysical components. The local study area was defined by lands held by Detour Gold that make up the Detour Lake Project, consisting of an approximate 5 km radius around the Detour Lake mine site; and A regional study area to assess human environment components. The alternatives were rated preferred, acceptable or unacceptable based on the objectives, and then qualitatively compared to each other to determine the most acceptable alternative. The alternative methods that were evaluated included: September 30,

16 Detour Lake Contingency Power Project Environmental Assessment Review Siting alternatives; and Design alternatives. Four siting alternatives were assessed, including: Placement of facilities on a brownfield footprint in close proximity to key power loads; Placement of facilities on greenfield lands/near environmentally sensitive areas in close proximity to key loads; Placement of facilities on a brownfield footprint distant from key loads; and Placement of facilities on greenfield lands distant from key loads. Siting the generators on a brownfield location near the permanent facilities requiring power was preferred. Alternative locations were acceptable but discarded as they would cause unnecessary disturbance. Two design alternatives were defined related to the configuration of diesel generators to meet the 10 MW power requirement, including utilizing smaller generator units (1.2 MW units) and utilizing larger generator units (>1.2 MW units). No other design alternatives were considered, as the generator design must meet design standards, and ministry air quality and noise requirements. Utilizing a design that includes smaller generator units was preferred. The primary difference between the use of smaller generators versus larger generators is transportability. Once the preferred alternative was determined, the EA evaluated the potential environmental effects of the undertaking and identified mitigation measures to avoid or minimize environmental effects. Environmental effects were determined for the construction, operation and decommissioning phases of the undertaking and included a range of environmental components, including the atmospheric environment, terrestrial environment, aquatic environment, socio-economic and cultural environment. Net effects were assessed based on the value of the environmental component, the magnitude, extent, duration, frequency, reversibility and likelihood of potential effects, and the application of available mitigation measures. In general, the EA concluded that there would be no significant net effects from the undertaking after mitigation measures are applied. The proposed mitigation measures include: Utilizing brownfield lands and existing infrastructure to avoid direct habitat effects; Designing generator units to allow for good atmospheric dispersion and to be insulated as required to reduce noise propagation; Maintaining spill response equipment at each generator location; Complying with the MOUs and IBAs with Aboriginal communities whose Aboriginal or treaty rights may be infringed by the proposed undertaking; and September 30,

17 Detour Lake Contingency Power Project Environmental Assessment Review Use industry best management practices for project design and environmental management during construction, operation and decommissioning. In addition to the application of mitigation measures where appropriate, Detour Gold commits in the EA to undertaking environmental monitoring to ensure that all commitments made in the EA are fulfilled and that the undertaking will be compliant with all legislation, approvals and permits. The EA identifies specific components of the undertaking that will be monitored and it outlines a plan for weekly inspections during construction, post-construction inspections, ongoing discussions with stakeholders regarding socio-cultural impacts and mitigation, and a formal complaints procedure Key Issues No issues with respect to the EA process were identified during the seven-week comment period Conclusion Overall, the ministry, in consultation with the GRT, is satisfied with the proponent s decision making process. The EA contains an explanation of the problems and opportunities that prompted the study and the decision making process documented in the EA was logical and transparent. The EA evaluates a reasonable range of alternatives based on a broad definition of the environment, provides a description of the affected environment in the study area and identifies the components of the environment that may be affected by the proposed undertaking. The ministry concludes that the EA was prepared in accordance with the approved ToR and the requirements of the EAA. 3.3 Proposed Undertaking The proposed undertaking is described in section 5.0 of the EA and was evaluated based on the potential advantages and disadvantages to the environment. A broad definition of the environment was used to evaluate the potential effects of the proposed undertaking. The proposed undertaking consists of the construction and operation of 10 MW of dieselfired electricity generation, to support the development of a new mine at Detour Lake. The proposed power generation is a contingency measure that will be implemented because of uncertainties with the construction and energizing of the new transmission line to the Detour Lake mine site. The onsite diesel-fired generation is proposed to comprise of eight 1.2 MW generators or an equivalent configuration based on the assessment of environmental impacts. Other generator configurations (i.e. one or more units > 1.2 MW) could be utilized as long as other aspects including the environmental effects remain the same. Detour Gold will ensure that proper oversight occurs with any modifications such as above, in order to ensure that the environmental effects are minimized and remain consistent with the September 30,

18 Detour Lake Contingency Power Project Environmental Assessment Review assessment of environmental effects determined through the EA. Although the number, size and timing of the generators may change according to the construction needs, the total combined generating capacity will be under 10 MW. Generator units will be located at the Detour Lake mine site, adjacent to existing generators on site (Figure 2) or at an equivalent site nearby. Each unit will be selfcontained, consisting of a diesel engine connected to an electrical generator with integral switchgear and controls. The self-contained generator units include a double-walled fuel tank which will provide fuel storage. The tanks will be equipped with appropriate measures to prevent and monitor tank ruptures or overflows. The generator units will be insulated as required to reduce noise propagation Key Issues Key issues regarding the proposed undertaking were gathered during the EA review comment period. Issues were raised by the GRT and Aboriginal communities. These submissions can be found in Appendix B. All comments, including Detour Gold s responses and ministry s level of satisfaction can be found in Tables 1-3. The issues raised by the GRT and Aboriginal communities were related to spill containment measures, system maintenance, site clearing, noise levels and air emissions. Comments were provided by the ministry s Water and Wastewater Unit related to requests for clarification on the spill containment measures for the generator units and the need for a high level alarm to be put in place on all fuel storage tanks to ensure that they do not overflow during filling operations. Detour Gold clarified that the generator units are entirely self-contained and include a double-walled fuel tank which will provide fuel storage. The tanks will be equipped with appropriate measures, such as a high level alarm, to prevent and monitor tank ruptures or overflows. The ministry s Water and Wastewater Unit and Timmins District Office advised Detour Gold of the need for a contingency plan that would list the potential clean-up contractors and certified waste haulers in case a spill occurs, and the need for a Spill Prevention, Control and Countermeasures Plan. Detour Gold confirmed a contingency plan would be prepared prior to transportation of fuel to the site and that a Spill Prevention, Control and Countermeasures plan is available for the Detour Lake Project and is applicable to the proposed undertaking. The ministry s Timmins District Office also suggested Detour Gold consider fully equipped spill response trailers at strategic locations on site. Detour Gold will consider this approach. With the mitigation measures proposed and considering the distance between the generators and watercourses, Detour Gold does not believe there is a significant potential for a spill that would impact the natural environment or not be readily cleaned up. September 30,

19 Detour Lake Contingency Power Project Environmental Assessment Review The ministry s Air technical reviewer agreed with the conclusions of the air quality assessment conducted for the proposed undertaking but recommended Detour Gold ensure that system maintenance records be maintained for the two year period the system is expected to be in operation, and that Detour Gold should evaluate the need for longer use of the system at the one-year mark due to uncertainties with the construction and energizing of the new transmission line and interested stakeholders and regulatory agencies should be advised. Detour Gold agreed and committed to these recommendations. Comments were provided by MCFN s MCRP related to site clearing, noise levels and air emissions. MCRP suggested that site clearing take place during the winter months when the ground is frozen. Snow cover and frozen ground can help protect the surface organic layers, support the weight of the machinery, limit soil compaction and prevent water management and erosion problems. Detour Gold confirmed that where the terrain is wet and organics are deeper, winter site clearing is the preferred approach when future development of the land by infrastructure/facilities is not proposed. MCRP also recommended that noise levels, air emission data and if necessary, the installation parameters (i.e. stack height, exhaust velocity etc.) should be reassessed once specific generator units are selected to ensure ministry requirements continue to be met. Detour Gold confirmed that once the generators units to be used have been identified, a reassessment and if appropriate, remodelling will be conducted to ensure that the ministry requirements will continue to be met including the requirements of a Certificate of Approval (Air) under the Environmental Protection Act (EPA). Detour Gold has provided additional information related to the issues raised above and commitments for addressing them as the project proceeds. The ministry was satisfied with the responses Conclusion The ministry is satisfied that the provisions of the EA and the commitments made by Detour Gold in response to comments received will ensure that: the concerns raised by the GRT and Aboriginal communities will be adequately addressed as the project proceeds, the onsite diesel-fired generation will be installed and operated to comply with ministry s standards; and environmental effects can be managed. September 30,

20 Detour Lake Contingency Power Project Environmental Assessment Review Figure 2: Detour Lake Contingency Power Project Environmental Assessment APPROXIMATE AREA IN WHICH THE PROPOSED PROJECT WILL BE LOCATED September 30,

21 Detour Lake Contingency Power Project Environmental Assessment Review 4. Summary of the Ministry Review The Review has explained the ministry s analysis for the Detour Lake Contingency Power EA. This Review concludes: The EA complies with the requirements of the approved ToR and has been prepared in accordance with the EAA; The EA has evaluated a reasonable range of alternative methods based on a broad definition of the environment and assessed the potential environmental effects of the proposed undertaking; The ministry is satisfied that the consultation opportunities provided by Detour Gold enabled an acceptable level of participation by the public, Aboriginal communities and the GRT; Concerns raised by the GRT and Aboriginal communities have either been addressed by Detour Gold, or can be addressed through commitments made by Detour Gold. The EA has provided sufficient information to enable a decision to be made about the application to proceed with the undertaking. September 30,

22 Detour Lake Contingency Power Project Environmental Assessment Review 5. What Happens Now? The Review will be made available for a five-week comment period. During this time, all interested parties, including the public, the GRT and Aboriginal communities can submit comments to the ministry about the proposed undertaking, the EA and/or the ministry Review. At this time, anyone can request that the Minister refer either all or part of the EA to the Environmental Review Tribunal for a hearing if they believe that their concerns have not been addressed. At the end of the Review comment period, ministry staff will make a recommendation to the Minister concerning whether the EA has been prepared in accordance with the ToR and the requirements of the EAA and whether the proposed undertaking should be approved. When making a decision, the Minister will consider the purpose of the EAA, the ToR, the EA, the Review, the comments submitted during the EA and the Review comment periods and any other matters the Minister may consider relevant. The Minister will make one of the following decisions: Next Step in the EA Process ToR Approval EA Preparation EA Submission EA Comment Period Ministry Review Review Comment Period Minister s Decision Give approval to proceed with the undertaking; Give approval to proceed with the undertaking subject to conditions; or Refuse to give approval to proceed with the undertaking. Prior to making that decision, the Minister may also refer either part of or the entire EA to mediation or refer either part of or the entire EA to the Environmental Review Tribunal for a decision. If the Minister approves, approves with conditions or refuses to give approval to the undertaking, the Lieutenant Governor in Council must concur with the decision. 5.1 Additional Approvals Required If EAA approval is granted, Detour Gold will still require other legislative approvals to design, construct and operate this undertaking. Section 11.0 of the EA outlines additional approvals that may be required. These approvals may include: EPA approval; and, If EAA approval is granted, the proponent must still obtain any other permits or approvals required to construct and operate this undertaking. September 30,

23 Detour Lake Contingency Power Project Environmental Assessment Review Ministry of Northern Development, Mines and Forestry approval for the decommissioning of the undertaking in accordance with the certified mine Closure Plan. These approvals cannot be issued until approval under the EAA is granted. September 30,

24 Appendix A Environmental Assessment Act Requirements

25 Appendix A: Environmental Assessment Act and Terms of Reference (ToR) Requirements of the Environmental Assessment (EA) EA Decision Making Process Problem/Opportunities EAA and ToR Requirements Identify an existing problem or opportunity Purpose of the Undertaking: s.6.1(2)(a) Description and Characteristics of the Requirements The EA should contain a brief explanation of the problem or opportunity that prompted the proposed activity. If a specific undertaking has been identified provide a brief description. Analysis of the EA Detour Gold has been exploring the previously developed Detour Lake mineral property since Detour Gold has determined that future operation at the site would be viable and is now moving forward with the planning of the redevelopment of the mine at Detour Lake. Detour Gold determined that a transmission line would be required to provide a reliable energy source for the mining operations. Detour Gold plans to construct the transmission line in two phases and expects the mining operations to commence and gold to begin pouring by the first quarter of However, because of uncertainties with the construction and energizing of the new transmission line to the Detour Lake mine site, the construction of the mine may not be completed in a timely manner and in keeping with the mine construction schedule. The purpose of the undertaking is to construct and operate 10 megawatts (MW) of diesel-fired electricity generation, to support the development of a new mine at Detour Lake. Detour Gold provided a detailed description of the problem/opportunity that prompted the project. The EA adequately described the purpose of the undertaking

26 EA Decision Making Process Alternatives Evaluation EAA and ToR Description and Characteristics Requirements of the Requirements Analysis of the EA Alternatives to represent functionally different ways of addressing the problem or opportunity. Description and Statement of the Rationale for the Alternatives to: Alternative to s.6.1(2)(b)(iii) Description and Statement of the Rationale for the Alternatives methods: Alternative Methods s.6.1(2)(b)(ii) Description of the Environment s.6.1(2)(c)(i) A reasonable range of alternatives to should be identified and evaluated. The proponent should be able to justify that it has considered a reasonable range of alternatives. The do nothing alternative to should be included in the evaluation and will represent the bench mark situation. Alternative methods include a description of different ways of implementing the preferred alternative to A reasonable range of alternative methods should be identified and outlined. Proponents must consider the broad definition of the environment including the natural, biophysical, social, economic, built and cultural conditions. The EA must provide a description of the existing environmental conditions in the study area. The EA must identify those elements of The EA focused on onsite diesel-fired generation as a contingency power supply. The do nothing alternative was brought forward for consideration in the EA to demonstrate the relative advantages and disadvantages of the proposed undertaking. Aside from the do nothing alternative, other alternatives to onsite diesel generation were not considered as part of the EA. Detour Gold provided detailed rationale, based on work done prior to the submission of the approved ToR for focusing on one alternative to the undertaking. Previous planning work screened out other alternatives to the undertaking due to greater costs, environmental impacts, comparatively lower capacity, infrastructure availability, reliability or technical feasibility. Section 7.0 of the EA provides a description and rationale for the alternative methods that were considered. The ministry is satisfied that the EA clearly explains how Detour Gold identified and evaluated the proposed alternative methods of carrying out the undertaking. Two study areas were identified for the undertaking: A Local Study Area to assess the natural and biophysical components. A Regional Study Area to assess the human environment components. Section 6.0 of the EA provided a detailed description of the existing environment within the - 2 -

27 EA Decision Making Process EAA and ToR Description and Characteristics Requirements of the Requirements Analysis of the EA the environment that may be reasonably expected to be affected, either directly or indirectly, by the proposed undertaking and/or the alternatives. Description of Potential Environmental Effects s.6.1(2)(c)(ii) Both positive and negative environmental effects should be discussed. The EA must identify methods and studies used to analyze the potential environmental effects. The methods used are contingent on the type of project. Impact assessment methods and criteria used during the evaluation should be identified. study area to establish baseline conditions and evaluate potential environmental effects. Detour Gold considered a broad definition of the environment including natural, social, cultural and economic environment. The EA identified those elements o the environment that may be reasonably expected to be affected by the proposed undertaking. Potential environmental effects are evaluated in detail in section 8.0 of the EA. The methods used to analyze the potential environmental effects of the proposed undertaking, including assessment criteria, were identified in the EA. The ministry is satisfied that the method to identify potential environmental effects was clear, traceable and replicable. The methods chosen must be clear, traceable and replicable so that interested parties can understand the analysis and logic used throughout the EA. Description of the Actions Necessary to Prevent, Change, Mitigate or Remedy the Environmental Effects s.6.1(2)(c)(iii) A description of future commitments, studies and a work plan may be included as part of the actions necessary to prevent, change, mitigate or remedy environmental effects for each alternative for the ultimate purpose of comparing them. The potential environmental effects and mitigation measures for the preferred undertaking have been considered in the evaluation of alternatives. Detour Gold has committed to a number of mitigation measures to avoid or minimize potential environmental impacts and has identified a monitoring plan to ensure all regulatory requirements are met

28 EA Decision Making Process EAA and ToR Description and Characteristics Requirements of the Requirements Analysis of the EA The preferred alternative should be identified through this evaluation. Evaluation of Advantages and Disadvantages to the Environment s.6.1(2)(d) Description of Consultation with Interested Stakeholders s.6.1(2)(e) A description of stakeholder consultation that occurred during the preparation of the EA needs be documented and should include consultation methods used, frequency of consultation, dates that events occurred, target audience, descriptions of key milestones for which stakeholders are providing input, comments received. The EA must identify any Aboriginal consultation efforts that have been made including methods for identifying potentially interested First Nations, who was consulted, when and how consultation occurred and any comments received from First Nations. The EA should include outline conflict resolution techniques to resolve issues used by the proponent to resolve outstanding issues with any stakeholders. Advantages and disadvantage to the environment are evaluated in the EA. The EA identifies the general advantages and disadvantages of the proposed undertaking in comparison to the do nothing alternative in section 7.3. The advantages and disadvantages of the proposed alternative methods were assessed during the selection of the preferred alternative. The EA outlines a clear, traceable and reproducible decision-making process. Section 9.0 of the EA provides a summary of the stakeholder consultation that occurred during the preparation of the EA and Appendix F provides a detailed record of the consultation activities that took place during the development of the ToR and EA. Public consultation included public information sessions, newspaper notices and advertisements, public mailings, and a project web site. Detour Gold identified the Moose Cree First Nation, the Taykwa Tagamou Nation, the Wahgoshig First Nation and the Métis Nation of Ontario as the primary interested communities in the area. Detour Gold has been supporting these Aboriginal groups through correspondence, community meetings and agreements put in place to document and determine potential effects of the proposed undertaking on traditional uses. A draft EA was disturbed to these Aboriginal communities so that interests and concerns could be identified - 4 -