Todd Goodsell, Senior Permitting Specialist

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1 MEMORANDUM T: Nicla Bantn, EA/Permitting Mgr. Date: 26 January 2017 Frm: Subject: Tdd Gdsell, Senir Permitting Specialist Blast Timing Cnstraints Intrductin This mem has been prepared in respnse t the BC EAO request fr further clarificatin n a preliminary blast schedule that reflects the mst current understanding f the timing and frequency f blasts in light f the prpsed mitigatins in the Applicatin/EIS, the revised fisheries and fish habitat ffsetting plan and ther respnses t technical reviewers and stakehlders that make cmmitments t blast timing cnstraints. EAO Cmment/Request The draft respnse t the Kamlps Fly Fishers Assciatin references a cmmitment t restrict blasting frm 10:00 a.m. 2:00 p.m. during the fishing seasn (while blasting in in the western prtin f the pen pit) t accmmdate prime fishing perids due t invertebrate hatch timing. The Applicatin/EIS includes the fllwing references t a nn blasting schedule as fllws (emphasis added): Pg : Blasting nise is expected t ccur n average nce per day, arund nn. Since amphibians are ncturnal and mst species are expected t resume their pre-stimulus calling rates nce the sund has diminished (Sun and Narins 2005) n effect is anticipated frm blasting nise disturbance n amphibians. Pg : Since blasting is currently scheduled t ccur nce a day at nn and breeding bird s activity is typically highest in the mrning fr the first few hurs after sunrise, this effect is nt anticipated t ccur. Pg : Research indicates that blasting nise frm a single event can lead t hearing lss in birds if it exceed 140 db SPL (125 db fr multiple blasts; Dling and Ppper 2007). Prject blasting is expected t ccur nce a day arund nn. At this level and frequency nise disturbance will nt have a residual effect n migratry birds. KGHM Ajax Mining Inc. 124 Seymur St Kamlps, BC V2C 2E1 Canada T

2 The EAO requests a rugh daily schedule by mnth (r seasnally such as ff-ice/n-ice) fr Years 1, 2, 4 and 8 (thse years with the greatest ptential blast effects) culd be prvided s that EAO can better evaluate the ptential fr blast effects. In additin the EAO has requested hw the varius assessments and cnclusins that relied n a nn blasting factr need t be updated t reflect the prpsed changes in the blast schedule that are intended t reduce effects n recreatinal fishing. KAM Respnse The respnse t the Kamlps Fly Fishers Assciatin and reference t the blast timing cnstraint echs the cmmitment made in the revised Fisheries and Fish Offsetting Plan. Specifically in Sectin f the ffsetting plan entitled Blast Scheduling, a new cmmitment is prpsed after cnsideratin f cmments related t blast scheduling and access restrictins received during the Applicatin/EIS review prcess related t the effects f blasting n recreatinal fishing in Jack Lake. In respnse t a cmment frm fisheries bilgists at the Ministry f Frest Lands and Natural Resurce Operatins that many anglers are ften n Jack Lake between 10:00 a.m. and 2:00 p.m., KAM has cmmitted t nt blasting during this time t minimize effects n the recreatinal fishery. This cmmitment is cnditinal and effective nly: frm April 1 t Octber 31 (when Jack Lake is pen fr fishing), and when the blast clearance radius extends int Jack Lake requiring clearing f the lake. In general, the ptential fr the blast clearance radius t extend int Jack Lake is mre likely during earlier years in the mine life (e.g., represented by years 1, 2, and 4/8). Hwever, any f the blast timing windws and their assciated mitigatin measures described belw culd freseeably ccur in any year f the mine life. We appreciate the EAO pinting ut this ptential incnsistency between this new cmmitment frm the revised Fisheries and Fish Offsetting Plan and thse previusly made in the Applicatin/EIS. Belw are revised prpsed blast timing cnstraints that take int accunt these cmmitments. 2

3 Blast Schedule Timing Windws and Cnstraints In light f the new cmmitment described abve, KAM prpses the fllwing blast timing windws: April 1 st thrugh July 31 st / when the blasting safety radius extends int Jack Lake: Blasting may ccur frm 4 hurs after sunrise t 10:00 AM and frm 2:00 PM t sunset. The blasting restrictin frm sunrise t 4 hurs after sunrise is t mitigate effects t migratry birds and nn-migratry gamebirds during the breeding seasn (May 1 st t July 31 st ) and sensitive perids (April 1 st t May 30 th ) respectively. April 1 st thrugh July 31 st / when the blasting safety radius des nt extend int Jack Lake: Blasting may ccur during the windw f 4 hurs after sunrise t sunset. The blasting restrictin frm sunrise t 4 hurs after sunrise is t mitigate effects t migratry birds and nn-migratry gamebirds during the breeding seasn (May 1 st t July 31 st ) and sensitive perids (April 1 st t May 30 th ) respectively. August 1 st thrugh Octber 31 st / when the blasting safety radius extends int Jack Lake: Blasting may ccur frm sunrise t 10:00 AM and frm 2:00 PM t sunset. The blasting restrictin frm 10:00 AM and frm 2:00 PM is t mitigate effects t recreatinal fishing by allwing access t the eastern areas f Jack Lake during chirnmid hatches that ccur mid-day. August 1 st thrugh Octber 31 st / when the blasting safety radius des nt extend int Jack Lake: Blasting may ccur frm sunrise t sunset. Nvember 1 st t March 30 th : Blasting may ccur frm sunrise t sunset. In all cases, blasting will be cnstrained/restricted if a temperature inversin, lw clud, r strng winds exist. The table belw indicates times f the day by mnth when blasting will be restricted due t sensitivity windws. Please nte: The table prvides apprximate restrictin timing by mnth that is based n sunrise and sunset. While the table indicates that blasting may ccur at any time utside f range perids, KAM recgnizes the need t set reasnably cnsistent blast times fr each mnth fr peratinal purpses and t mitigate disturbance and annyance effects. Cnsistent blast time windws will be set fr peratinal needs likely t cincide with emplyee shift scheduling, shift changes and cmmn break times. 3

4 Nte: as further utlined belw, references in the Applicatin/EIS t blasting at, r near, nn, were nt intended t be a specific cnstraint. They were intended t reflect the pint abve regarding establishing a cnsistent blast time, and the timing was cnsistent with a simplifying assumptin built int the air and nise mdels. Revised language that prvides mre clarity is utlined belw. Blast timing cmmitments Revised The abve blast timing cnstraints require minr revisins t cmmitments currently stated in the Applicatin/EIS: 6.12 Amphibians and 6.14 Migratry Birds Current cmmitment: Blasting nise is expected t ccur n average nce per day, arund nn Revised cmmitment: Blasting nise is expected t ccur n average nce per day. Ratinale: prpsed change t delete the expectatin t blast arund nn due t the cmmitment t nt blast frm 10:00 2:00 t mitigate effects t recreatinal fishing. This change is in keeping with mitigatin bjective f minimizing lud, cntinuus nise at dawn, dusk and vernight during breeding seasn and will nt result in adverse effects t amphibians r migratry birds nt cnsidered in the Applicatin/EIS Nn-Migratry Birds Current cmmitment: N blasting between sunrise and 10:00 (pg ); Revised cmmitment: N blasting until 4 hurs after sunrise during sensitive perids. Ratinale: prpsed change t be cnsistent with cmmitment made fr migratry birds. RIC (1997) 1 indicates that calling by males is mst intense just prir t and after sunrise. Peak hurs fr sharp-tailed gruse are half an hur befre sunrise and 2 hurs after. This change is in keeping with mitigatin bjective f minimizing lud, cntinuus nise at dawn, dusk and vernight during breeding seasn and will nt result in adverse effects t migratry birds nt cnsidered in the Applicatin/EIS. 1 Resurces Inventry Cmmittee (RIC) Inventry Methds fr Upland Gamebirds. Versin 1.1. Standards fr Cmpnents f British Clumbia s Bidiversity N. 17. Victria, BC: BC Ministry f Envirnment, Lands and Parks, Resurces Inventry Branch. Retrieved frm 4

5 8.5 Current Use f Land and Resurces fr Traditinal Purpses Current cmmitment: General mitigatin fr with respect t nise includes ensuring impulse events, such as blasting, will be limited t certain times f the day (utside f the sunrise t 1000 windw); cnsidering nise ratings when selecting equipment; adjusting blasting cnfiguratins t minimise simultaneus blasting effects; ptimizing the peratin f equipment t minimize nise (e.g., reduced speed limits); ptimizing the site layut t minimize nise impact (e.g., thrugh use f natural screens such as buildings, facing away frm relevant receptrs, minimizing the need fr mbile equipment t use their backup alarms); and nise dampening measures will be applied where pssible, including cnducting lud prcedures indrs, where practical. Revised cmmitment: General mitigatin fr with respect t nise includes ensuring impulse events, such as blasting, will be limited t certain times f the day (blasting will nt ccur during the seasnal Spring Trut Fishery frm sunrise t 10:00 AM if Abriginal fishers are present. The seasnal Spring Trut Fishery ccurs each spring when the Jack Lake / Petersn Creek spillway verflws releasing mature rainbw trut int the creek frm Jack Lake. Typically the spillway flws during several weeks ver the mnths f May and June each year depending n precipitatin); cnsidering nise ratings when selecting equipment; adjusting blasting cnfiguratins t minimise simultaneus blasting effects; ptimizing the peratin f equipment t minimize nise (e.g., reduced speed limits); ptimizing the site layut t minimize nise impact (e.g., thrugh use f natural screens such as buildings, facing away frm relevant receptrs, minimizing the need fr mbile equipment t use their backup alarms); and nise dampening measures will be applied where pssible, including cnducting lud prcedures indrs, where practical. Ratinale: the prpsed change remains cnsistent with the intent f the cmmitment t mitigate nise and vibratin effects t Abriginal fishers n Petersn Creek during the asserted Spring Trut Fishery at the spillway f the Jack Lake dam. 5

6 Table: Blast Timing Restrictins 23 Mnth 05:00 06:00 07:00 08:00 09:00 10:00 11:00 12:00 13:00 14:00 15:00 16:00 17:00 18:00 19:00 20:00 21:00 22:00 Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nv Dec 2 Shading indicates when blasting may nt ccur based n cmmitments made in Applicatin/EIS and prvide apprximate times based n sunrise and sunset 3 The table takes int accunt the fllwing cmmitments frm the Applicatin/EIS: Sectin 6.12 Amphibians: N blasting at night (pg ) - during spring, summer and fall; Blasting nise is expected t ccur n average nce per day, arund nn (pg ); Minimizing lud, cntinuus nise at dawn, dusk and vernight during breeding seasn (pg ); Amphibians Sensitive Perid April t September (Appendix in 0720_KAM_Mitigatin Hierarchy and Offsetting mem) Sectin 6.14 Migratry Birds: Prject blasting is expected t ccur nce a day arund nn, limited t nce per day and des nt ccur frm sunrise t 4 hurs after sunrise during breeding seasn - May t August (pg ); Ensure blasting events d nt ccur during the sensitive time perid (sunrise t 4 hurs after sunrise) during breeding perid (pg ); Migratry Birds Sensitive Perid April 1 t August 15 (Appendix in 0720_KAM_Mitigatin Hierarchy and Offsetting mem) Sectin 6.15 Raptrs: Blasting t ccur at specific times f the day and blasting events t be limited t the fewest pssible ccurrences during sensitive bird breeding perids (February thrugh June) (pg ); t ccur nly nce per day (pg ); Raptrs Sensitive Perid February 1 t August 15 (Appendix in 0720_KAM_Mitigatin Hierarchy and Offsetting mem) Sectin 6.16 Nn-migratry game birds: N blasting between sunrise and 10:00 (pg ); Migratry Game Birds Sensitive Perid April 1 t May 31 (Appendix in 0720_KAM_Mitigatin Hierarchy and Offsetting mem) Sectin 6.17 Mammals: Badgers and bats - n blasting during dawn r dusk (pg ); blasting t ccur nce per day (pg ); Ensuring impulse events, such as blasting, will be limited t certain times f the day (aviding crepuscular (sunrise and sunset) and vernight wrk, during spring, summer, and fall (nn-trpr seasn), if pssible) (pg ); Badgers Sensitive Perid April 1 t August 15 (Appendix in 0720_KAM_Mitigatin Hierarchy and Offsetting mem); Bats Sensitive Perid May 15 t September 30 and Octber 1 t May 31 (Appendix in 0720_KAM_Mitigatin Hierarchy and Offsetting mem) 8.5 CULRTP: Once per day arund 12:00 PM (pg , 105, 120, 126); aviding sunrise t 10:00 (pg , 92, 95). This cnstraint is nly in place when harvestable species f interest are present and wuld avid the area during blasts

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