BACK RIVER PROJECT. Responses to Clarification Requests Yellowknives Dene First Nation. July The

Transcription

1 The BACK RIVER PROJECT Responses to Clarification Requests Yellowknives Dene irst Nation Submitted to: Nunavut Impact Review Board PO Box 1360 Cambridge Bay, NU 0B 0C0 Prepared by:

2 This package includes Sabina old & Silver Corp. s responses to the following Yellowknives Dene irst Nation YKDN) clarification requests on the Draft Environmental Impact Statement DEIS) for the Back River Project that were not included in the Information Request responses. Information Request responses are submitted under a separate cover. Large files and reports are included in the Clarifications Appendix package. YKDN-2-1 YKDN-2-5 YKDN-4-3 YKDN-4-5 SABINA OLD & SILVER CORP. i

3 Interested Party: YKDN IR No.: 2-1 Subject: ildlife Mitigation and Monitoring Plan Reference to DEIS: MMP Issue/Justification: Construction of infrastructure will avoid, where possible, wildlife sensitive areas Information Request: Please provide a map that illustrates sensitive wildlife areas in the PDA. Sabina Response: The requested information can be found in igures YKDN-2-1a, YKDN-2-1b, and YKDN-2-1c: Locations of ildlife eatures, which are provided below. These maps indicate the locations of wildlife features, such as dens, nests, staging areas and areas identified from TK. Attachment: N/A SABINA OLD & SILVER CORP. 1

4 IS BAC a April Kilogiktok Bathurst Inlet Southern Arm) ± Ekalokhiokvik 1:150,000 UTM Zone13 UTM Zone oose eorge a ck H n an Hanningayuk Beechey Lake) ig a oose yok er) R iv B eorge Tikigak 1:150,000 UTM Zone13 UTM Zone12 r) Tahikafalok Nahik Propeller Lake) ve Ri 1:3,500,000 Nunav ut Northw est Te rritorie s rn oose TCR inter Road Connector te es Tibbitt to Contwoyto inter Road eorge k kto kgi Kilogiktok Bathurst Inlet, Southern Arm) K ilo BIPR inter Road Connector Marine Laydown Tahikafalok Bathurst Lake) Marine Laydown Main Map 1:135,000 Cliff-nesting Raptor Nest olf Den TCR inter Road Connector Caribou Crossing olverine Den aterbird Staging Regional Study RSA) inter Road all ater/ice Crossing Spring Traditional Knowledge Caribou Crossing Source: KRLUP, 2005 Summer ederal atershed Delineation Bathurst Inlet - Burnside River Upper Back River inter Road, eorge Tie-In Option 2 Queen Maud ulf - Ellice River Hand digitized, area approximate BIPR inter Road Connector Inferred from Inuit TK KIA 2012) Local Study LSA) Projection: NAD 1983 UTM Zone 13N Potential Development PDA) inter Road, eorge Tie-In Option Caribou Crossing Existing Exploration Camp Marine Laydown Kingaok. Bathurst Inlet) Kiligiktokmik Bathurst Inlet) Marine Laydown PROJECT Haul and Access Road Proposed Infrastructure 0 1:600, Department of Natural Resources, Canada. All rights reserved. Kilometres igure YKDN 2-1a igure YKDN 2-1a ildlife Sensitive s within the Terrestrial Regional Study

5 PROJECT IS BAC b April alrus Island Kingaok Bathurst Inlet) ollaston Point Main Map Omingmaktok Bay Chimo). Marine Laydown Kiligiktokmik Iglorua Bathurst Inlet) Island BIPR inter Road Connector Kilogiktok Bathurst Inlet, Southern Arm) Tibbitt to Contwoyto inter Road eorge UTM Zone13 UTM Zone12 Ekalulia Island oose TCR inter Road Connector Barry Islands Nunav ut Northw est Te rritorie s 1:4,500,000 Brown Sound Omingmaktok Bay Chimo) Kiligiktokmik Bathurst Inlet) ± Kanuyak Island Marine Laydown Kilogiktok Bathurst Inlet, Southern Arm) UTM Zone UTM Zone 13 Banks Peninsula 1:150,000 rn Bu side kpakt ik ov a ap Ay R iv e r) Kingaok Bathurst Inlet). Kilogiktok Bathurst Inlet, Southern Arm) Potential Ringed Seal Lair aterbird Staging all Summer Marine Laydown Ekalokhiokvik Caribou Crossing ater/ice Crossing Source: KRLUP, 2005 Local Study LSA) Regional Study RSA). Community/Settlement Marine Laydown inter Road Potential Development PDA) Proposed Shipping Lane ederal atershed Delineation Bathurst Inlet - Burnside River Tahikafalok Bathurst Lake) Department of Natural Resources, Canada. All rights reserved Queen Maud ulf - Ellice River 0 1:520, to k r ) gik Rive ok K il tern es Upper Back River 20 Kilometres Projection: NAD 1983 UTM Zone 13N igure YKDN 2-1b igure YKDN 2-1b ildlife Sensitive s within the Marine Regional Study

6 PROJECT IS BAC c April 30, '0" 112 0'0" 110 0'0" 108 0'0" 106 0'0" 104 0'0" 102 0'0" 68 0'0"N. Kugluktuk Coronation ulf Omingmaktok Bay Chimo) Kiligiktokmik Bathurst Inlet). Traditional Knowledge Caribou Calving Inferred from Inuit TK KIA 2012) Traditional Calving rounds Source: unn et al., '0"N 67 0'0"N Caribou ixed Kernel Utilization Distribution Calving 50% 95% Bathurst Herd Kingaok Bathurst Inlet). Ahiak Herd Local Study LSA) Regional Study RSA) Marine Laydown 66 0'0"N. Community/Settlement Existing Exploration Camp Marine Laydown Tibbitt to Contwoyto inter Road TCR inter Road Connector inter Road inter Road, eorge Tie-In Option 1 inter Road, eorge Tie-In Option 2 Napaktolik Lake Tahikafalok Bathurst Lake) eorge Tikigak 66 0'0"N BIPR inter Road Connector Haul and Access Road 65 0'0"N Proposed Infrastructure Potential Development PDA) 1:1,500, Kilometres Hand Digitized, Approximate Source of data: NT, ENR ) Source of data: NT, ENR ) Projection: NAD 1983 Statistics Canada Lambert 114 0'0" 112 0'0" Nunavut Northwest Territories Contwoyto Lake 110 0'0" Nose Lake 108 0'0" k Hannigayo Back River) Hanningayuk Beechy Lake) oose 106 0'0" 104 0'0" 65 0'0"N igure YKDN 2-1c Traditional and Current Calving s within the Terrestrial Study

7 Interested Party: YKDN IR No.: 2-5 Subject: Connector to the Tibbitt to Contwoyto inter Road Reference to DEIS: eneral EIS, Section Issue/Justification: The document introduces the potential connector to the Tibbitt to Contwoyto winter road with very little assessment other than as a general inclusion within the winter roads. However, unlike the winter roads that will connect to the Marine Laydown the orientation and location of the TCR connect will potentially have different effects on the caribou herd. The evaluation of this approach is deficient. The number of loads being conveyed through this route is unknown as it the proposed frequency, further complicating any analysis of the barrier effects. The EIS does not present the early work done at Ekati which suggests that the caribou were reluctant to cross the Misery Road more than half the time. Information Request: Please assess the potential likelihood of interactions between caribou migrating north and the operational window of this road. In particular, please assess the potential impacts on movement of the herd, including during the migration. Sabina Response: The truck freight option via Yellowknife was proposed as an alternative mobilization route; however, it was not selected due to the considerations outlined in the Transportation Study in Appendix V2-4A. Since it was not selected, the Tibbitt to Contwoyto inter Road is not considered a project component at this time. Consequently, details are not provided. Should it become a viable option and be reintroduced to the Project, an effects assessment and all requisite engineering information will be provided. Although it is stated in the Transportation Study, Sabina acknowledges that the main body of DEIS does not make it clear that this option was not selected. This will be clarified in the EIS. Attachment: N/A SABINA OLD & SILVER CORP. 1

8 Interested Party: YKDN IR No.: 4-3 Subject: Caribou Mitigations Reference to DEIS: s Summary of Mitigations Issue/Justification: Table notes that the infrastructure has been designed to minimize the project footprint to reduce habitat loss. However, the project footprint appears to be very large relative to other operations currently operating and in the past suggesting that perhaps the mitigation design is not provide the value that is being suggested. Information Request: Please provide a figure that shows the relative sizes of this project with others used in the cumulative effects analysis as well as Tyhee, ortune and Avalon s mine proposals. Secondly, please provide examples of where the project made choices to conserve caribou habitat rather than functionality or cost. or these examples, please show how the value of the habitat was accounted for within the trade off analyses. Sabina Response: igures 5.6-3, 5.6-4, and show the relative sizes and disturbance profiles for each Project located within the CEA boundaries for caribou. The proposed Tyhee, ortune and Avalon projects, while not included on these maps, fall outside to the southwest) of the CEA boundaries for both Bathurst and Beverly herd caribou. or the Back River Project, the Project engineering was not complete at the time of DEIS submission, thus PDAs were used to evaluate habitat loss for the EA. These PDAs greatly overestimate the actual amount of expected habitat loss as only 10-15% of these PDAs are anticipated to be cleared for infrastructure etc. Section , p. 5-88). Therefore, these actual areas of loss are expected to be small relative to other current developments such as the Ekati Diamond Mine). Attachment: N/A SABINA OLD & SILVER CORP. 1

9 Interested Party: YKDN IR No.: 4-5 Subject: Caribou Impacts Reference to DEIS: s Reductions in Reproductive Productivity p5-144) Issue/Justification: Thus effects on fecundity from behavioural disturbances due to interaction between female caribou and the project are predicted to be lower than predicted effects from insect harassment. Yellowknives Dene harvesters have had their subsistence economy damaged and constitutional rights infringed upon due to declining caribou populations. At the same time, mineral development continues to be advanced. The predictions that impacts from this project will be less than that of insects is moot. These effects contribute to stress on the caribou population. This impact prediction ignores the real world impacts upon the people who depend on caribou. Elders of the YKDN believe that the caribou have already been affected by significant effects, particularly to migration routes and movement. These effects are not considered within the analyses conducted by the project. Information Request: Please provide a discussion that considers how additional developments) may prolong the recovery of the Bathurst Caribou herd and the impacts to Dene harvesters that are already sacrificing their connections to caribou due to population decline. Sabina Response: 1. Habitat Loss, Disturbance, and Reduction in Reproductive Productivity were identified as residual effects with a significance rating of "Not Significant" in the Effects Assessment. Effects on migration routes and disruption to movement were considered in Section p ), and no residual effect was anticipated. Thus the potential effects of Disruption to Movement were not considered further. 2. The CEA included an assessment boundary based on caribou ranges when the herd could occur within the Project area e.g. post-calving and summer range for Bathurst caribou). a. Methods for assessing Habitat Loss due to additional developments is provided in Section p ) and include the total area removed by all projects compared to the CEA boundary area, the area likely degraded by dust altered) surrounding each additional project and an estimate of these areas that are high-use habitat by caribou, based on a resource selection function for Bathurst herd caribou. Characterization of the results of the assessment are presented in Section p ) and indicate that combined habitat loss is 0.3% or less of the total CEA boundaries for caribou, thus considered "Not Significant". b. Methods for assessing Disturbance due to additional developments is provided in Section p ) for worst case construction scenarios) and normal case operation scenario) and include: area of modelled disturbance due to each Project based on typical disturbance distances reported in the literature), and an estimate of the area of high use habitat calculated from a resource selection function for Bathurst caribou). These are compared to the amount of habitat and high-use areas available within the CEA boundary. Characterization of the results of this assessment are presented in Section p ) and indicate that combined disturbed habitat is less than 5% of the CEA boundaries for caribou, thus residual effects were considered "Not significant" c. Methods for assessing reduction in reproductive productivity are presented in Section p ). Analysis of encounter rates with disturbance zones by collared caribou were assessed and indicated that individual caribou would encounter disturbance zones fewer than 19 times per year p ) resulting in <3% reduction to fecundity. This is anticipated to be within the SABINA OLD & SILVER CORP. 1

10 natural range of variability for fecundity. In addition, analysis of the total area lost, altered and disturbed within the CEA boundary and the proportion of high use areas that are lost, altered or disturbed due to all Projects were calculated resulting in <6.5% of post-calving and summer range Bathurst Caribou). The residual effects were thus considered "Not Significant". 3. No significant effects were predicted for any effect due to the Project alone, or as a result of cumulative effects with other Projects on the post-calving and summer ranges for Bathurst Caribou, thus no impacts to the Dene harvesters are anticipated as a result of the Back River Project development. Attachment: N/A 2 RESCAN ENVIRONMENTAL SERVICES LTD., AN ERM COMPANY PROJ REV D.1 JULY 2014