Canadian Environmental Agence canadienne Assessment Agency d’évaluation environnementale

Kitsault Mine Project Comprehensive Study Report

August 2013 Cover photo credited to Avanti Staff.

© Her Majesty the Queen in Right of Canada (2013).

This publication may be reproduced for personal use without permission, provided the source is fully acknowledged. However, multiple copy reproduction of this publication in whole or in part for purposes of distribution requires the prior written permission of the Minister of Public Works and Government Services Canada, Ottawa, Ontario. To request permission, contact [email protected].

Catalogue No.: En106-120/2013E-PDF

ISBN: 978-1-100-22586-9

This document has been issued in French under the title Rapport d'étude approfondie – Projet minier Kitsault

Alternative formats may be requested by contacting [email protected] Executive Summary The Canadian Environmental Assessment Agency (the Agency) prepared this comprehensive Avanti Kitsault Mine Ltd. proposes to study report in consultation with Fisheries and construct, operate and decommision an open pit Oceans Canada and Natural Resources Canada molybdenum mine with a production capacity of following a technical review of the proponent’s approximately 40 000 to 50 000 tonnes (t) per day. Environmental Impact Statement and an The proposed Kitsault Mine project (the Project) evaluation of the potential environmental effects will be located 140 kilometres (km) north of Prince of the Project. Environment Canada, Health Rupert, British Columbia, within the Nass Area Canada and Aboriginal Affairs and Northern and Nass Wildlife Area defined by the Nisga’a Development Canada provided additional Final Agreement. The Project consists of an expert advice. open pit, an ore processing plant, ancillary mine infrastructure, tailings and waste rock management Valued components (VCs) are notable features facilities, buildings, explosives manufacturing of the natural and human environment that have facility and storage magazines, water management the potential to be impacted by the Project. This facilities and a power substation. The Project report presents the assessment of the Project’s involves redeveloping a previous mine which last effects on the following key VCs: surface water operated in 1982. and sediment quality, hydrology, groundwater, fish and fish habitat, marine aquatic resources, An environmental assessment (EA) of the Project wildlife and wildlife habitat, vegetation and plant under the former Canadian Environmental communities, and land and resource use. Assessment Act (the former Act) is required because Fisheries and Oceans Canada The Agency assessed the potential for the and Natural Resources Canada may take Project to have significant adverse effects on regulatory decisions in relation to the Project. the environment. In addition, the environmental A comprehensive study EA is required under effects on the Nisga’a Nation and the effects of the Comprehensive Study List Regulations. The the Project on the existing and future economic, Project is considered a major resource project social and cultural well-being of Nisga’a citizens under the Cabinet Directive on Improving the as set out in the NFA were assessed as part Performance of the Regulatory System for of the EA. These evaluations were completed Major Resource Projects. based on technical information provided by the proponent, advice from federal, provincial and A provincial EA was conducted under British Nisga’a Lisims Government (NLG) experts, and Columbia’s Environmental Assessment Act comments provided by Aboriginal groups and with federal and provincial agencies working public stakeholders through various consultation cooperatively to coordinate activities as guided opportunities. by the principles of the Canada-British Columbia Agreement for Environmental Assessment Potential environmental, economic, social and Cooperation (2004). The Project is also subject cultural effects and concerns examined during to the EA requirements of the Nisga’a Final the comprehensive study process include: Agreement (NFA), a constitutionally-protected treaty, as the mine footprint will be situated ••changes to surface water and sediment quality in the Nass Wildlife Area and Nass Area of ••management of mine wastes to prevent metal British Columbia and portions of the proposed leaching and acid rock drainage transportation corridors overlap Nisga’a Lands. ••protection of fish and fish habitat ••effects on the marine environment

CEAA—Comprehensive Study Report: Kitsault Mine Project III ••attainment of employment and training for Project is not likely to cause significant adverse Nisga’a citizens environmental effects. ••social effects related to limited housing supply in Nisga’a Villages and increased income With respect to potential effects on residents of Nisga’a Lands, Nisga’a Lands or Nisga’a Issues identified as a result of public and Aboriginal interests, the Agency identified potential adverse consultations include the protection of moose but not significant environmental effects on and surface water quality, site reclamation and Nisga’a Nation treaty interests in relation to the need for ongoing monitoring and fisheries, wildlife and migratory birds and forest environmental management. resources. The Project is also likely to affect the social and cultural well-being of Nisga’a citizens Mitigation measures to prevent or reduce the as the potential inflow of people and income adverse effects of the Project were incorporated to Nisga’a communities may place additional into the project planning and design. These demand on the existing housing supply and may measures include: reduce Nisga’a opportunities to pursue cultural activities. A modest benefit may occur to the ••treatment of mine contact water prior to economic well-being of Nisga’a citizens due discharge into the receiving environment to employment and contracting opportunities ••subaqueous disposal of potentially acid associated with the Project. generating tailings and low grade ore ••discharge of mine water in a manner that Following public consultation on this Report, mimics natural stream flow the Minister of the Environment will decide ••fish habitat compensation plan whether, taking into account the implementation of mitigation measures, the Project is likely to Management plans to address economic, cause significant adverse environmental effects. social and cultural effects on the Nisga’a At the same time, the Minister will issue an NFA Nation include: Project Recommendation. The Project will then be referred back to the responsible authorities for ••educational support, skills training and the appropriate course of action in accordance closure transition support with Section 37 of the former Act. ••programs and policies based on the results of a cultural and social needs assessment

A follow-up program is required under the former Act to verify the accuracy of the EA and to determine the effectiveness of the proposed mitigation measures. The follow-up program will focus on confirming predictions of effects for the following elements:

••water management ••wildlife and wildlife habitat ••wetlands and species-at-risk

The Agency concludes that with the implementation of mitigation measures, the

IV CEAA—Comprehensive Study Report: Kitsault Mine Project Table of Contents Executive Summary...... iii List of Figures...... ix List of Tables...... ix List of Acronyms and Short Forms...... x 1 Introduction...... 1 1.1 Project Overview...... 1 1.2 Environmental Assessment Context and Process...... 1 1.2.1 Purpose of the Comprehensive Study Report...... 1 1.2.2 Federal Environmental Assessment Process...... 2 1.2.3 Cooperative EA Process...... 2 1.2.4 Nisga’a Final Agreement...... 3 2 Project Description and Assessment of Alternatives...... 4 2.1 Need for and Purpose of the Project...... 4 2.2 Project Components...... 4 2.2.1 Project Activities and Schedule...... 7 2.3 Assessment of Alternatives...... 7 2.3.1 Alternatives to the Project...... 7 2.3.2 Alternative Means of Carrying Out the Project...... 8 3 Scope of the Environmental Assessment...... 9 3.1 Factors to be Considered...... 9 3.2 Scope of the Project...... 9 3.3 Scope of Assessment...... 9 3.4 Temporal and Spatial Boundaries...... 11 3.5 Information Distribution...... 13 3.5.1 Technical Working Group...... 13 4 Environmental Effects Assessment...... 14 4.1 Assessment Methodology...... 14 4.2 Surface Water and Sediment Quality...... 15 4.2.1 Description of Baseline Environment...... 15 4.2.2 Potential Environmental Effects...... 16 4.2.3 Mitigation Measures...... 19 4.2.4 Government, Aboriginal and Public Comments...... 22 4.2.5 Residual Effects...... 22 4.2.6 Agency Conclusions...... 23

CEAA—Comprehensive Study Report: Kitsault Mine Project V 4.3 Hydrology...... 23 4.3.1 Description of Baseline Environment...... 23 4.3.2 Potential Environmental Effects...... 24 4.3.3 Mitigation Measures...... 24 4.3.4 Government, Aboriginal and Public Comments...... 25 4.3.5 Residual Effects...... 25 4.3.6 Agency Conclusions...... 26 4.4 Groundwater...... 26 4.4.1 Description of Baseline Environment...... 26 4.4.2 Potential Environmental Effects...... 26 4.4.3 Mitigation Measures...... 27 4.4.4 Government, Aboriginal and Public Comments...... 28 4.4.5 Residual Effects...... 28 4.4.6 Agency Conclusions...... 29 4.5 Fish and Fish Habitat...... 29 4.5.1 Description of Baseline Environment...... 29 4.5.2 Potential Environmental Effects...... 30 4.5.3 Mitigation Measures...... 32 4.5.4 Government, Aboriginal and Public Comments...... 33 4.5.5 Residual Effects...... 33 4.5.6 Agency Conclusions...... 34 4.6 Marine Aquatic Resources...... 34 4.6.1 Description of Baseline Environment...... 34 4.6.2 Potential Environmental Effects...... 35 4.6.3 Mitigation Measures...... 35 4.6.4 Government, Aboriginal and Public Comments...... 35 4.6.5 Residual Effects...... 36 4.6.6 Agency Conclusions...... 36 4.7 Wildlife and Wildlife Habitat...... 36 4.7.1 Description of Baseline Environment...... 36 4.7.2 Potential Environmental Effects...... 37 4.7.3 Mitigation Measures...... 38 4.7.4 Government, Aboriginal and Public Comments...... 40 4.7.5 Residual Effects...... 40 4.7.6 Agency Conclusions...... 44 4.8 Vegetation and Plant Communities...... 44 4.8.1 Description of Baseline Environment...... 44 4.8.2 Potential Environmental Effects...... 45 4.8.3 Mitigation Measures...... 46 4.8.4 Government, Aboriginal and Public Comments...... 47 4.8.5 Residual Effects...... 47 4.8.6 Agency Conclusions...... 48

VI CEAA—Comprehensive Study Report: Kitsault Mine Project 4.9 Land and Resource Use...... 48 4.9.1 Description of Baseline Environment...... 48 4.9.2 Potential Environmental Effects...... 49 4.9.3 Mitigation Measures...... 50 4.9.4 Government, Aboriginal and Public Comments...... 51 4.9.5 Residual Effects...... 51 4.9.6 Agency Conclusions...... 52 4.10 Effects of Accidents and Malfunctions...... 52 4.10.1 Mitigation Measures...... 53 4.10.2 Government, Aboriginal and Public Comments...... 53 4.10.3 Agency Conclusions...... 53 4.11 Effects of the Environment on the Project...... 53 4.11.1 Agency Conclusions...... 54 4.12 Capacity of Renewable Resources...... 54 4.13 Cumulative Effects Assessment...... 54 4.13.1 Approach...... 54 4.13.2 Potential Cumulative Effects...... 55 4.13.3 Government, Aboriginal and Public Comments...... 57 4.13.4 Summary of Cumulative Environmental Effects...... 57 4.13.5 Agency Conclusions...... 59 5 Nisga’a Nation Effects Assessment...... 60 5.1 Assessment of Environmental Effects (8e of NFA Chapter 10)...... 60 5.1.1 Lands...... 60 5.1.2 Access...... 61 5.1.3 Water...... 62 5.1.4 Fisheries...... 63 5.1.5 Wildlife and Migratory Birds...... 66 5.1.6 Forest Resources...... 68 5.1.7 Cultural Artefacts and Heritage...... 69 5.1.8 Nisga'a Nation Comments...... 70 5.1.9 Agency Conclusions on 8e Assessment...... 70 5.2 Assessment of Economic, Social, and Cultural Effects (8f of the NFA Chapter 10)...70 5.2.1 Economic Well-being...... 72 5.2.2 Social Well-being...... 77 5.2.3 Cultural Well-being...... 83 5.2.4 Nisga’a Nation Comments...... 93 5.2.5 Agency Conclusions on 8f Assessment...... 93

CEAA—Comprehensive Study Report: Kitsault Mine Project VII 6 Treaty and Aboriginal Consultation...... 94 6.1 Nisga’a Nation Consultation Activities...... 94 6.2 Consultation Activities related to Potential Aboriginal Rights...... 95 6.2.1 Metlakatla First Nation...... 95 6.2.2 Gitanyow First Nation...... 95 6.2.3 Gitxsan Nation...... 95 6.2.4 Kitsumkalum First Nation...... 96 6.2.5 Kitselas First Nation...... 96 6.2.6 Métis Nation of British Columbia...... 96 6.3 Proponent Engagement...... 96 6.4 Summary of Key Issues...... 97 6.4.1 Nisga’a Nation...... 97 6.4.2 Metlakatla First Nation...... 98 6.4.3 Gitanyow First Nation and Gitanyow Huwilp Luuxhon...... 99 6.4.4 Gitxsan Nation...... 100 6.4.5 Kitsumkalum First Nation...... 100 6.4.6 Kitselas First Nation...... 100 6.4.7 Métis Nation of British Columbia...... 100 6.5 Mitigation and Accommodation...... 101 6.6 Agency Conclusions Regarding Impacts to Aboriginal Rights...... 101 7 Public Consultation...... 102 7.1 Public Comment Summary...... 102 8 Follow-up under the Canadian Environmental Assessment Act...... 103 8.1 Water Management...... 103 8.2 Fish and Fish Habitat...... 104 8.3 Wildlife and Wildlife Habitat...... 104 8.4 Wetlands and Species at Risk...... 104 8.5 Other Valued Ecosystem Components...... 104 9 Benefits to Canadians...... 105 10 Conclusions of the Agency...... 106 10.1 Canadian Environmental Assessment Act...... 106 10.2 Nisga’a Final Agreement...... 106

VIII CEAA—Comprehensive Study Report: Kitsault Mine Project 11. Appendix...... 108 Appendix A: Project Components and Activities...... 108 Appendix B: Alternatives for Carrying out the Project...... 113 Appendix C: Summary of Mitigation Measures...... 117 Appendix D: Environmental Effects from Accidents and Malfunctions and Summary of Prevention/Mitigation Measures...... 120 Appendix E: Summary of the Environmental Effects Assessment...... 124 Appendix F: Comparison of Predicted and Current Water Quality Against Water Quality Guidelines...... 135 Appendix G: Monthly Flows in Lower Lime Creek (LC1)...... 136 Appendix H: Summary of Public Comments...... 137 Appendix I: Aboriginal Consultation: Further information...... 138

List of Figures

Figure 1-1: Location of the Kitsault Mine Project...... 5 Figure 2-1: Project Components and Layout...... 6 Figure 4-1: Patsy Creek, Lime Creek, and Clary Creek Watersheds...... 18 Figure 4-2: Proposed Transportation Corridors from Highway 16 to the Mine Site...... 41 List of Tables

Table 1-1: Project Summary...... 1 Table 2-1: Project Activities and Schedule...... 7 Table 3-1: Key Valued Components Included in the Environmental Assessment...... 10 Table 3-2: Local and Regional Study Areas for Valued Components...... 12 Table 4-1: Definitions for Significance Rating...... 14 Table 4-2: Mitigation for Potentially Acid Generating Waste Rock and Tailings...... 19 Table 4-3: Management of Contact Water from Mine Infrastructure...... 21 Table 4-4: Fish Bearing Habitat Displaced by Project...... 30 Table 4-5: Wetland Classes in the Local Study Area...... 45 Table 4-6: Wetland Loss Associated with the Project...... 46 Table 4-7: Activities and Projects Included in the Cumulative Effects Assessment...... 55 Table 4-8: Cumulative Effects from Past, Present and Reasonably Foreseeable Projects and Activities...... 56 Table 5-1: Projects Considered in Regional Development Scenarios...... 72 Table 5-2: Frameworks for the Nisga’a Nation Economic, Social and Cultural Management Plans.....87

CEAA—Comprehensive Study Report: Kitsault Mine Project IX List of Acronyms and Short Forms

AANDC Aboriginal Affairs and Northern Development Canada AEMP Aquatic Effects Monitoring Program Agency Canadian Environmental Assessment Agency AP acid potential ARD acid rock drainage B.C. British Columbia BC EAO British Columbia Environmental Assessment Office BC WQG British Columbia Water Quality Guideline BC MOE British Columbia Ministry of Environment BC MFLNRO British Columbia Ministry of Forests, Lands and Natural Resource Operations BMI benthic macro-invertebrates CCME Canadian Council of Ministers of the Environment CEA cumulative effects assessment CEAA Canadian Environmental Assessment Act CEAR Canadian Environmental Assessment Registry CSR Comprehensive Study Report CWQG Canadian Water Quality Guidelines DFO Fisheries and Oceans Canada, Department of Fisheries and Oceans EA environmental assessment EC Environment Canada EMP environmental management plan EIS environmental impact statement ESCIA economic, social, and cultural impact assessment FHCP fish habitat compensation plan FSR forest service road GHCO Gitanyow Hereditary Chiefs’ Office ha hectare HC Health Canada km kilometre LGS Low Grade Stockpile LSA local study area m3 cubic metres m metre mg/L milligrams per litre MEMP Marine Environment Monitoring Program ML metal leaching

X CEAA—Comprehensive Study Report: Kitsault Mine Project ML/ARD metal leaching/acid rock drainage MMER Metal Mining Effluent Regulations MNBC Métis Nation of BC Mt million tonnes Mt/a million tonnes per annum NA Nass Area NFA Nisga’a Final Agreement NLG Nisga’a Lisims Government NPR neutralisation potential ratio NP/AP neutralisation potential/acid potential NWA Nass Wildlife Area NRCan Natural Resources Canada NSCP Northeast Seepage Collection Pond PAG potentially acid generating Project Kitsault Mine Project RA responsible authority RSA regional study area SARA Species at Risk Act t tonne TRWG Transportation Working Group TWG Technical Working Group TMF tailings management facility TSS total suspended solids VAP Village Advisory Process VC valued component WRMF waste rock management facility

CEAA—Comprehensive Study Report: Kitsault Mine Project XI

1. Introduction

1.1 Project Overview 1.2 Environmental Assessment Context and Process Avanti Kitsault Mine Ltd. (the proponent) is proposing to redevelop, construct, operate and 1.2.1 Purpose of the Comprehensive decommission an existing open pit molybdenum Study Report mine located in the northwest coastal region of British Columbia (B.C.). As shown in This comprehensive study report (CSR) presents Figure 1-1, the proposed Kitsault Mine Project the information and analysis that the Canadian (the Project) site is located approximately Environmental Assessment Agency (the Agency) 140 km north of Prince Rupert, B.C., within considered to determine whether the Project is the Nass Area (NA) and the Nass Wildlife likely to cause significant adverse environmental Area (NWA) as defined by the Nisga’a Final effects after mitigation measures are applied. The Agreement (NFA). Minister of the Environment will consider the CSR and comments received from the Nisga’a Lisims Government (NLG), Aboriginal groups, and the public when issuing the environmental assessment (EA) decision statement. The Minister

Table 1-1: Project Summary Project Summary The Project will consist of an open pit mine with a production capacity of approximately 40 000 - 50 000 tonnes per day, an ore processing plant, tailings and waste rock management facilities, low grade ore stockpile, site access roads, power transmission lines, explosives factory and magazines, water management facilities, plant buildings, ancillary mine infrastructure, and associated activities. Proponent Avanti Kitsault Mine Ltd. Mr. Craig J Nelsen, President and Chief Executive Officer Suite 175, 12200 E. Briarwood Ave., Centennial, CO 80122 USA www.avantimining.com Location The Project will be located in the Skeena Mining Division of B.C., approximately 140 km northeast of Prince Rupert, B.C. Coordinates of the Project 55º 25’ 19” N latitude and 129º 25’ 10” W longitude. In UTM coordinates, the location is in zone 9 at 473451 E and 6141826 N. Environmental Canadian Environmental Assessment Agency Assessment Contact Project Manager, Sherwin Shih Suite 410, 701 West Georgia Street Vancouver, B.C. V7Y 1C6 Telephone: 604-666-9876 Fax: 604-666-6990 Email: [email protected] Canadian http://www.ceaa-acee.gc.ca/050/index-eng.cfm Environmental File number: 10-03-57958 Assessment Registry (CEAR) Electronic Project http://a100.gov.bc.ca/appsdata/epic/html/deploy/epic_home.html Information Centre (B.C.)

CEAA—Comprehensive Study Report: Kitsault Mine Project 1 will issue a federal Nisga’a Final Agreement Project Recommendation at the same time as the EA decision. The Minister of the The Minister may request additional information or require that public concerns be addressed Environment will consider further before issuing the EA decision statement. The Minister will refer the Project back to the CSR and comments Fisheries and Oceans Canada (DFO) and Natural Resources Canada (NRCan) following the EA received from the Nisga’a decision statement to allow them to take the appropriate course of action. Lisims Government (NLG),

1.2.2 Federal Environmental Aboriginal groups, and the Assessment Process public when issuing the The Canadian Environmental Assessment Act1 (the former Act) applies when federal regulatory environmental assessment authorities contemplate certain actions or decisions about a project that would enable (EA) decision statement. the project to proceed in whole or in part.

An EA is required under the former Act because DFO and NRCan may take regulatory decisions Canada (EC), Health Canada (HC) and in relation to the Project, specifically, under the Aboriginal Affairs and Northern Development Fisheries Act and the Explosives Act respectively. Canada (AANDC) also provided advice in relation to their respective mandates and areas The Project is subject to a comprehensive study of expertise. type EA because a component of the Project is described in Section 16(a) of the former Act’s 1.2.3 Cooperative EA Process Comprehensive Study List Regulations: The Project was subject to an EA under the ••The proposed construction, decommissioning B.C. Environmental Assessment Act. The or abandonment of a metal mine, other than a Governments of Canada and B.C. (through gold mine, with an ore production capacity of the B.C. Environmental Assessment Office 3 000 tonnes per day or more. (BC EAO)), conducted the EA cooperatively in accordance with the principles of the The Agency is responsible for the conduct of the Canada-British Columbia Agreement for comprehensive study and prepared this CSR in Environmental Assessment Cooperation (2004). consultation with DFO and NRCan. Environment

1 The Canadian Environmental Assessment Act, 2012 (CEAA 2012) came into force on July 6, 2012, replacing the former Canadian Environmental Assessment Act S.C. 1992, c. 37 (the former Act). In accordance with the transition provisions of CEAA 2012, the comprehensive study of the Kitsault Mine Project was completed under the former Act. All references to federal EA legislation in this report reflect the requirements of the former Canadian Environmental Assessment Act S.C. 1992, c. 37.

2 CEAA—Comprehensive Study Report: Kitsault Mine Project 1.2.4 Nisga’a Final Agreement The proponent conducted an Economic, Social, and Cultural Impact Assessment (ESCIA) on the The NFA came into effect in May 2000 under well-being of Nisga’a citizens (i.e., 8(f) effects) the Constitution Act, 1982 and represents the based on a work plan that was a requirement first modern treaty in B.C. and the first treaty of the federal Environmental Impact Statement in Canada to incorporate both land claims and (EIS) guidelines. Effects defined under 8(e) were constitutionally protected self-government described in the EIS as part of the proponent’s provisions. The NFA establishes the decision- analysis of the Project’s effects on environmental making authority of the NLG and the lands over valued components (VCs). which the Nisga’a Nation has law-making power and jurisdiction. Chapter 10 of the NFA outlines Chapter 5 of this report examines both 8(e) and specific provisions for EAs that are required 8(f) effects to Nisga’a citizens, lands and interests under federal, provincial, and Nisga’a law. and provides the federal perspective regarding these effects. This chapter, together with comments The Project was subject to the NFA because received during the final public consultation the Project may reasonably be expected to have opportunity on the CSR, will inform the Minister of adverse environmental effects on residents the Environment’s NFA Project Recommendation of of Nisga’a Lands, Nisga’a Lands or Nisga’a whether the Project should proceed. Any subsequent interests set out in this agreement. Requirements permitting or approval decisions by responsible under Chapter 10, paragraph 8 were included authorities (RAs) must take the NFA Project in the EA in addition to the requirements of Recommendation into account. the former Act. The Government of Canada considered whether the Project could reasonably be expected to have: 1) adverse environmental effects on residents of Nisga’a Lands, Nisga’a Lands, or Nisga’a interests set out in the NFA (i.e., effects under paragraph 8(e)) and 2) effects on the existing and future economic, social, and cultural well-being of Nisga’a citizens (i.e., effects under paragraph 8(f)).

In February 2011, a federal approach was established to clarify how the Government of Canada would meet Chapter 10, paragraph 8 requirements in the EA, including the assessment of effects under paragraphs 8(e) and 8(f) and the issuance of a Ministerial NFA Project Recommendation.

The Government of Canada operated in a tripartite government approach with the NLG and the Government of British Columbia to facilitate the assessment of 8(e) and 8(f) effects as part of the comprehensive study.

CEAA—Comprehensive Study Report: Kitsault Mine Project 3 2. Project Description and Assessment of Alternatives

2.1 Need for and Purpose of • explosives manufacturing facility and magazines the Project • infrastructure and facilities (e.g., truck shop, fuel storage, administration office, assay laboratory) Under the former Act, the need for a project • use and maintenance of a network of existing describes the problem or opportunity that a access roads including the Nass Forest Service project is intended to solve or satisfy. The Road, Nass-Kwinatahl Forest Service Road, purpose of a project describes what is to be Kinskuch Forest Service Road and Kitsault achieved by carrying out a project. Forest Service Road

The need for the Project relates to supplying Off-site components molybdenum concentrate to help meet the global demand for molybdenum. The proponent • new substation at the mine site serviced by has stated that the purpose of the project is to an existing B.C. Hydro 138 kilovolt (kV) redevelop, operate, close, and reclaim a former transmission line from the New Aiyansh producing mine to extract molybdenum ore in a substation profitable and sustainable manner. The Project • transport of concentrate by truck from the will bring training, employment opportunities mine site to Kitwanga and increased investment in services to residents • Fisheries Act compensation works to offset within the region and to the province of B.C. the loss of fish habitat as a whole. On a national level, the proponent suggests that development of the Project will contribute to Canada’s role as a producer of molybdenum in the world economy. 2.2 Project Components

The Project includes the on-site and off-site components described below and shown in Figure 2-1. Further details of these components are provided in Appendix A. On-site components

• 40 000 to 50 000 tonnes/day open pit mine and processing plant • waste rock and tailings management facilities • ore stockpiles • water management facilities • site runoff, diversion and water collection system • sewage and waste water management facility • borrow pit, overburden and topsoil storage • construction camps and accommodation building complex

4 CEAA—Comprehensive Study Report: Kitsault Mine Project Figure 1-1: Location of the Kitsault Mine Project

CEAA—Comprehensive Study Report: Kitsault Mine Project 5 Figure 2-1: Project Components and Layout

6 CEAA—Comprehensive Study Report: Kitsault Mine Project 2.2.1 Project Activities and Schedule

The activities required to build and operate the Project and associated timeframes are presented in Table 2-1 with additional details described in Appendix A.

Table 2-1: Project Activities and Schedule Closure and Construction Operations Post Closure Decommissioning 2 months commissioning; Duration 25 months 15 to 17 years 5+ years 15 to 16 years mining • Sourcing construction • Open pit mining • Site reclamation and re- • Inspection and materials • Ore processing and vegetation maintenance of • Open pit preparation milling • Pit filling with water geotechnical structures (pre-stripping) • Waste rock from TMF and other • Reclamation monitoring • Construction of mine management sources and site management processing facilities, • Tailings management • Processing of Low • Construction and tailings management • Water treatment and Grade Ore Stockpile operation of water facility, earthworks management • Water treatment, treatment facilities (removal and stockpiling • Road use management and • Environmental monitoring of topsoil and organics) • Explosives discharge including water Description and foundations manufacturing, • Dismantling and quality and aquatic of • Construction of on-site handling, and storage decommissioning of environmental effects Activities mine access roads • Fuel and materials mine site facilities and monitoring • Construction of management removal of equipment • Final closure of access temporary and • Solid waste and materials from and power corridors permanent camps management the site • Construction of interim • Concentrate packaging • Re-contouring the site water management and transportation and restoring drainage facilities, including • Environmental patterns diversion ditches, monitoring • Environmental sediment ponds and monitoring temporary coffer dams • Environmental monitoring

2.3 Assessment of Alternatives The environmental effects associated with the first two alternatives would be essentially the 2.3.1 Alternatives to the Project same, with the exception of the timeframes. The proponent has indicated that delaying the Project The proponent has indicated that alternatives is not practical given the particular conditions to the Project are constrained by the location needed to proceed—that is, favourable metal of the ore body and by the proponent’s purpose prices and overall project economics. Any delay of redeveloping a molybdenum resource. The may result in unfavourable conditions in the proponent has determined that there are three demand for or price of molybdenum. project alternatives: The third alternative would not result in 1. proceed with the Project in the near-term, project-related adverse environmental effects. as planned However, there would be a loss of the positive 2. delay the Project until circumstances for socioeconomic effects associated with the its development are more favourable Project’s development, specifically, employment, 3. abandon the Project business and training opportunities and additional

CEAA—Comprehensive Study Report: Kitsault Mine Project 7 benefits through Aboriginal capacity building. The Agency carried out a review of the rationale Opportunities to compare the alternatives are and method for the selection of preferred limited, but abandoning the Project would not alternative means. Based on this review, the fulfill the proponent’s purpose. Agency is satisfied that the proponent has identified the technically and economically viable In considering the above, the proponent has advised approaches for carrying out the Project and the that proceeding with the Project in the near-term, as environmental effects of these alternatives have planned, is the preferred alternative, and is the only been adequately considered. alternative that fulfills the project purpose. 2.3.2 Alternative Means of Carrying Out the Project

As presented in the EIS and supporting technical documents, the proponent considered alternative means of carrying out the Project in relation to the following components and activities:

••processing plant ••Waste Rock Management Facility (WRMF) ••truck shop and fuel storage compound ••primary crusher ••explosives manufacturing facility and storage magazines ••Tailings Management Facility (TMF) ••water management ••transportation of construction materials ••transportation of concentrate ••decommissioning, closure and reclamation

The proponent used acceptability criteria and professional judgement to evaluate different alternatives, including cost-effectiveness, potential environmental effects, potential social and economic effects and amenability to reclamation. Appendix B presents a summary of the alternatives considered by the proponent.

8 CEAA—Comprehensive Study Report: Kitsault Mine Project 3. Scope of the Environmental Assessment

Scoping establishes the boundaries of the EA • capacity of any renewable resources to meet with the purpose of focusing the assessment on the needs of the present and those of the future relevant factors and concerns. • significance of the effects • comments received from the public in accordance 3.1 Factors to be Considered with the former Act and the regulations • technically and economically feasible measures Pursuant to subsections 16(1) and 16(2) of the that would mitigate any significant adverse former Act, the following factors were considered environmental effects of the Project as part of the comprehensive study: • need for and requirements of any follow-up program in respect of the Project • purpose of the project • alternative means of carrying out the Project The environmental effects of the Project on that are technically and economically feasible, residents of Nisga’a Lands, Nisga’a Lands, or and the environmental effects of any such Nisga’a interests were included in the assessment of alternative means environmental effects defined in paragraph 2(1) (a) • environmental effects of the Project, including and (b) of the former Act, to meet the requirements the environmental effects of accidents and of Chapter 10, paragraph 8(e) of the NFA. malfunctions that may occur in connection with the Project, and any cumulative environmental The effects on the existing and future economic, effects that are likely to result from the Project in social and cultural well-being of Nisga’a citizens combination with other projects or activities that as defined in Chapter 10, 8(f) of the NFA have been or will be carried out were considered as a “matter relevant to the comprehensive study” under subsection 16(1)(e) of the former Act. The Agency also determined that the EA, in accordance with paragraph 16(1)(e), would include a description of the need for the The scope of the Project Project, an evaluation of the alternatives to the Project, and an examination of the benefits for the purposes of the to Canadians as a result of the EA process. comprehensive study 3.2 Scope of the Project

includes all physical The scope of the Project for the purposes of the comprehensive study includes all physical works works and activities and activities associated with the construction, operation and decommissioning of the Project as associated with the described in Chapter 2 of this report. construction, operation 3.3 Scope of Assessment

and decommissioning of For the purposes of identifying the potential for significant adverse environmental effects, the the Project. EA focused on aspects of the natural and human environment with particular value or importance

CEAA—Comprehensive Study Report: Kitsault Mine Project 9 that are likely to be impacted by the Project. from the NLG, federal and provincial experts, These aspects are termed valued components and Aboriginal groups, and which are the focus (VCs). of this report, are shown in Table 3-1. The Agency’s assessment of project-related effects The selection of VCs for the EA was based on on all VCs and the significance of those effects issues raised during consultations, literature are summarized in Appendix E. sources and professional judgement. The VCs considered most important, based on feedback

Table 3-1: Key Valued Components Included in the Environmental Assessment Aspect of the Valued Components Rationale Environment • Groundwater flow • Groundwater quality • Importance to the health and well-being of humans, wildlife, vegetation • Recharge and and other biota Groundwater Discharge • Pathway for the transport of contaminants to the freshwater, marine, • Groundwater and terrestrial and human environments Surface Water Interaction • Hydrology of Lime/ Patsy Creek , Clary • Changes to surface water flow and quantity could affect water and Hydrology Creek and Illiance sediment quality, habitat for aquatic resources, wildlife and other biota River watersheds Surface water • Pathway for the transport of contaminants to freshwater, terrestrial • Surface water quality and sediment and human environments • Sediment quality quality • Important to hydrological processes • Ecological, aesthetic and recreational importance of the freshwater environment to the Nisga’a Nation and Aboriginal groups • Dolly Varden • Direct interaction of the Project with freshwater streams, some of which • Coho salmon Fish and Fish support fish • Rainbow trout Habitat • Potential for effects on the freshwater environment as a result of accidents • Benthic macro- and malfunctions invertebrates • Federal (Fisheries Act) regulations and federal and provincial policies that offer various levels of protection to fish and fish habitat Marine Aquatic • Marine water quality • Commercial, recreational and cultural importance Resources • Marine biota • Potentially influenced by water quality effects associated with the Project • Ecosystem composition • Ecological, commercial, and recreational importance of wildlife resources • Wetland ecosystems Vegetation to the Nisga’a Nation, Aboriginal groups and public • Old forests and Plant • Interaction of project-related activities with wildlife and wildlife habitat • Species at Risk • Provincial (B.C. Wildlife Act) and federal (Species at Risk Act) legislation Communities • Ecological that offer protection to wildlife communities at risk • Cultural plants

10 CEAA—Comprehensive Study Report: Kitsault Mine Project Table 3-1: Key Valued Components Included in the Environmental Assessment continued Aspect of the Valued Components Rationale Environment • Contribution to landscape, community and species-level biodiversity • Western Toad • Function as an indicator of overall ecosystem health • Olive-sided Flycatcher • Dependence of wildlife, plant communities and hydrological processes on • Sooty Grouse the condition and characteristics of terrestrial vegetation Wildlife and • Northern Goshawk • Commercial and cultural values, recognized at a site-specific or Wildlife Habitat • American Marten regional scale • Mountain Goat • Direct interaction of the Project with vegetation resources • Moose • Provincial and federal legislation and policies that offer protection to • Grizzly Bear vegetation resources

• Current use of lands • The project footprint is located within the asserted traditional territory of the and resources for Metlakatla First Nation. Portions of the proposed transportation corridors traditional purposes intersect the traditional territories of the Kitselas First Nation, Kitsumkalum Land and by Aboriginal people First Nation, Gitxsan Nation, Gitanyow Nation and pass through the NA, Resource Use • Trapping and guide NWA, and Nisga’a Lands as defined by the NFA outfitting • Potential for project activities to affect resources that are used by local • Country foods harvesters (e.g., hunters, gatherers, trappers or fishers)

3.4 Temporal and Spatial Boundaries

The VC selection process also considered the Spatial boundaries for each VC reflect the temporal and spatial scope of potential project- geographic extent over which the Project’s environment interactions. The definitions of potential environmental effects are expected temporal boundaries are based on the timing and to be measurable. These include the local study duration of project activities that could adversely area (LSA) for consideration of direct effects and affect the environment and humans. Based on the regional study area (RSA) for assessment of the proponent’s project schedule, the temporal cumulative effects. Spatial boundaries for each boundaries for the EA are: VC are described in Table 3-2.

Construction: Estimated 25 months Operations: Estimated two months of commissioning and 15 to 16 years of mining Decommissioning Estimated 15 to 17 years and Closure: Post Closure: Estimated five years or more

CEAA—Comprehensive Study Report: Kitsault Mine Project 11 Table 3-2: Local and Regional Study Areas for Valued Components

Valued Component Local Study Area Boundary Regional Study Area Boundary • Groundwater flow • Groundwater quality • Recharge and discharge • Groundwater and surface water interaction Project footprint plus the Lime Creek, Patsy Extends from the LSA to include the Illiance • Hydrology of Lime-Patsy Creek and Clary Creek watersheds River watershed Creek, Clary Creek and Illiance River watersheds • Surface water • Sediment quality • Dolly Varden Lime Creek watershed including Patsy LSA plus the Clary Creek watershed and • Coho salmon Lake, Patsy Creek and Lime Creek the Illiance River LSA plus Clary Creek from the outlet of Clary Clary Creek upstream of the Clary Lake • Rainbow trout Lake downstream to the impassable waterfalls outlet to Lake 901 and Lake 943 near the confluence with the Illiance River LSA plus Lime Creek from the Patsy Creek For the Lime Creek watershed, the LSA confluence downstream to Alice Arm and Lake includes Patsy Creek from its headwaters 901 and the Lake 901 outlet, Lake 493, Clary • Benthic macro- at Pasty Lake downstream to its confluence Creek from Lake 493 downstream to Clary invertebrates with Lime Creek and Patsy Lake; for the Lake, Clary Lake, and Clary Creek from Clary Clary Creek watershed, the LSA includes Lake downstream to the impassable waterfalls stream 76800 and ILP 887 of Lake 901 upstream of the confluence of Clary Creek and the Illiance River 5-km-long section of near-shore area along the eastern side of Alice Arm, extending • Marine water quality from the vicinity of the Illiance River at Encompasses the entire length of Alice Arm • Marine biota the head of the inlet to southwest of Roundy Creek • Ecosystem composition • Wetland ecosystems LSA plus 500 m to the east, highlands of Patsy • Old forests Creek watershed to the south, Clary Creek to Project footprint including mine site roads • Species at Risk the north, Lime Creek drainage to the east, plus a 500 m buffer surrounding the footprint • Ecological communities at Roundy Creek at the outlet to Alice Arm, and risk the Kitsault townsite • Cultural plants • Western Toad • Olive-sided Flycatcher LSA plus 500 m to the east, highlands of Patsy • Sooty Grouse Creek watershed to the south, Clary Creek to • Northern Goshawk Project footprint including mine site roads the north, Lime Creek drainage to the east, • American Marten plus a 500 m buffer surrounding the footprint Roundy Creek at the outlet to Alice Arm, and • Mountain Goat the Kitsault townsite • Moose • Grizzly Bear

12 CEAA—Comprehensive Study Report: Kitsault Mine Project Table 3-2: Local and Regional Study Areas for Valued Components continued

Valued Component Local Study Area Boundary Regional Study Area Boundary LSA plus Alice Arm, Bessie Lake, Patsy Lake, • Current use of lands and Shishilabet Lakes, the Kitsault and Illiance resources for traditional Rivers, a number of creeks including Roundy, purposes by Aboriginal Project footprint and access and haul roads Lime, Clary, Falls, Wilauks, Morley, Foxy, people plus a 500 m buffer surrounding this area Hoan, Kelskiist and Theophilus, and the south • Trapping and guide side of Chaloner Ridge, Mount Theophilus, outfitting Ksi Gwinhatal and Dawson Ridge Project footprint plus a 2 km buffer • Country foods LSA plus a 2.5 km buffer surrounding the LSA surrounding the footprint

3.5 Information Distribution Smaller working groups were also established during the EA to focus on specific issues related 3.5.1 Technical Working Group to metal leading and acid rock drainage, fisheries, wildlife and wildlife habitat, and transportation. In October 2010, a Technical Working Group (TWG) that comprised provincial agencies, federal departments, the NLG, and Aboriginal groups was established by the BC EAO for the EA. The TWG provided the opportunities for parties to:

••review and comment on proposed baseline study programs; ••review and comment on draft EIS guidelines and the EIS; ••provide advice on issues raised during the course of the EA; and ••comment on the EA findings to be reported to provincial ministers and the federal Minister of the Environment at the conclusion of the EA process.

CEAA—Comprehensive Study Report: Kitsault Mine Project 13 4. Environmental Effects Assessment

4.1 Assessment Methodology Agency applied the criteria described in the Reference Guide noted above, including The Agency, in cooperation with federal and magnitude, geographic extent, duration, provincial authorities, the NLG and Aboriginal frequency, reversibility, and ecological and groups, evaluated the proponent’s assessment cultural context, to evaluate the significance of of the Project’s potential adverse environmental the residual adverse environmental effects of the effects on the VCs. The analysis of environmental Project. Table 4-1 describes the definitions used effects was based on information provided by the to rate the overall significance of residual effects. proponent, comments received from the NLG and Aboriginal groups, comments received during The Agency’s evaluation of the significance of public participation opportunities, and mitigation residual environmental effects is presented in measures proposed during the EA. Appendix E. Additional details with respect to the assessment of VCs are provided in the proponent’s The proponent developed mitigation measures EIS. Monitoring and follow-up measures are that were integrated into the project design or summarized in Chapter 8 of this report. environmental management plans to address the potential adverse environmental effects of The following sections provide a summary the Project. The residual environmental effects of the potential project-related environmental that remain after implementation of mitigation effects, proposed mitigation, and residual effects measures were evaluated in accordance with for key VCs. In conducting this assessment, the Reference Guide: Determining Whether a the Agency considered the proponent’s EIS Project is Likely to Cause Significant Adverse and supplementary technical information, Environmental Effects (Federal Environmental comments from government agencies, the Assessment Review Office, 1994). NLG, Aboriginal groups and the public on the potential environmental effects of the In addition to considering information from Project, and responses from the proponent. federal and provincial authorities, NLG, Aboriginal groups, and the proponent, the

Table 4-1: Definitions for Significance Rating

Criteria Definition

Not significant Residual effects are generally of no or low magnitude, site-specific or local extent, short to (negligible/minor) long-term, low frequency (once or intermittent), reversible and negligible or low ecological context; their effects are not distinguishable from those resulting from background physical, chemical and biological processes. Not significant Residual effects are generally of medium magnitude, local to regional extent, medium to (moderate) long-term, occur at all frequencies (once to continuous), reversible or irreversible and medium ecological context; their effects and consequences are distinguishable at the level of populations, communities and ecosystems. Follow-up or monitoring of these effects may be required. Significant Residual effects are generally of high magnitude, regional extent, long-term, occur at all frequencies (once to continuous), irreversible and high ecological context; their effects are consequential in terms of structural and functional changes in populations, communities and ecosystems. If significant effects are justified, follow-up and monitoring would be required.

14 CEAA—Comprehensive Study Report: Kitsault Mine Project Patsy Creek watershed as shown in Figure 4-1, with certain components, such as the Low Grade Ore Stockpile, situated in the Lime Creek watershed. The analysis of 4.2.1 Description of Baseline Environment environmental Historical context effects was based on The surface water quality assessment focused information provided on project activities that would affect surface water quality and the contribution of past mining by the proponent, activities to existing water quality conditions. Sampling locations used to determine water comments received from quality conditions are shown in Figure 2-1, and include LC1, LC2, LC3, and PC2. the NLG and Aboriginal To separate the effects of historical mining groups, comments activities on water quality from those of the Project, the proponent differentiated between received during “current” baseline water quality conditions, which include disturbance from past mining, public participation and “natural” water quality conditions, which exclude mining effects. “Natural” water quality opportunities, and was modeled for the proposed point of discharge upstream of LC2 using data collected from upper mitigation measures Lime Creek (LC3) and Patsy Creek (PC2).

proposed during the EA. Current baseline water quality

Concentrations of various parameters in Patsy Creek and Lime Creek exceed B.C. Water Quality Guidelines (BC WQGs) and/or Canadian Water 4.2 Surface Water and Quality Guidelines (CWQGs) for the Protection Sediment Quality of Aquatic Life (CWQGs were applied for parameters where BC WQGs did not exist). The quality of surface water and sediment has These parameters include fluoride, nitrite, intrinsic importance to the health of the aquatic sulphate, aluminum, cadmium, copper, iron, zinc ecosystem and other VCs such as fish, wildlife and molybdenum. Exceedances in Patsy Creek and vegetation that depend upon it. The Agency water quality are attributed to runoff and seepage analyzed the effects of project-related changes from the existing mine infrastructure, including to surface water and sediment quality with a the Patsy Dump and Kitsault Pit. With similar focus on the Patsy Creek, Lime Creek and Clary water quality in Patsy Creek and Lime Creek, Creek watersheds, given their proximity to the water quality in Patsy Creek is likely contributing mine site. Most of the mine site infrastructure, to the diminished downstream water quality in both historical and proposed, is located within the Lime Creek.

CEAA—Comprehensive Study Report: Kitsault Mine Project 15 Water quality results for the Clary Creek neutralization, dilution, attenuation and change watershed reported that concentrations are in chemical species in the receiving environment. within guidelines. Sampling at the outlet of Lake 901, located in the headwaters of Clary Creek, The proponent expects to generate approximately revealed pH values (pH <6.5) below CWQGs 210 million tonnes (Mt) of waste rock over during freshet high flow periods. Periodic the life of the mine with up to 160 Mt of this exceedances of BC WQGs were identified waste rock placed in the WRMF. The proponent for aluminum, cadmium, iron and zinc. conducted geochemical analyses and modeling to predict the potential for metal leaching Baseline sediment quality or acid rock drainage in the waste rock, pit walls, stockpiled low-grade ore, tailings and Sediment quality data from 2009 and 2010 in construction materials, and potential loadings lower and upper Lime Creek showed exceedances to surface water and groundwater. relative to B.C. Ministry of Environment (BC MOE) working guidelines (2006) and CCME Samples with a Neutralisation Potential Ratio of Interim Freshwater Sediment Quality Guidelines less than 2 are considered to be potentially acid (ISQGs). These exceedances are attributed generating (PAG) material. Testing of mined to local mineralization and historical mining rock (i.e., waste rock, low grade ore, and pit walls) activities in the area. Exceedances were identified associated with the Kitsault deposit revealed for arsenic, cadmium, chromium, copper, iron, that 93 percent of the rock will have a ratio of lead, manganese, nickel, silver and zinc. less than 2 with half of this rock having a ratio of less than 1. The northern zone of the deposit Exceedances for the same parameters were found showed a highly heterogeneous distribution of in Clary Lake and Lake 901. Elevated mercury ratio and a wide variation of acid potential, while levels in sediments and not the surface water of samples from south of Patsy Creek almost all have a Lake 901 suggests that mercury was transported ratio lower than 1 and low neutralisation potential. in sediments eroded from mineralised bedrock and is not bioavailable. Sediments in Patsy Characterization of the long-term condition of Lake were also observed to have elevated metal waste rock at the mine site is influenced by the concentrations exceeding BC MOE working long lag time to onset of acid generation. For guidelines (2006) and CCME ISQGs. example, Pasty and Clary Dumps contain nearly 30 Mt of waste rock from historical mining 4.2.2 Potential Environmental Effects activities that have been exposed to weathering for nearly four decades without producing any Potential for Metal Leaching and evidence of large scale acid rock drainage. Acid Rock Drainage However, the absence of acid rock drainage to date does not eliminate the potential for it to Metal leaching (ML) and acid rock drainage (ARD), occur in the future and metal leaching from these which results from the weathering of sulphide- areas have likely affected Lime Creek water containing rock, has the potential to impact quality. Recent kinetic testing of the waste rock surface and groundwater quality within the mine predicted that ARD would not likely start until site and nearby water bodies. The effect on water at least 50 years after the end of mining (i.e., quality and subsequent exposure to aquatic life Year 34 of post closure). is dependent on the loading, concentration, chemical species and solubility of the metals Metals of interest with respect to metal leaching and other components in the drainage, and the and acid rock drainage associated with the deposit include arsenic, cadmium, lead, molybdenum, selenium, sulphur, and zinc.

16 CEAA—Comprehensive Study Report: Kitsault Mine Project The Project is expected to produce approximately Cadmium was identified as the main parameter 16 Mt of tailings per year, with the tailings of concern due to the persistent exceedances management facility (TMF) designed for secure of BC WQGs and CWQGs and the elevated and permanent storage of approximately 270 Mt concentrations in waste rock. of tailings. Two main streams of tailings will exit the mill. Most of the tailings will be de- Cadmium concentrations in lower Lime Creek pyritised rougher tailings that will be non- were modeled as high as 18 times BC WQG and potentially acid generating (i.e., less than CWQG during operations and 14 times these 0.10 percent sulphur and a ratio above 15) and guidelines during the post-closure period prior to suitable for beach or TMF dam construction. treatment. Other parameters were also predicted Rougher tailings not used for construction will to exceed water quality guidelines in lower Lime be deposited and partly flooded in the TMF. Creek including fluoride, sulphate, aluminum, The second tailings stream will comprise a chromium, copper, mercury, molybdenum, combination of cleaner scavenger tailings with selenium and zinc. pyrite concentrate. This waste stream is expected to be strongly potentially acid generating with For the Clary Creek watershed, cadmium and anticipated sulphide concentrations above mercury were the key parameters of concern that 30 percent and will be stored underwater in the were predicted to reach peak concentrations after center of the TMF to prevent the onset of metal closure when the Northeast Seepage Collection leaching and acid rock drainage. Ponds (NSCPs) are allowed to spill into Lake 901. Without mitigation, concentrations of these Surface Water Quality parameters are predicted to exceed BC WQGs and CWQGs due to seepage from the cyclone sand dam Mine development and operation involve within the TMF embankments (cyclone sand is activities that have the potential to affect surface finely ground rock that is a by-product of tailings). water quality. Without mitigation, changes in Exceedances of guidelines were also predicted water quality could result from discharges of for arsenic, aluminum, sulphate, copper, lead, mine process water, seepage from the TMF molybdenum, chromium, iron, selenium and zinc. embankments and Low Grade (ore) Stockpile (LGS), runoff from disturbed surfaces, topsoil Water quality further downstream in Clary and till, and metal leaching and acid rock Lake, although predicted to exceed BC WQGs drainage from exposed mine rock, tailings, and CWQGs for various parameters including and molybdenum concentrate storage. The cadmium, would not cause further decline in proponent’s water quality modeling results before water quality downstream in the Illiance River mitigation predicted potential water quality where baseline concentrations already exceed effects throughout all project phases, peaking guideline limits. towards the end of operations and then declining through closure and post closure. Predictions Water Quality Effects on Fish and Fish Habitat were compared against both the “natural” and current water quality conditions. Changes in surface water quality resulting from mine water discharge and seepage over the course Without treatment, water quality predictions of the Project have the potential to affect fish and for Lime Creek showed exceedances of BC fish habitat. Without mitigation, exceedances of WQGs and CWQGs (30 day or maximum) for a BC WQGs and CWQGs could potentially affect number of metals including fluoride, aluminum, the health of Dolly Varden, coho salmon, and cadmium, copper, chromium, mercury and zinc. other freshwater biota.

CEAA—Comprehensive Study Report: Kitsault Mine Project 17 Figure 4-1: Patsy Creek, Lime Creek, and Clary Creek Watersheds

490,000 490,000 A REV - REFNO. 6,145,000 6,140,000 ) 2 P/A NO.P/A FIGURE3 VA101-343/13 Disturbed Disturbed (kmArea ) 2 - 10.5 KITSAULT PROJECT KITSAULT AVANTI KITSAULT MINE KITSAULT LTD. AVANTI Watershed Watershed (kmArea WATERSHED MODEL STREAMFLOW WATERSHED NODES

485,000 485,000 km 3

2 C r e e k e e r C 1 Mine Site Footprint Mine Lime Creek Watershed Lime Creek 39.7 8.7 Name Watershed Clary Creek 36.7 1.8 0 : 0.5 COORDINATE SYSTEM: COORDINATE NAD 1983 UTM 9N. ZONE NOTES ANDACRGIS ONLINE ESRI IMAGERY. BASE1. NRCAN MAP: DATA MTS COORDINATE GRID2. IS IN METRES. 3. THIS FIGURE IS PRODUCED AT A NOMINAL SCALE NOMINAL OF 1:61,990A THIS FIGURE3. IS AT PRODUCED FOR 11x17 (TABLOID) PAPER. ACTUAL SCALE MAY DIFFERACTUAL SCALE MAY PAPER. (TABLOID) 11x17 FOR ACCORDING TO CHANGESACCORDING TO IN PRINTER SETTINGS OR SIZE.PRINTEDPAPER 1

R i v e r 480,000 SCALE 480,000

WATERSHED K w i n a t a h l h a t a n i w K Clary Clary Lake

CLARY CREEK R i v e r e v i R Patsy Patsy Lake

475,000 475,000

Creek Creek DRAFT

Clary Patsy

I l l i a n c e c n a i l l I Creek Wilauks KJB APP'D

Lime GLS CHK'D

WATERSHED

L I M E C R E E K 470,000 CC

470,000 DRAWN AMD Creek DESIGNED Alice Alice Arm Roundy

Creek DESCRIPTION

Falls : RIVER LAKE BOUNDARY MAJOR WATERSHED AREASITEMINE A 19OCT'12 ISSUED FOR INFORMATION

6,145,000 6,140,000 REV DATE

LEGEND GENERAL SAVED: M:\1\01\00343\13\A\GIS\Figs\_working\KITS_WatershModelNodes.mxd; Oct 22, 2012 5:01 PM; cczembor PM; 5:01 2012 22, Oct M:\1\01\00343\13\A\GIS\Figs\_working\KITS_WatershModelNodes.mxd; SAVED:

18 CEAA—Comprehensive Study Report: Kitsault Mine Project Sediment Quality with future water treatment (see Table 4-2). These measures are expected to reduce contaminant Project-related activities, including land clearing, discharge, but water treatment would still be topsoil stripping and stockpiling, and road required as metal leaching and acid rock drainage and infrastructure construction could affect is predicted in the future. sediment quality through sediment entrained in surface runoff and mobilization of metals that The proponent also considered additional become adsorbed into sediments. The Patsy mitigation by waste rock segregation and undertook Creek discharge site (Lime Creek watershed) a geochemical modeling to get a conceptual picture was identified as the greatest source of sediment of the NPR distribution in the Kitsault deposit. The metals as water would be discharged into Lime proponent concluded that segregation of waste rock Creek directly. In the Clary Creek watershed, by ARD potential was at present not practical based seepage from the LGS and the Northeast on the predominance of potentially acid generating Embankment Water Management Ponds during material, the variability of neutralisation potential operations could provide a pathway for metals ratio and the lack of detailed sampling and analysis. to become adsorbed onto sediments. However, the actual distribution of low NPR 4.2.3 Mitigation Measures waste can be accurately determined once mining begins. As a result, and in response to comments Metal Leaching and Acid Rock from the TWG, the proponent is required as Drainage Management part of the B.C. EA Certificate, to complete an assessment of the technical feasibility to segregate A suite of mitigation measures will be applied to and submerge waste rock based on its potential manage potentially acid generating waste rock and for acid rock drainage and measurable long- tailings and reduce the liability and costs associated term water quality benefits. A plan to segregate

Table 4-2: Mitigation for Potentially Acid Generating Waste Rock and Tailings

Mitigation measures Activities

Geochemical characterization of construction material and use of non-PAG material for Use of non-PAG construction other than South Embankment Construction of the WRMF in an area of previous disturbance to minimize the environmental Footprint minimization footprint of the mine Non-contact water will be diverted around the WRMF and contact water will be diverted to the Water management TMF or Kitsault open pit for discharge, depending on the project phase The Project will be designed to enable water treatment during operations, closure and post Water treatment closure to meet BC WQGs or approved Site Specific Water Quality Objectives Cleaner scavenger tailings and pyrite concentrate that are PAG will be stored below water in PAG Tailings the TMF; rapid on-site NP and AP sample analyses will identify and assist management of PAG materials (NPR < 2) A technical evaluation will be undertaken prior to construction to determine feasibility of relocating Low Grade Ore the LGS to a location adjacent to the open pit. At mine closure, the stockpiled low grade ore will stockpile be milled or moved to the open pit for permanent subaqueous storage Provision of a financial security for construction, inspection, monitoring, maintenance and repair of Financial Assurance drainage collection and ML/ARD mitigation structures Assessment of the technical feasibility of segregating and submerging waste rock and segregate Segregation waste rock, if feasible, based on potential for ARD and benefits to water quality

CEAA—Comprehensive Study Report: Kitsault Mine Project 19 and submerge waste rock will be developed and treatment (closure) and active water treatment implemented if provincial ministries determine (post closure). that segregating and submerging waste rock is feasible and beneficial to long-term predicted For in-mill treatment, lime and sulphide reagents water quality. would be added to the tailings slurry within the mill circuit to cause the precipitation of dissolved Water Quality Management metals in the tailings supernatant. The precipitate would be entrained with the tailings solids and The proponent’s Mine Site Water Management directed to the TMF, which would be designed Plan includes the following measures to address to provide filtration by dividing the pond into project-related effects to surface water quality: two sections containing filtered and unfiltered water. Microfilters would draw water from the ••Separation of contact and non-contact water and unfiltered section of the TMF into the filtered storing contact water in the TMF section, which would then be discharged into ••Seepage collection ponds and vertical sumps to the receiving environment. Applying the lime- collect surface runoff and seepage from mine sulphide treatment to the mill circuit, combined infrastructure, including the TMF embankments with filtration, would improve the quality of the and LGS water that would be released from the TMF into ••Water treatment during operations, closure and Lime Creek. post closure, including the construction of a water treatment plant if there is elevated metal As the Kitsault Pit fills during the closure leaching or acidic drainage from the WMRF phase, the addition of lime to raise the pH and ••Reuse of water to the extent practicable through precipitate metals would be used to reduce the collection and management of site runoff elevated concentrations of dissolved metals in from disturbed areas, recycling of process water the pit lake. Lime would be applied to the pit lake and storage of surplus water within the TMF water, either by batch treatment or continuous until discharge is required application, prior to discharge into Lime Creek ••Ongoing research to support the development at the start of post closure. During post closure, of site-specific water quality objectives during adding lime to a water treatment plant, such as a permitting for parameters exceeding BC WQG High Density Sludge facility, can be effective in limits (i.e., cadmium, sulphate, and aluminum) improving water quality affected by ARD.

Additional mitigation measures were developed During the winter, snow that accumulates within during the review of the EIS in response to the mine site will be deposited at the western concerns raised by the TWG. Water quality in edge of the WRMF instead of on top of the waste Lime Creek (LC1 and LC2) and Lake 901 will rock so that the water from the melted snow meet BC WQGs unless site-specific water quality does not drain through the rock placed with objectives have been approved by the BC MOE the WRMF. for specific parameters of concern. The project design will also provide for water treatment Table 4-3 describes the proposed approaches during operations, closure, and post closure and to managing contact water as part of the Mine include the capacity to collect runoff and seepage Site Water Management Plan. A summary of from all project infrastructure and direct it to the mitigation measures is described in Appendix C. TMF. Viable water treatment technologies were assessed during the EA, including in-mill water treatment (operations and closure), in-pit water

20 CEAA—Comprehensive Study Report: Kitsault Mine Project Table 4-3: Management of Contact Water from Mine Infrastructure Project phase Mine infrastructure Operations Closure Post Closure (Years 3 to 18) (Years 19 to 35) (Year 36 +) Contact water directed to the Low Grade Stockpile Contact water directed to the TMF Reclaimed Kitsault Pit if ore is not milled No longer dewatered; pit is Overflow water treated, if filling and water is treated Kitsault Pit Contact water directed to the TMF required, and directed to (lime), if required, before Lime Creek discharge into Lime Creek Contact water treated Waste Rock Contact water directed to the (High Density Sludge/ Contact water directed to the TMF Management Facility Kitsault Pit lime) and then discharged to Kitsault Pit Contact water directed to the Contact water directed Northeast/South TMF along with groundwater to the TMF along with Seepage Collection Contact water directed to the TMF seepage and TMF beach groundwater seepage Ponds runoff and TMF beach runoff • Pond water pumped to the mill • Pond water pumped to • Treated tailings slurry water from the mill mill directed to the TMF Tailings Management • Excess water filtered and • Excess water directed • Excess water filtered and Facility discharged proportional to the Kitsault Pit discharged proportional to to natural year-round natural year round discharge discharge in Lime Creek in Lime Creek

Maintenance of Water Quality for Fish and These measures include: Fish Habitat ••Diversion and runoff collection ditches In each project phase, water quality in the Lime ••Diverting water to areas within the mine site Creek receiving environment will be required where it is required or to divert clean water to meet BC WQGs or site-specific water quality for release into the environment objectives, established by the BC MOE and in ••Temporary or permanent runoff collection consultation with the NLG, to ensure water quality ditches to intercept construction water will be protective of aquatic life, including fish. runoff and divert it to a stabilised area The effluent discharged into Lime Creek will where it can be effectively managed be subject to authorized limits for deleterious ••Sediment control ponds substances under the Metal Mining Effluent ••Ponds to detain runoff from disturbed Regulations (MMER). areas so that sediment can settle out and be captured Sediment quality management ••Best management practices ••Surface roughening, temporary seeding, Mitigation measures and best management sediment traps, sediment basins, mulching practices will be undertaken, as part of the and progressive land reclamation Erosion and Sediment Control Plan, to control siltation and erosion in disturbed areas and Measures to prevent water quality effects on to prevent the release of sediment-laden sediment through metals export and downstream water into the receiving environment. sedimentation will be undertaken as part of the Mine Site Water Management Plan.

CEAA—Comprehensive Study Report: Kitsault Mine Project 21 4.2.4 Government, Aboriginal and and Management plan for all phases of the Public Comments Project. The effluent to be discharged into Lime Creek will be subject to and is predicted to meet Key concerns associated with surface water water quality limits prescribed in the MMER. and sediment quality pertained to the host of Environmental Effects Monitoring pursuant to the parameters that exceeded BC WQGs and CWQGs MMER will help to evaluate the adequacy of the in Lime Creek and Clary Creek watersheds regulatory limits in protecting fish, fish habitats, and the consideration of both “natural” (pre- and the use of fisheries resources. mine) and current water quality in the definition of “baseline” water quality for Lime Creek. With the application of the proponent’s Mine Site Comments were provided about the elevated Water Management Plan, that includes measures for concentrations of certain parameters without water treatment and seepage control, the Project is mitigation during times of low flow in Lime designed to meet BC WQGs or site-specific water Creek and the effects of these concentrations quality objectives approved by the BC MOE in in the receiving environment on marine life, Lime Creek. including the seafood consumed by Nisga’a citizens. There was also discussion regarding the Comparisons were made between predicted appropriate location for compliance monitoring water quality (annual average), water quality (i.e., LC1 vs. LC2) and the range and frequency guidelines and current concentrations for cadmium, of exceedances above guidelines currently aluminum and sulphate at monitoring station LC1 occurring at LC1 and in modeled predictions in lower Lime Creek during operations, closure during the mine life. The LGS garnered attention and post closure (see Appendix F). LC1 was used with regard to its contribution to metal loadings to represent the receiving environment since the on freshwater creeks during the life of the monitoring station is near to where fish habitat is Project. Questions were raised regarding the found in lower Lime Creek. The data indicates that potential to mill versus stockpile the low grade while predicted cadmium values may still remain ore. Reviewers discussed the possibility of above guideline limits during the life of the Project, segregating PAG from non-PAG waste rock water quality is expected to improve over current as a cost-effective measure that could avoid (baseline) conditions, which already exceed the the need for long-term treatment if PAG waste BC WQGs and CWQGs. While annual values are rock were stored in a sub-aqueous manner. provided in Appendix F for comparison purposes, Other comments focused on the proponent’s these numbers are higher or lower during certain approach to developing site-specific water quality times of the year. management targets at the permitting phase of the Project and the scope of the proponent’s Aquatic Aluminum concentrations are also predicted Effects Monitoring Program (AEMP). This led to to be below water quality guidelines, except further analysis of potential water quality effects during operations when values are highest due during the EA. to TMF discharge. Unlike other parameters, sulphate concentrations are not projected to 4.2.5 Residual Effects improve through the course of the Project. The highest concentrations are projected to occur and Residual Water Quality Effects exceed guidelines in early post closure following the discharge from the Kitsault Pit into Lime Residual effects of ML/ARD on water quality will Creek. These exceedances are likely during high be mitigated by water management measures precipitation periods of the year (e.g., winter and activities specified in the ML/ARD Monitoring and spring freshet) because in-pit lime water

22 CEAA—Comprehensive Study Report: Kitsault Mine Project treatment is not effective in reducing sulphate 4.2.6 Agency Conclusions concentrations. Initial post-closure concentrations in the Kitsault Pit will be elevated, but are expected Based on the information in this report and with to improve over time. the implementation of the mitigation measures as described in this report and summarized in With the implementation of the proposed mitgation Appendix C, the Project is not likely to result measures, future water quality in Lime Creek is in significant adverse environmental effects on predicted to improve over current water quality surface water and sediment quality. conditions. However, residual water quality effects related to cadmium and sulphate in Lime Creek 4.3 Hydrology are expected to be of low to medium magnitude, localized, long-term (beyond post closure), The Agency assessed the effects of the Project on continuous and irreversible. hydrology (surface water quantity) in the Lime Creek, Clary Creek and Illiance River watersheds Residual effects to water quality are not predicted given its influence on water and sediment quality in Lake 901, Clary Lake or further downstream and in turn, aquatic and wildlife habitat. Key in the Clary Creek and Illiance River watershed issues relating to hydrology included changes to with the implementation of the proposed seepage annual and seasonal flows in these watersheds. collection measures. 4.3.1 Description of Baseline Environment Residual Sediment Quality Effects The LSA included the project footprint and Water management and sediment and erosion associated activities that could cause surface control measures outlined in the Erosion and water quantity and flow effects. The RSA Sediment Control Plan are expected to prevent covered the Lime Creek (including Patsy Creek), sedimentation and erosion from affecting Clary Creek and Illiance River (lower portion sediment quality in the Lime Creek and Clary downstream of Clary Creek) watersheds. Annual Creek watersheds at all phases of the Project. As hydrographs of these creeks show the highest prescribed in the MMER, the effluent discharge peak flow occurring in the spring freshet period cannot exceed a monthly mean concentration of and a secondary peak occurring in the late fall 15 mg/L for total suspended solids. Due to past or early winter period. mining activities, current sediment quality in the Lime Creek and Clary Creek watersheds Lime Creek/Patsy Creek Watershed exceeds both BC MOE and CCME ISQGs for a host of parameters. The Patsy Creek watershed is a sub-watershed of the Lime Creek watershed with Patsy Creek Effluent discharges from the mine are not draining into Lime Creek and then into Alice predicted to exacerbate metal loading on Arm. The downstream end of Lime Creek was downstream sediments with the proposed water identified to be of hydrological importance given treatment measures in place. As such, the residual the presence of various species of fish and its effects to sediment quality are considered local proximity to the intertidal zone of Alice Arm. in geographic extent, low magnitude, long-term, continuous, and irreversible. A bedrock cascade located approximately 1800 meters up Lime Creek acts as a barrier to fish passage, making parts of Lime Creek and all of Patsy Creek non-fish bearing.

CEAA—Comprehensive Study Report: Kitsault Mine Project 23 Clary Creek Watershed Lime Creek-Patsy Creek Watershed

The Clary Creek watershed is situated to the The TMF will be constructed over Patsy Lake and north and east of the Project. Several lakes and is expected to alter the flow pattern of the Patsy ponds, including Clary Lake and Lake 901, are Creek drainage area. The WRMF and Kitsault located in the headwaters of Clary Creek, which Pit will affect a portion of Patsy Creek. Annual flows in a north-westerly direction and discharges flow volumes, peak flows, and low flows will be into the lower Illiance River. affected during each phase of the Project with the greatest hydrological effects anticipated in the area Illiance River Watershed of the proposed TMF. The filling of the Kitsault Pit during closure will affect flows in Lime Creek. The Illiance River watershed upstream of the Clary Creek and Illiance River confluence does Clary Creek Watershed not interact with mining activities, and as a result, was not considered in the hydrological Changes in the hydrology of Clary Lake and assessment. Conversely, the Illiance River below Lake 901 are expected because of TMF the confluence of Clary Creek and the Illiance development and water withdrawal from River could be affected by flow and water Clary Lake for mill processing and potable quantity changes in the Clary Creek watershed water needs. Approximately 1.9 km2 of the and was included in the assessment. Lake 901 drainage area will be covered by the TMF and not contribute to flows in the Clary 4.3.2 Potential Environmental Effects Creek watershed. With Lake 901 flowing to Clary Lake, water levels in Clary Lake are All three watersheds are situated within or predicted to decline by up to 5 percent. adjacent to the project footprint, with the greatest disturbance situated in Patsy Creek. Water Illiance River Watershed diversion, obstruction and withdrawal activities have the potential to affect annual flows, seasonal The proponent’s modeling estimated minor flow distributions (high and low flows) and lake effects (i.e., -2 percent to 0 percent change from levels during all phases. baseline) to average annual, peak, and seven- day low flows in the lower Illiance River. These Runoff volumes in affected watersheds are effects reflect the small loss of drainage due the anticipated to change due to the construction of TMF in the Clary Creek watershed (1.9 km2) mining infrastructure (e.g., waste rock and LGS) compared to the overall drainage area of the and water diversions, increased evaporation lower Illiance River (127.1 km2). and seepage due to the large surface water area of the TMF, greater impermeable areas where 4.3.3 Mitigation Measures mine facilities are constructed, and alteration of groundwater flows as a result of Kitsault Pit. As part of the Mine Site Water Management Plan, Aspects of the Mine Site Water Management Plan, mitigation measures to minimize project effects including pit de-watering and flooding, seepage on surface water flows include maximising collection, surface water retention and diversions, water recycling, regulating discharges to mimic also have the potential to affect hydrology. baseline conditions, and compensating for flow losses during low-flow periods. Contact water from the TMF embankments, WRMF, Kitsault Pit and LGS will be collected and pumped back

24 CEAA—Comprehensive Study Report: Kitsault Mine Project to the TMF for reuse in the milling process or proposed to install monitoring and pump-back discharged into Lime Creek following treatment. wells downstream of the NSCPs and upstream of Lake 901 prior to construction. This seepage The TMF is expected to have sufficient capacity management infrastructure would remain over to store water for most of the year without the life of the Project to prevent effects to Lake requiring discharge; however, excess water from 901 and Clary Lake. the TMF will be discharged into Lime Creek throughout the year in a manner that mimics the 4.3.5 Residual Effects natural hydrograph of Lime Creek. Therefore, more water will be discharged during periods Following mitigation, reductions in annual low of high natural flow (i.e., May – July, October) flows and peak flows in the Lime Creek and Patsy and less water will be discharged during winter Creek watershed are expected during all project and late summer low-flow periods. Based on this phases prior to post closure, despite the measures approach, the seasonal distribution of high and to mimic the natural hydrological conditions of low flows is maintained until post closure, when Lime Creek. water is no longer stored on the mine site. In some cases, excess water may be retained in the Water storage from the mine site catchment during TMF to meet regulatory requirements. operations and closure is expected to reduce the annual water volume in Lime Creek up to Flow reduction in Lake 901 will be mitigated 11 percent relative to baseline conditions. This by diverting water from neighbouring Lake 493. reduction amounts to a 13 percent reduction in With this diversion, no effects in Lake 901 and average peak flow and an 11 percent reduction Clary Lake are anticipated during construction during the period of low flow. Similar flow and operations phases; however, lake levels are reductions are expected during filling of the expected to increase during closure and post Kitsault Pit at closure, but the natural hydrographic closure due to continued flow diversion from pattern (cycle of peak and low flows) will be Lake 493 and runoff from the TMF. maintained. At post closure, a slight increase of 7 percent in annual volume and 10 percent in peak 4.3.4 Government, Aboriginal and flow are expected when water is no longer stored Public Comments on site (see Figure G-1 in Appendix G).

Key concerns regarding hydrology included the Residual effects to Lime Creek flows will potential impacts of reduced flows on fish and be continuous throughout all project phases fish habitat in lower Lime Creek and the Clary including post closure and are expected to be Creek watershed, the accuracy of the water long-term. The magnitude is expected to be low balance model in representing baseline flows to medium since the changes are within the range and the potential for unregulated discharges to of natural variation. The altered flow conditions disrupt the natural hydrology in Lime Creek. will be limited to the watershed and irreversible. Government agencies, the NLG and Aboriginal groups expressed the importance of addressing In the Clary Creek watershed, diversion from water flows and reclamation during closure and Lake 493 to Lake 901 is expected to mitigate post closure. Comments were also provided the loss of flow in Lake 901 caused by the TMF. regarding the calibration of the TMF water The seepage collection and pump-back system in balance model to reflect the changes to water place at the north end of the Project are predicted management in and around the mine site. In to reduce the effects on Lake 901 and on flow response to comments raised, the proponent contributions to Clary Creek.

CEAA—Comprehensive Study Report: Kitsault Mine Project 25 However, after mitigation, overall decreases (lower reach) watersheds. Groundwater recharges in Clary Creek flows as a result of the Project from precipitation that flows down-slope, over are still anticipated– maximum reductions of exposed bedrock or through thin overburden, 8 percent, 7 percent, and 17 percent in average to stream valleys or topographically low areas. annual, peak (10-year and 200-year) flows, Groundwater discharges to surface water bodies and 10-year 7-day low flows, respectively. that intersect the water table at the watershed The 100-year 7-day low flows will be unaffected. boundary’s lowest elevation. Maximum predicted changes in average annual, peak and 7-day low flows are within 2 percent Groundwater quality of baseline flows in the Illiance River below Clary Creek. Analyses of local groundwater samples revealed elevated concentrations of sulphate, ammonia, Based on these considerations, residual effects to and dissolved metals relative to BC WQGs, B.C. the Clary Creek watershed are expected to be low Contaminated Sites Regulations, B.C. Hazardous to medium in magnitude, continuous, long-term, Waste Regulations, and CWQGs. Sources of and irreversible. potential groundwater contamination from the Project include: 4.3.6 Agency Conclusions ••blasting residue Based on the information in this report and with ••construction, use and reclamation of the the implementation of the mitigation measures LGS stockpile, WRMF and TMF as described in this report and summarized in ••surface and waste water management works and Appendix C, the Project is not likely to result facilities and operational failure of these works in significant adverse environmental effects ••infiltration of pit lake water, containing on hydrology. blasting residue and metal concentrations into bedrock groundwater 4.4 Groundwater The proponent continues to conduct quarterly The Agency assessed groundwater as an aquatic groundwater quality monitoring to validate environment VC because changes to groundwater baseline data. flow and quality can affect water and sediment quality which, in turn, influence fish and 4.4.2 Potential Environmental Effects wildlife habitat. Groundwater flow 4.4.1 Description of Baseline Environment Potential groundwater flow effects could Groundwater flow occur as a result of dewatering the Kitsault Pit, construction and operation of the TMF The proponent’s field studies and groundwater and construction of water diversion structures. modeling show that average groundwater flow rates constitute a small portion of the Development of the Kitsault Pit below the total average surface water flow rates within existing water table is expected to direct the modeled area. Groundwater flow beneath groundwater flow from Patsy Creek and Lime the RSA is influenced by local climatic and Creek toward the open pit and lower the water hydraulic conditions within the Patsy Creek, table near the pit. With the pit located near the Lime Creek, Clary Creek and Illiance River confluence of Patsy Creek with Lime Creek, pit

26 CEAA—Comprehensive Study Report: Kitsault Mine Project dewatering is predicted to result in loss of both Sources of seepage include the supernatant pond groundwater and surface water flows to Lime and precipitation onto the tailings beach. Seepage Creek. However, low bedrock permeability and is also expected to flow through the Northeast and the high potential for groundwater recharge are South embankments and embankment foundation expected to limit the flow loss to a relatively materials. Potential for seepage via lava flows small area of influence around the pit. is low given the absence of seeps along the perimeter of the lava flows, the estimated During operations, surface water diversion hydraulic conductivities, and the limited channels will divert surface water within the Patsy exposure of the lava flows along the TMF. and Lime Creek watersheds around the Kitsault Pit. These diversion channels are not anticipated Precipitation entering the LGS and the WRMF to affect groundwater flow, since the extent of the will interact with mineralized rock and explosives diverted flow would be small compared to that of residue, and the resulting seepage could affect the watershed and the discharge would occur at groundwater quality. or near locations where the diverted surface water would have discharged naturally. When the Kitsault Pit floods with water during post closure, there is a possibility that surface Baseline groundwater flow near the Kitsault Pit water could interact with mineralized rock in the and diversion channels is expected to re-establish upper pit walls. With the onset of ML/ARD, this during mine decommissioning and closure, interaction could alter the quality of groundwater but the TMF is predicted to continually alter in bedrock surrounding the pit over the long-term. groundwater flow in the Lime Creek watershed as a new reclaimed landscape feature. 4.4.3 Mitigation Measures

Any pit water in the TMF supernatant pond that Groundwater flow infiltrates the Patsy Creek watershed is not likely to affect groundwater flow within the Patsy Creek Measures to mitigate potential groundwater and Lime Creek watersheds since the extracted flow effects include: groundwater originated within these watersheds. In addition, a small volume of pit water is ••Discharge of water drawn from the Patsy Creek expected to infiltrate the Clary Creek watershed, and Lime Creek watersheds at hydraulically but is not likely to result in groundwater effects upgradient locations in the headwaters of these at the watershed scale. watersheds to compensate for groundwater effects associated with pit dewatering. With no project development proposed for the ••Monitoring of bedrock groundwater wells near Illiance River watershed, groundwater flow and hydraulically downgradient from the Kitsault effects are not anticipated in this watershed. Pit during all phases of the Project to assess bedrock groundwater hydraulic head and chemical Groundwater quality quality and implementation of additional measures should adverse effects be detected. Groundwater quality could be affected by infiltration of seepage from the TMF, LGS, A summary of mitigation measures is provided WRMF, and Kitsault Pit. in Appendix C.

The TMF will be constructed over lava flows that could potentially provide a pathway for seepage.

CEAA—Comprehensive Study Report: Kitsault Mine Project 27 Groundwater quality lime treatment of the pit lake, active water treatment in post closure, and diversion of all The proponent designed and located project contact water and seepage back to the TMF. components to mitigate local groundwater effects. The WRMF has been strategically sited between The proponent will conduct seep mapping and the TMF and the Kitsault Pit to keep potential develop a Groundwater Monitoring and Mitigation effects in an area where groundwater has already Plan designed to assess groundwater seepage been impacted by historical mining activity. and assess chemical quality downgradient of key mine infrastructure and in the receiving Runoff and seepage from all project infrastructure environment. This plan will specify monitoring will be collected and diverted to the TMF. This methods, locations and parameters, thresholds infrastructure will be maintained indefinitely for management action and reporting protocols. (into post closure). Additional measures will be implemented (e.g., additional monitoring wells, seepage collection For the TMF, surface runoff and seepage from trenches and groundwater interception wells) the Northeast Embankment will be collected by should monitoring results detect adverse effects the NSCPs located at the downstream toe and on groundwater quantity or quality. pumped back to the TMF to protect Lake 901 and the Clary Creek watershed. Groundwater that 4.4.4 Government, Aboriginal and potentially bypasses the collection ponds (i.e., Public Comments 10 percent of total seepage under the Northeast Embankment) will be monitored, captured and Government agencies, the NLG, and Aboriginal pumped back to the TMF via monitoring and groups raised issues regarding the influence of pump-back wells located between the NSCPs the Project on local groundwater and potential and Lake 901. The South Seepage Collection regional groundwater effects. Reviewers Pond downstream of the South Embankment commented on the cumulative effects associated and WRMF will collect and pump runoff and with the impacts of different project components seepage from these structures back to the TMF. on groundwater. Other comments focused on Any seepage that bypasses the South Seepage the potential effects of Kitsault Pit groundwater Collection Pond will discharge into the Kitsault seepage on Lime Creek water quality during Pit. Monitoring wells located downgradient of closure when the pit is filling. Monitoring of the TMF embankments will be sampled to the pit lake water quality and the receptors identify any effects on groundwater quality. downgradient throughout the closure period was considered important to confirm that no Seepage water and runoff from the LGS will effects on Lime Creek would occur. There be collected in a vertical sump downstream of was also discussion about the decline in water the LGS and pumped back to the TMF. The quality in Lake 901 and Clary Lake from proponent will either mill the low grade ore the decommissioning at closure of seepage or move it to the Kitsault Pit for permanent management infrastructure for Lake 901 and subaqueous storage at mine closure to minimize the Clary Creek watershed. long-term effects. 4.4.5 Residual Effects For the potential effects of the Kitsault Pit on groundwater quality, the proponent has proposed After mitigation, residual effects to groundwater a suite of mitigation options to prevent a decline flow will persist as a result of dewatering of in groundwater quality in the pit area, including the Kitsault Pit, construction of the TMF, and

28 CEAA—Comprehensive Study Report: Kitsault Mine Project seepage from the TMF, LGS and WRMF. 4.5 Fish and Fish Habitat Groundwater flow rates in overburden and bedrock near the Kitsault Pit and the TMF will The Agency assessed the project effects on be affected during construction and operations. fish and fish habitat including the alteration, These changes would be local and not expected disruption and loss of fish and fish habitat to affect groundwater flow at the broader and hydrological effects on fish habitat in the watershed level. The Kitsault Pit would be Lime Creek and Clary Creek watersheds. The allowed to flood, diversion channels would effect of mine water discharge and seepage on be removed, and the baseline flow regime water quality as a component of fish habitat is would be re-established during closure and addressed in Section 4.2. decommissioning. These measures are expected to minimize local groundwater flow effects 4.5.1 Description of Baseline Environment associated with the Kitsault Pit except for the potential effects associated with altered Dolly Varden, coho salmon, prickly sculpin, and pit water infiltration rates caused by mining coastrange sculpin are found in Lime Creek, activity. Residual effects are considered medium but an eight metre (m) high waterfall restricts in magnitude, local in geographic extent, fish passage to the lower 1.8 km of Lime Creek. continuous, long-term, irreversible given the Dolly Varden have been found up to the waterfall. permanency of the TMF and Kitsault Pit on Juvenile coho salmon have not been captured the landscape. or observed upstream of a bedrock cascade approximately 400 m upstream of the mouth of Residual effects to groundwater quality will Lime Creek. While adult coho salmon were not occur as a result of seepage from the Kitsault captured or observed within Lime Creek, coho Pit, WRMF and TMF. The least predictable and salmon parr were found in lower Lime Creek. potentially most important residual effect is the Coho salmon are also known to be present in the potential for mobilization of metals from acid Illiance River and in the lower reach of Clary generating waste rock that could be entrained Creek. Prickly sculpin and coastrange sculpin in groundwater recharge. Any effects following inhabit the lower section of Lime Creek. mitigation would be localized to Lime Creek and to a lesser extent Clary Creek. With effective Rainbow trout was the only fish species identified mitigation, any decline in groundwater quality in the Clary Creek watershed. These rainbow will be medium in magnitude, long-term, trout are descendants from provincial stocking in continuous and irreversible. Killam Lake in the late 1980s. Fish bearing lakes in the Clary Creek watershed include Lake 901, 4.4.6 Agency Conclusions Lake 493, Killam Lake, Clary Lake, and three unnamed lakes north of Clary Lake. These lakes Based on the information in this report and with cover an area of 1 013 943 m2. the implementation of the mitigation measures as described in this report and summarized in Benthic macro-invertebrates (BMI) function as an Appendix C, the Project is not likely to result important food source for fish. Sampling results in significant adverse environmental effects showed higher density, richness, and diversity on groundwater. of benthic macro-invertebrates in Patsy Creek compared to other locations in the Lime Creek watershed. These characteristics were higher in the Clary Creek watershed than in the Lime Creek watershed.

CEAA—Comprehensive Study Report: Kitsault Mine Project 29 4.5.2 Potential Environmental Effects than baseline during construction and operations, and closure, respectively. Lake 901 has three The development of the TMF and associated other inlet tributaries and one outlet channel water management structures would affect the that are not affected by the Project and provide quality and quantity of fish bearing habitat at the suitable habitat for rainbow trout. The losses headwaters of the Clary Creek watershed (i.e., of habitat in Stream 76800 and ILP 887 are rainbow trout spawning and rearing habitats in two shown in Table 4-4. Without mitigation, the loss inlet tributaries of Lake 901) and result in the loss of fish habitat in these streams would threaten of BMI habitat in Patsy Lake and Patsy Creek. the viability of the rainbow trout population in Lake 901 since these streams provide the only Fishing Pressure spawning habitat for the lake.

Recreational angling by mine employees during Table 4-4: Fish Bearing Habitat Displaced by Project their off-shift time could affect fish species Fish Habitat Fish Habitat Habitat in the creeks and rivers near the mine site. Stream Such activities, if unchecked, can extirpate Area Lost Species Use Quality 2 local populations even if fishing conservation (m ) rainbow spawning, regulations are established to protect these 76800 3 335.7 Moderate trout rearing populations. Considering the predicted number of spawning, rainbow employees at the mine site and the open access to ILP 887 1 932.9 rearing, Marginal trout lower Lime Creek, the actions of mine employees foraging could result in the mortality of fish in the Lime Creek and Clary Creek watersheds. Changes in hydrology Loss of fish habitat Hydrological changes due to reductions in The Project is expected to remove habitat in fish upstream catchment areas (i.e., Patsy Creek), bearing reaches of Stream 76800 and Stream ILP stream diversion and the filling of the Kitsault 887 due to the following activities: Pit at closure have the potential to affect fish spawning habitat in lower Lime Creek. ••construction and operation of the Northeast Embankment of the TMF and seepage collection While reductions in water depth and water ponds over stream habitat; velocities are anticipated during the construction ••loss of flow in both streams downstream of and operations phases of the Project, these changes the Northeast Embankment and the seepage would not reduce the suitability of habitats for collection ponds; and Dolly Varden spawning and egg incubation. ••deposit and/or seepage of tailings water into Reductions in water depth and water velocities in stream habitat in both streams within the TMF these habitats would actually increase the winter footprint. period during which these characteristics would fall within optimal conditions for Dolly Varden These tributaries of Lake 901 are used by spawning and egg incubation relative to pre-mine rainbow trout for spawning and rearing. The conditions. Based on these results, Dolly Varden proponent predicted the total reduction in mean would continue to use lower Lime Creek for monthly and annual flows in both streams to be spawning and laying eggs during construction and approximately 70 percent and 50 percent lower

30 CEAA—Comprehensive Study Report: Kitsault Mine Project operation with the eggs predicted to have the same Loss of BMI habitat and communities in Patsy likelihood of survival to hatching as eggs laid in Creek (e.g., mayflies and stoneflies) and Patsy pre-mine flows. Lake (e.g., dipteran larvae, bivalves, and oligochaetes) are expected during the development Without mitigation, water levels in Lake 901 of the Northeast Embankment, tailings beach, and and Clary Lake would be reduced with Lake 901 northeast water management ponds and collection experiencing the greatest effect as the two streams ditches in the Lime Creek watershed. feeding 84 percent of the total annual inflow to Lake 901 would be affected by the TMF. The development of the TMF in the Clary Lake watershed would result in the destruction of Changes to water temperature BMI habitat and the loss of BMI communities in Stream 76800 and ILP 887 of Lake 901. This With the TMF and Kitsault Pit situated in the Patsy loss would result in a reduction in the benthic Creek watershed, water temperatures in Patsy invertebrate drift entering Lake 901, with Creek could change as the inflow to Patsy Creek potential effects on rainbow trout in this lake. shifts from Patsy Lake outlet (pre-mine conditions) to the TMF discharge (construction, operations and Effects associated with the closure) and the Kitsault Pit (post closure). transportation corridors

Changes in summer water temperatures in Accidents and spills near or into major water lower Lime Creek could affect fish feeding bodies and tributaries along the proposed rates, metabolism, conversion efficiency, and transportation corridors have the potential to growth, and potentially lead to fish mortality. affect aquatic life including fish and fish habitat. Average monthly water temperatures in winter The major types of effects associated with are less than the optimal temperature range for project-related transportation include: Dolly Varden egg incubation and near the lower lethal temperature range for coho salmon parr ••Motor vehicle accidents: spills of hazardous (a developmental life stage when salmon are or non-hazardous substances several months of age). However, the release of ••Dust water from the TMF into Lime Creek is predicted ••Vehicle emissions to result in small increases in water temperatures (1oC or 2oC) that may benefit Dolly Varden The proponent’s risk assessment of accidents or and coho salmon parr overwintering in lower malfunctions along the transportation corridors Lime Creek. determined that spills of chemicals and fuel from transport trucks along the highways and forest Changes to benthic macro-invertebrate service roads (FSRs) close to water bodies could communities affect aquatic organisms. Chemicals required for the Project are considered low in toxicity when BMI drift (e.g., larvae of aquatic insects or mixed with the aquatic receiving environment terrestrial invertebrates) serves as a food source and are expected to result in short-term effects to for Dolly Varden, coho salmon, and rainbow water bodies. Environmental damage from such trout. These fish species could be affected by events could vary depending on the size of the changes in the abundance and composition of spill and the affected water body. the BMI community caused by changes to habitat, water quality, stream flow and water temperatures in Lime Creek.

CEAA—Comprehensive Study Report: Kitsault Mine Project 31 4.5.3 Mitigation Measures of this plan is to offset unavoidable impacts to fish habitat with habitat creation or improvement. To address fishing pressures on local fish Developed in consultation with the NLG, the populations, the proponent will implement FHCP follows DFO policies and preferences for a no-fishing policy that would apply to all habitat compensation, including the habitat to be mine personnel at the mine site and during created, compensation ratio, technical feasibility transportation between the mine site and and commitments for environmental monitoring. residential communities. The policy will be The FHCP is based on a 2.4:1 habitat impact ratio communicated to all employees during employee to compensate for the loss of spawning and rearing orientation and to contractors as part of their habitat in Stream 76800 and Stream ILP 887. contractual agreements with the proponent. The proposed FHCP contains a list of Mitigation measures to reduce the potential 15 considerations for on-site and off-site habitat effects of, and changes in, hydrology on fish and compensation and is expected to create 17 412 m2 fish habitat, include: of new fish bearing stream habitat with spawning habitat features. For on-site compensation, the ••The design and installation of the gravity fed diversion from Lake 493 would supplement diversion between Lake 493 and Lake 901 to flows in Lake 901 to maintain lake water levels mitigate potential lake level changes in Lake 901 and provide opportunities to create spawning and Clary Lake caused by flow reductions from and rearing habitat within the existing lake development of the TMF. outlet. This would create nearly 343 m2 of new ••The installation of new structures in fish bearing spawning, rearing, and overwintering habitat streams along the Alice Arm road and new mine for rainbow trout in the Clary Creek watershed. site access roads to allow for fish passage that Off-site habitat compensation would include would be beneficial to rainbow trout in the Clary side channel enhancement and ponds to improve Creek watershed. spawning and rearing habitat for chum and coho ••The construction of structures in fish bearing salmon in the Kitsault River. Both chum and coho streams following DFO guidelines to minimize the salmon are species of high concern for the NLG. potential for entrainment and impingement of fish. Compensation activities in the Kitsault River would provide approximately 5 660 m2 and While no mitigation measures are specifically 11 409 m2 of spawning and rearing habitat targeted to reduce the potential changes in water for chum and coho salmon, respectively. temperatures in Lime Creek, the proponent predicts that these changes would be attenuated by Although the proposed FHCP has not been the continued thermal loading provided by runoff finalized and aspects of the plan may be modified, from the unaffected upper Lime Creek watershed, the final plan is required to be technically, the diverted upper Patsy Creek watershed, and the economically and biologically feasible. DFO will unaffected Lime Creek tributaries downstream of continue to consult with the NLG on the design the Patsy Creek confluence. and implementation of the FHCP; however, the plan is part of the federal permitting process and Fish Habitat Compensation Plan is, therefore, not considered part of the follow-up program under the former Act. The proponent has developed a conceptual Fish Habitat Compensation Plan (FHCP) to offset the A Geographic Response Plan will be developed loss of rainbow trout habitat in a portion of the prior to construction to manage the potential Clary Creek watershed. The primary objective effects to fish and wildlife from spills that affect water bodies and environmentally sensitive areas

32 CEAA—Comprehensive Study Report: Kitsault Mine Project along the proposed transportation corridors. not in agreement with DFO’s determination that More information on this plan is provided in streams at the location of the northeast seepage Section 4.10. Where important aquatic values collection ponds are not frequented by fish and along areas of the transportation corridors could that therefore the proposed tailings impoundment be at risk from spills of hazardous materials, area does not need to be added to Schedule 2 of the proponent will identify appropriate forms of the Metal Mining Effluent Regulations pursuant barrier protection (e.g., concrete or wire barriers). to the Fisheries Act. These measures will be subject to provincial approval and include consultation with the NLG 4.5.5 Residual Effects and Aboriginal groups. The loss of fish habitat in Stream 76800 and ILP Benthic macro-invertebrate communities 887 will affect rainbow trout. The geographic extent of this residual effect will be limited to Measures to mitigate the effects of habitat loss the Clary Creek watershed. This disturbance will on BMI include minimizing the project footprint, be short-term, reversible and fixed to a discrete locating project components in the headwaters period of time as fish habitat compensation of the Lime Creek and Clary Creek watersheds will be carried out. The Clary Creek watershed, and compensating for lost habitat. Potential including Lake 901 and Clary Lake, has medium water temperature changes associated with the ecological importance that results in the need to release of TMF surplus water into Lime Creek are compensate for losses of fish habitat. Monitoring anticipated to persist over the life of the Project; and reporting activities by the proponent, as however, water temperature effects on Lake 901 prescribed in a Section 35(2) Fisheries Act would be attenuated by the diversion of water authorization, will demonstrate compliance from Lake 493 to Lake 901. Water quality at and evaluate the effectiveness of the habitat LC1, LC2 and in Lake 901 will meet BC WQGs compensation program. or Site Specific Water Quality Objectives that protect aquatic life. A summary of mitigation In reaching a conclusion on the significance of measures is described in Appendix C. the potential environmental effects on fish and fish habitat, the Agency has taken into account 4.5.4 Government, Aboriginal and the following: Public Comments ••Fish habitat in Stream 76800 and ILP 887 Key issues raised included the potential for represents a small fraction of the available water quality changes and stream flow reduction habitat in the Clary Creek watershed. to affect Dolly Varden and coho salmon parr in ••While the predicted effects on rainbow trout lower Lime Creek and the loss of BMI habitat that use Stream 76800 and ILP 883 are highly in the Patsy Creek watershed. Government probable, the magnitude of the predicted agencies, the NLG, Aboriginal groups and the effects is low. public commented on the potential effects of ••The creation of compensation habitats will flow changes on fish bearing habitats in lower ensure that the productive capacity of the Lime Creek and the predicted loss of rainbow aquatic environment is not diminished. trout spawning and rearing habitat in Stream ••Throughout all phases of the Project, best 76800 and ILP 883. Reviewers also discussed management practices will be employed the encroachment of the TMF Northeast to reduce or eliminate adverse effects on Embankment on the Clary Creek drainage and fish habitat. the resulting effects on water levels in Lake 901 and Clary Lake. The NLG submitted that they are

CEAA—Comprehensive Study Report: Kitsault Mine Project 33 Losses of BMI habitat and communities in Patsy and several smaller creeks, including Lime Creek, Creek and Patsy Lake are anticipated, however flow into the head and sides of the inlet. these effects are not expected to affect Dolly Varden and coho salmon parr in lower Lime Creek The physical and chemical characteristics of given the drift distance (~6 km) and different local seawater in Alice Arm are typical of glacially- conditions (deeply incised with average gradient fed inlets along the west coast of B.C. Total of ~7 percent) between the Patsy sub-basin and suspended solids (TSS) concentrations were the fish bearing reaches of lower Lime Creek. lowest in surficial water and higher in deeper Such losses in the Patsy Creek watershed are water. Surface water TSS decreased with distance considered low magnitude, continuous, long-term from the Kitsault River, as the lowest surface and reversible. As for the Clary Creek watershed, water turbidity was recorded at the mouth of the loss of habitat in Stream 76800 and ILP 887 Lime Creek. for BMI communities is expected to be negligible because: 1) these streams represent a small Higher concentrations of certain metals (i.e., fraction of the total habitat area of the Clary Creek total aluminum, iron, manganese, copper, lead watershed; and 2) the enhancement or creation of and zinc) were reported in surface waters than new habitat would compensate for the lost habitat at depth, which suggests that these metals are and BMI production. entering Alice Arm through riverine inputs. Other dissolved metals showed higher concentrations 4.5.6 Agency Conclusions in deeper waters signifying a more marine origin. The only element found to exceed B.C. Marine Based on the information in this report and with Water Quality Guidelines was boron. the implementation of the mitigation measures as described in this report and summarized in For marine biota in Alice Arm, the EIS identified Appendix C, the Project is not likely to result in five types of habitat including intertidal gravel significant adverse environmental effects on fish beach, shallow sub tidal mud and sand areas, and fish habitat. deep sub tidal mud areas, rocky outcrops and an estuarine mud flat. Twenty species were found 4.6 Marine Aquatic Resources with the most abundant consisting of Dolly Varden char, Chinook and coho salmon, shiner The Agency examined the potential effects perch, sculpins and dungeness crab. The greatest of mine site surface drainage on both marine species abundance was found in the intertidal estuarine water quality and select marine biota environment adjacent to the outflows of Lime in Alice Arm. Marine water quality is important and Roundy Creeks. to the diversity and health of the biota, including plankton, benthic invertebrates, marine fishes, Marine mammal surveys in Alice Arm and mammals and birds, that use marine waters Observatory Inlet identified the presence of near the Project. harbour seals, harbour porpoises, Dall’s porpoises and humpback whales. Other marine mammals 4.6.1 Description of Baseline Environment were also incidentally observed, including a sea lion species, an unidentified whale species Alice Arm, the closest body of seawater to the and river otters. Harbour seals were the most Project, is located approximately 7 km northwest of commonly observed species in Alice Arm. The the proposed project site and represents one of the harbour porpoise is designated as a species of terminal branches of Observatory Inlet and Hastings special concern while the humpback whale is Arm. Two major rivers, the Kitsault and Illiance, designated as a threatened species under the Species at Risk Act (SARA). The humpback

34 CEAA—Comprehensive Study Report: Kitsault Mine Project whale is also protected under the Marine 4.6.3 Mitigation Measures Mammal Regulations under the Fisheries Act. The proponent predicts that the Project is not Recent baseline studies in Alice Arm showed expected to result in direct effects on the marine elevated metals concentrations in sediment, environment in Alice Arm and that any potential which can be attributed to past mining activities effects on Lime Creek water quality would be at the Kitsault mine, including mine tailings addressed through the implementation of the deposition directly into Lime Creek and Alice Mine Site Water Management Plan described in Arm. Past sediment quality data collected in Section 4.2 of this report. Alice Arm identified a historically impacted area spanning 14 km2 from the head of Alice Arm A conceptual framework for the MEMP was close to the Kitsault River. developed to determine whether the Project would result in “statistically significant change 4.6.2 Potential Environmental Effects in project-related metal concentrations in shellfish from current reference conditions in Alice Arm.” Project-related effects to freshwater quality and The framework specifies monitoring objectives quantity in Lime Creek have the potential to and locations, species selection, statistical affect the downstream marine environment near design and other technical details, which will the mouth of Lime Creek during operations and be completed prior to construction of the mine post closure. Direct project effects to the marine and in compliance with provincial permit environment are not anticipated since no project- requirements. Actions related to the related activities would occur in marine waters MEMP include: or along the shoreline of Alice Arm. ••use of monitoring results to determine mitigation Potential effects to marine aquatic resources effectiveness in the marine environment and to include the degradation of marine water quality determine if additional actions are warranted to near the mouth of Lime Creek, affecting marine address potential effects; biota, and the deposit of chemical contaminants ••collaboration with government agencies, the adsorbed by waterborne particulates that could NLG, and the Metlakatla Nation during all alter sediment quality in marine BMI habitat. stages of the MEMP and sharing data with Contaminants, whether in dissolved form or these parties; and particle-bound, could affect marine biota by ••completion of two years of baseline studies for direct uptake or bioaccumulation through the the MEMP prior to the start of mine operations. food chain. Changes in marine water quality could alter the species composition of benthic A summary of mitigation measures is provided invertebrates near the creek’s mouth and, in in Appendix C. turn, influence other marine biota. 4.6.4 Government, Aboriginal and Public Beyond the potential project-related effects on the Comments health of the marine environment, the potential effects of water quality on human health from With regard to potential effects to marine aquatic fish and shellfish harvesting in Alice Arm were resources, a key issue raised by the NLG was the also discussed. Outcomes from these discussions interest to ensure a thorough characterization of formed the basis of the proponent’s MEMP, which the existing baseline conditions in Alice Arm, is designed to determine whether the Project would particularly the current sediment quality that change metal concentrations in shellfish relative to has been impacted by historical mining tailings current conditions in Alice Arm. disposal. This issue arose in response to a report

CEAA—Comprehensive Study Report: Kitsault Mine Project 35 titled “Environmental Impact Assessment of Alice Discharges into Lime Creek are not likely Arm” (2012) prepared for the BC MOE that was to affect the water quality of the marine provided to the TWG during the EIS review. The environment, provided the proponent report provided information to guide future studies successfully implements the Mine Site Water of metal content in shellfish tissue in proximity to Management Plan and considering the dilution the mine site. Other comments sought information zone in Lime Creek between the mine site and to indicate whether shellfish in Alice Arm were Alice Arm and the relatively small contribution of safe to consume, and in particular, the appropriate Lime Creek to Alice Arm compared to the other quantity that could be consumed safely. In light of riverine inputs. Implementation of the MEMP is the effects of historical mining activities and the expected to detect project-related effects in Alice potential cumulative effects of the Project on the Arm. The MEMP will specify early warning marine environment in Alice Arm, comments were thresholds for triggering management actions made about the need to implement a robust marine and processes for determining critical effect effects monitoring program that would set protocols thresholds on marine biota. for monitoring and detecting potential effects, communicating outcomes to appropriate parties and Mine water releases into Lime Creek are mitigating any identified adverse effects. therefore not expected to adversely affect primary productivity, reduce fish survival, or 4.6.5 Residual Effects affect Nisga’a Nation, Aboriginal or recreational fisheries in the marine aquatic resources in Alice Project-related activities effects on surface water Arm. Residual effects resulting from changes to and sediment in Lime Creek have the potential to water and sediment quality are anticipated to be affect marine water quality and sediment that have of low magnitude, occurring at the local scale, already been affected by past mining at the former long-term, continuous and irreversible. Kitsault site. However, the freshwater contribution of Lime Creek to Alice Arm is relatively small 4.6.6 Agency Conclusions (5 percent) compared to the Kitsault River (57 percent), Illiance River (17 percent), and the Based on the information in this report and with combination of other smaller creeks (21 percent) the implementation of the mitigation measures that discharge into Alice Arm. Discharge from the as described in this report and summarized in Kitsault River, which is unaffected by the Project, Appendix C, the Project is not likely to result heavily influences the marine water and sediment in significant adverse environmental effects on quality in Alice Arm and, in turn, the local marine marine aquatic resources. biota including shellfish. 4.7 Wildlife and Wildlife Habitat The proponent will ensure the water quality in the Lime Creek receiving environment will The Agency examined the potential effects of meet BC WQGs or site-specific water quality the Project on wildlife and their habitat, which objectives for the protection of aquatic life. are important to the biodiversity of the region For parameters with residual exceedances, and could be sensitive to mining and other site-specific water quality objectives will be activities in the region. developed for water users in Lime Creek (e.g., fish, aquatic biota, etc.). Although there may 4.7.1 Description of Baseline Environment still be exceedances of BC WQGs, the predicted water quality in Lime Creek is expected to Baseline field studies were undertaken by the improve over current water quality conditions. proponent in 2009 and 2010 to characterize the

36 CEAA—Comprehensive Study Report: Kitsault Mine Project terrestrial wildlife communities and identify for both species. The assessment of old forest important wildlife habitats in and around also indicated potential nesting habitat for the mine site area. In addition to direct field Marbled Murrelet. observations, the proponent conducted literature reviews to compile existing information and Moose were observed at lower elevations along held discussions with knowledgeable experts, Alice Arm and the Kitsault River and found to including representatives of the NLG and the use the stretch of road from the Nass FSR (also Gitanyow Hereditary Chiefs Office (GHCO). known as the Cranberry Connector) to the mine as a travel corridor. The moose population in Wildlife studies focused on reptiles and the NWA (5 000 km2) area has been in gradual amphibians, birds and mammals, including decline, with recent provincial moose survey species listed on Schedule 1 of SARA. Under results showing a 70 percent reduction in the Section 79(2) of SARA, the Agency must identify population since 1997. Harvest reductions and the adverse effects of the Project on listed other conservation measures have been initiated wildlife species and their critical habitats. If the by provincial agencies, the NLG and Aboriginal Project is undertaken, measures must be taken groups to respond to this population decline. to avoid or lessen those adverse effects and to Wildlife studies did not identify grizzly bear monitor them in a way that is consistent with aside from an incidental sighting near Clary any applicable recovery strategy. Lake. However, salmon runs in both the Illiance River and the Kitsault River provide potential Migratory birds, including Marbled Murrelet feeding sites for grizzly bears. Mountain goats and Olive-sided Flycatcher, and the Northern were observed in lower elevation forested areas Goshawk (A. g. laingi subspecies), are listed outside the RSA. as threatened species on Schedule 1 of SARA, while the Western Toad is listed under SARA as Baseline surveys indicated that American marten a species of special concern. The grizzly bear is are commonly found in the region where there designated as a species of special concern by the is mixed canopy conifer forest supporting high federal Committee on the Status of Endangered structural diversity associated with mature and Wildlife in Canada (COSEWIC). Species on old growth stands. Wetland surveys revealed the provincial blue list include the Olive-sided limited breeding habitat for Western Toad within Flycatcher, sooty grouse, and grizzly bear while the existing wetland complexes. Northern Goshawk subspecies A. g. laingi is on the provincial red list. 4.7.2 Potential Environmental Effects

Important wildlife habitats in the project area The potential environmental effects of mine were identified through habitat suitability activities and components on wildlife and their mapping and wetland habitat assessments. habitats were examined during all project phases Portions of the LSA provide suitable habitat and included habitat loss or alteration, physical for Olive-sided Flycatcher (33 percent), sooty barriers, sensory disturbance and wildlife grouse (71 percent), Northern Goshawk mortality. (6 percent), American Marten (43 percent), and moose (11 percent), respectively. Baseline Habitat loss or alteration bird surveys detected Olive-sided flycatchers beyond the footprint area and sooty grouse Development of the Project will result in the throughout the LSA and RSA, which indicates loss, disturbance and degradation of wildlife that the RSA provides suitable breeding habitat habitat. Removal of upland and wetland areas

CEAA—Comprehensive Study Report: Kitsault Mine Project 37 and alteration of aquatic breeding habitat within their winter range, particularly in areas where the area of the mine footprint could impact noise disturbance is currently limited. The Nass amphibian populations including the Western FSR and the Nass-Kinskuch FSR bisect wildlife Toad. Clearing of forested area has the potential winter range habitat and are not ploughed in the to remove forage and wintering habitat for moose winter. Ploughing of these roads to allow vehicle and American Marten and breeding habitat for traffic during the winter could disturb wildlife Olive-sided Flycatcher, Northern Goshawk and in adjacent habitats and potentially hinder their sooty grouse. Edge effects resulting from habitat movement between habitats. loss or fragmentation can affect wildlife breeding, nesting and foraging activities as competition, Wildlife mortality predation and parasitism along the habitat interface increases. Traffic along the proposed transportation corridors could increase the risk of wildlife Physical barriers mortality. Winter ploughing of the network of Forest Service Roads from the mine site to Physical barriers may affect wildlife or disrupt Cranberry Junction off Highway 37 has the wildlife movement. Mine infrastructure, such as potential to increase moose-vehicle collisions the TMF and WRMF, has the potential to block or since these roads are currently inaccessible in alter seasonal toad migration between terrestrial the winter and experience relatively low levels and wetlands habitat. Some species may use of traffic during the remaining months. Ploughed cleared right-of-ways as travel corridors leading roads that provide year-round access to the to altered wildlife movement patterns. project area could also lead to an increase in hunting pressure or poaching of moose. Increased Sensory disturbance mortality could yield adverse changes to the already depressed moose population in the Nass Noise and vibration from mine-related activities Wildlife Area. (e.g., blasting, machinery) and human presence have the potential to affect wildlife behaviour and Increased traffic levels associated with the Project habitat use. Visual disturbance is related to lights, may also increase vehicular collisions with structures, and human presence while salt used as other wildlife species including bears, American a road de-icing agent and odours from garbage, Marten, sooty grouse, and Northern Goshawks. sewage, machine oils and food are considered The clearing of active nesting areas and the wildlife attractants. These attractants could potential for bird collisions with mine-related entice wildlife to the mine site area and along vehicles and power lines have the potential the proposed transportation corridors, increasing to increase bird mortality. the potential for human-wildlife interactions. The effects of sensory disturbance will vary by 4.7.3 Mitigation Measures species and life stage, but could include increased stress levels, avoidance of or displacement from A broad range of mitigation measures will important foraging, denning and nesting habitats, reduce the potential effects on wildlife and distractions from feeding or breeding and wildlife habitat resulting from the mine site decreased productivity. or transportation corridors. Details of these measures are provided below with a summary Vehicle traffic noise can also disturb and of mitigation measures found in Appendix C. potentially displace wildlife (e.g., moose) from

38 CEAA—Comprehensive Study Report: Kitsault Mine Project Habitat loss or alteration ••Provide transportation for employees working at the mine to reduce traffic volumes and reduce ••Maximize the use of previously cleared areas the risk of motor vehicle-wildlife collisions. to minimise encroachment into undisturbed ••Monitor road conditions during all project phases wildlife habitat. and minimize dust generation by applying dust ••Conduct surveys of Western Toad (e.g., in suppression materials. wetlands and ponds) prior to clearing and salvage toads that are found. During the EIS review, the proponent proposed ••Conduct vegetation and tree clearing outside further investigation into the potential project- the bird breeding window (1 April to 31 July) related effects on bats and Marbled Murrelet by to minimise nest mortality. identifying 1) the potential presence of hibernacula ••Identify and avoid sensitive habitats adjacent (shelter of a hibernating species) or roosting to worksites. sites for bats in and around the mine site and 2) potential breeding habitat for Marbled Murrelet. Physical barriers The proponent also prepared a Road Use Effects ••Install signs along access roads (forest service Assessment to identify and address the potential roads) and mine site roads (for all mine-related effects associated with the following two vehicles) to yield the right of way to wildlife. proposed transportation corridors from Highway 16 to the mine site, as shown in Figure 4-2: Sensory disturbance 1. From the Highway 16 turn-off west of ••Train employees and contractors in handling Terrace, north on Highway 113 past New wildlife interactions and minimising or Aiyansh onto the Nass FSR to kilometre 31 avoiding bear-human conflicts (Bear Interaction and then following the Nass-Kinskuch FSR, Management Plan, Solid Waste Management Plan). Nass-Kwinatahl FSR, Kitsault FSR, and Alice ••Minimize visual and noise disturbance by Arm Road to the mine site. preserving vegetation buffers around construction 2. From the Highway 16 turn-off at Kitwanga, and operations areas, and reducing noise north on Highway 37 to the Nass FSR (i.e., emanating from operating facilities, equipment Cranberry Connector), west along the Nass and vehicles (Noise Management Plan). FSR to kilometre 31 and then following the ••Use refuse control during construction and Nass-Kinskuch FSR, Nass-Kwinatahl FSR, operations to prevent the attraction of wildlife Kitsault FSR, and Alice Arm Road to the to work areas. mine site. ••Use non-palatable de-icing products and re- vegetation species at the road’s edge to reduce Issues related to road use were discussed the attraction of moose to the access road. amongst members of the Transportation Working ••Install signage at known wildlife crossing points. Group (TRWG), resulting in the development of additional mitigation measures beyond those Wildlife mortality described in the EIS to manage road use effects on wildlife. As part of the B.C. EA Certificate, ••Restrict mine site access to only individuals the proponent will be required to: who are employed with the Project, using gated entry points. ••Support Nass moose population recovery ••Enforce a no hunting policy for all mine efforts, including education and communication, personnel.

CEAA—Comprehensive Study Report: Kitsault Mine Project 39 inventory, monitoring, collection of harvest data, important cultural value of moose to the NLG signage and programs to increase knowledge of and local Aboriginal communities, concerns human interactions with moose. were raised regarding the potential mortality ••Provide the option to Conservation officers or of moose from vehicle collisions along the other provincial enforcement staff conducting transportation corridors and increased illegal enforcement activities along the proposed or unregulated hunting along the Nass FSR. transportation corridors to use accommodations Reviewers recommended managing human- at the mine during enforcement activities. bear interactions and separating wildlife from ••Develop a Wildlife Corridor Management Plan areas of waste or contaminants on-site during all before the start of construction. The Plan will phases of the Project and monitoring to ensure include measures to reduce the risk of vehicle- wildlife exclusion measures are effective. It was also wildlife interactions. See Appendix I for suggested that carrion along the FSRs to the mine more details. site be removed to reduce grizzly bear attraction to ••Develop a Transportation Safety Plan, prior to roads and interactions with mine-related vehicles. construction, to enhance driver safety and protect the public and environment through measures to 4.7.5 Residual Effects reduce the likelihood of vehicle accidents. See Appendix I for more details. Habitat loss or alteration ••Participate in cross-industry, government strategies or planning exercises or studies that Western Toads are known to move between address road use adjacent to or intersecting terrestrial and aquatic habitats for breeding moose habitat along the proposed transportation and survival. After mitigation, 35 percent and corridors, including funding to support a 24 percent of terrestrial and wetland habitats, coordinated approach to managing and mitigating respectively, in the LSA will be lost during the potential cumulative effects to aquatic and construction and operations. Most of the habitat wildlife populations along Highway 37. in the LSA is not suitable for Western Toad ••Regularly share traffic schedules and data on breeding and baseline surveys did not identify accidents and wildlife collisions with other any potential breeding sites in the areas of the project proponents who are undergoing an EA proposed TMF or WRMF. Although potential or will during the life of the Project, and who breeding habitat was found in Lake 493, will be using Highway 37, Highway 113 and northeast of the TMF, mine-related activities the Nass FSR. are not expected to affect these habitats. Pre- clearing surveys, salvage and reporting of 4.7.4 Government, Aboriginal and Western Toad breeding or mass dispersal Public Comments movements will be undertaken to prevent further effects to Western Toad individuals. After Comments were provided about the identification reclamation, the landscape, although different and avoidance of western toad migration routes from baseline conditions, may provide suitable and seasonal habitats. Other comments focused habitat for Western Toad breeding. on undertaking further work to identify wildlife habitat areas in the mine area, including potential bat hibernacula or roosting sites and old forest breeding habitat for Marbled Murrelet, and developing appropriate strategies to mitigate any potential disturbances to individuals found in these areas. Given the conservation status and

40 CEAA—Comprehensive Study Report: Kitsault Mine Project Figure 4-2: Proposed Transportation Corridors from Highway 16 to the Mine Site

CEAA—Comprehensive Study Report: Kitsault Mine Project 41 The removal of Patsy Lake and the surrounding Of the 209 ha (or 11 percent) of potential moose forested area for the construction of the TMF winter habitat, 31 ha (15 percent) would be is expected to remove 228 hectares (ha) removed. Use of this habitat by moose will be (35 percent) and 502 ha (36 percent) of the affected over the life of the Project. However, total Olive-sided Flycatcher and sooty grouse moose are known to winter in the lower elevation potential breeding habitat (649 ha and 1 409 ha) riparian areas near the Kitsault River estuary and respectively, in the LSA. While the predicted surrounding low elevation areas of Alice Arm. losses would affect nesting opportunities on a This part of the Kitsault area has been identified local scale (i.e., within the mine footprint), they as moose winter range and will not be affected are not predicted to cause population-scale effects by the Project. given the remaining potential breeding habitat in the LSA (65 percent for Olive-sided Flycatcher Residual effects related to lost and altered and 64 percent for sooty grouse). These species habitats are anticipated to be low to medium can also use a broader range of habitat in the in magnitude, local, long-term, continuous RSA. The predicted Olive-sided Flycatcher and and irreversible. sooty grouse habitat losses will be long-term, as it is uncertain whether both species would return Physical barriers to a potentially different landscape following reclamation (i.e., denser forest environments The development of TMF, WRMF and other replaced with open habitats). mine infrastructure is expected to disrupt the movement of Western Toads. Western Toads, Residual effects to Northern goshawk are not however, can use different types of terrestrial anticipated, considering the mitigation proposed, habitats and have the ability to move over long the high elevation of the Project (i.e., ≥ 900 m) distances to find suitable habitat. Baseline relative to the optimal elevation for breeding surveys of the existing landscape in the project habitat, and the limited value of potential footprint did not identify Western Toad or breeding in the mine footprint as a result of breeding habitat. The localized residual effect past disturbances. is expected to be intermittent, long-term, and reversible, based on these considerations, Of the 856 ha of potential wintering habitat for assuming Western Toad re-inhabit the American marten in the LSA, 312 ha (36 percent) landscape after reclamation. will be removed due to mine construction and operations. The quality of the habitat lost is Project infrastructure and activities would likely considered low because of the snow depths displace grizzly bears from the mine site area associated with higher elevations (>800 m) and alter any movements through the site into at the mine site that would restrict marten adjacent habitats. Considering the moderate movement and hunting activities in the LSA. suitability of bear habitat in the LSA, the Lower elevation areas beyond the LSA with temporary use by bears of the LSA during the reduced snow packs may provide more suitable fall season, and the amount of habitat that will be winter habitat for marten. Effects to the regional removed by the Project (553 ha) relative to the marten population are not anticipated given the sizeable home ranges of grizzly bears, residual relative abundance of potential wintering habitat effects associated with direct habitat alteration in the RSA and the highly mobile nature of and the displacement of bears are not expected. marten to find suitable habitat. Marten are likely to reoccupy the area once the mine site has been reclaimed and revegetated.

42 CEAA—Comprehensive Study Report: Kitsault Mine Project Sensory disturbance risk to Western Toads. Any residual effects would occur intermittently and at the local scale of the Displacement of moose from the mine site area mine footprint. is likely to occur as a result of noise and human disturbances during construction and operations. For moose, mortality is not anticipated within The degree of displacement is considered minimal the mine site area or along road sections since because of the limited moose winter habitat these are not adjacent to high quality habitat. available in the LSA (209 ha or 10.6 percent of the Moose winter range habitat has, however, LSA) and because moose use lower elevation areas been identified along sections of the Nass FSR along Alice Arm and the Kitsault River estuary. (Cranberry Connector) and the Nass-Kinskuch FSR, both of which are not accessible in the Mitigation measures to prevent the disturbance winter. Potential moose mortality could increase or displacement of moose along the proposed as a result of greater vehicle traffic and access transport corridors will help manage the along these areas during winter when moose disturbance by vehicle traffic of roadside might concentrate in winter habitat ranges. By winter moose habitat. congregating, moose in these areas would be susceptible to increased hunting pressure (i.e., Development and implementation of a Bear illegal or unregulated hunting). The moose Interaction Management Plan will reduce the population in the Nass Wildlife Area has been potential attraction of grizzly bears to the mine in decline and is considered at risk by provincial site and, in turn, minimize the risks associated government agencies, the NLG and Aboriginal with bear-human conflicts. groups. Therefore, the cultural and ecological importance of the moose population in the region Vegetation clearing activities may cause sensory is considered high. disturbance to Olive-sided Flycatchers and sooty grouse during the breeding season and near active The expected increase in project traffic in nests. These effects are confined to a point source combination with the winter snow ploughing of of disturbance that would continue to occur until roads is likely to increase grizzly bear mortality vegetation clearing activities are complete. risk as a result of vehicle collisions. The grizzly bear mortality risk is expected to vary depending Residual effects related to sensory disturbance are on the suitability of habitat adjacent to the roads, anticipated to be low to medium in magnitude, speed limits (e.g., higher along highways), areas local to regional in geographic extent, intermittent with blind turns or time of season. The potential to continuous, medium-term or longer, medium mortality of female grizzly bears could affect the level of ecological importance and reversible. productivity of the local population since grizzly bears generally have lower reproductive rates. Direct mortality The ecological importance of the grizzly bear population is considered medium as a result of Mortality of Western Toads at the mine site its designation as a species of special concern. and along the mine access roads could occur during mass tadpole dispersal, which in turn, Avoidance of vegetation clearing activities could affect the local population. Pre-clearing during breeding periods is expected to limit surveys and salvage to be conducted during the the direct mortality of Olive-sided Flycatchers. amphibian breeding and dispersal periods are Considering the conservation status of the anticipated to minimize the potential mortality Olive-sided Flycatcher under SARA, the

CEAA—Comprehensive Study Report: Kitsault Mine Project 43 ecological importance of any loss of nesting Vegetation is shaped by elevation (600-1 600 m) individuals and the productivity of the local and the transition between coastal and interior population would be high. Sooty grouse, a climates that are characterised by long, moist, species of special concern and American marten cold winters and short, cool, moist summers. may be affected by clearing activities and by Forests are dominated by mountain hemlock and vehicle strikes. The potential mortality of hens amabilis fir with subalpine fir less commonly and chicks could affect the productivity of the found. Wetland fen and narrow-leaved cotton- local population. grass – peat-moss fen are also widespread in the area. The understorey vegetation comprises Residual effects related to direct mortality Alaskan blueberry, black huckleberry, oval- are anticipated to be low to medium in leaved blueberry, five-leaved bramble, magnitude, local to regional in geographic pipecleaner moss and red-stemmed feathermoss. extent, intermittent, long-term, medium to high ecological importance and irreversible. Riparian ecosystems were identified within the project footprint. Other sensitive vegetation 4.7.6 Agency Conclusions communities include old forests, sparsely vegetated areas, and wetlands (i.e., fens, treed Based on the information in this report and with swamps and marshes), which play an important the implementation of the mitigation measures role in regulating surface and groundwater flow as described in this report and summarized in and providing habitat for amphibians, birds, Appendix C, the Project is not likely to result plants and insects. in significant adverse environmental effects on wildlife and wildlife habitat. One rare ecological community, Sitka-sedge – peat-moss fen, is on the provincial red list 4.8 Vegetation and for ecological communities designated for Plant Communities conservation. Two provincially blue-listed ecological communities at risk, WH-lodgepole The Agency evaluated the potential effects of pine-Feathermoss and amabilis fir-western the Project on vegetation and plant communities red cedar-oak fern, were also identified. These because these communities provide chemical, communities covered approximately 15 ha or biological and physical functions that contribute less than 1 percent of the LSA. to the maintenance of healthy ecosystems and are important to the cultural and commercial interests Although field surveys did not identify invasive of the Nisga’a Nation and Aboriginal groups. species or species at risk listed under provincial legislation, Cryptic Paw Lichen (Nehroma 4.8.1 Description of Baseline Environment occultum), a species designated as a species of special concern by COSEWIC and listed on The NLG noted that the Project is located within Schedule 1 of SARA, could potentially occur the Meziadin Mountains Ecosection of the Nass in the LSA. Ecosystems with medium to high Ranges Ecoregion. The LSA comprises three potential to support species at risk covered biogeoclimatic ecosystem classifications: coastal approximately 256 ha or 13 percent of the LSA. western hemlock (CWHws2) at lower elevations and mountain hemlock amabilis fir (MHmm2) Wetlands and mountain hemlock subalpine parkland, heath and meadow (MHmmp) at higher elevations. Wetlands provide habitat for wildlife, birds and amphibians and support ecological and biological

44 CEAA—Comprehensive Study Report: Kitsault Mine Project processes. Nine wetland site associations were were considered as having an optimal habitat surveyed and all five federally recognized for pine mushroom growth. wetland classes were mapped, covering a total area of 510 ha, as shown in Table 4-5. Fen Fifty percent of ecosystems were considered wetlands were the most prevalent among the to have moderate cultural plant potential while classes, covering 390 ha with the narrow-leaved only 10 percent (190 ha) and 6 percent (119 ha) cotton-grass – peat-moss fen identified as the were regarded as having high and low potential, dominant fen, occupying 226 ha. The provincially respectively. red-listed Sitka-sedge – peat-moss fen covered 42 and 102 ha in the LSA and RSA, respectively. Only 1 percent (27 ha) of ecosystems had high The proposed tailings management facility will be potential to support berry-producing plants. The situated in the MHmm2 biogeoclimatic ecosystem remainder of the LSA is divided between areas of classification unit. Approximately 367 ha of the moderate (35 percent, 700 ha) and low potential MHmm2 in the LSA are covered by fen wetlands. (24 percent, 563 ha) for growth.

Table 4-5: Wetland Classes in the Local Study Area 4.8.2 Potential Environmental Effects Wetland Class Wetland Area (ha) The Project’s potential environmental effects Bog 51 include loss and degradation of terrestrial Marsh 4 ecosystems and wetlands. Swamp 55 Fen 390 Terrestrial Ecosystem Loss and Degradation Shallow open water 10 Total 510 Potential project-related effects on ecosystems include loss or alteration of existing ecosystems Cultural plants (e.g., drawdown of the water table in wetlands, alteration of vegetation overstorey and understorey), The proponent assessment of cultural plants vegetation degradation due to dust deposition, included a number of categories that have social, encroachment of invasive plant species and economic or traditional use importance for the conversion of ecosystems following reclamation. NLG and Aboriginal groups: cedar trees (western red cedar and yellow cedar), pine mushrooms, Of the 1980 ha of existing ecosystems in the and ecosystems with potential to support cultural LSA, approximately 440 ha of upland ecosystem plants, including medicinal and edible berry- (35 percent of the LSA) and 113 ha of wetland producing plants. ecosystems (24 percent of the LSA) will be removed due to construction of the Project. Cultural plants occur in all three biogeoclimatic Mining activities will also utilize 115 ha of units represented in the LSA. Vegetation data was previously disturbed area (5 percent of the LSA), modeled to determine the distribution of potential including mine spoils (25 ha) and the reclaimed cedar trees and pine mushroom habitats and to mine area (19 ha). The Kitsault Pit, TMF and examine the ecosystems that support cultural WRMF represent the largest vegetation loss with plants and plants that produce edible berries. a total footprint of 118 ha and 460 ha, respectively. This includes a loss of 4 ha of shallow open water Approximately 15 percent (235 ha) of ecosystems as Patsy Lake is incorporated into the TMF. The were identified as having the potential to support Project would also remove 4 percent (1 ha) of cedar trees while only 2 percent of ecosystems the ecological communities at risk, all within

CEAA—Comprehensive Study Report: Kitsault Mine Project 45 the blue-listed amabilis fir-western-red cedar- Cultural plants oak fern site series, and 13 percent (34 ha) of ecosystems that have high and medium potential Potential project effects on cultural plants are to support species at risk linked to the loss of baseline ecosystems and the associated loss of cultural plant habitats, Wetland Loss and Degradation particularly at the proposed TMF site. Other effects could be related to dust deposition, Wetlands will be removed due to construction of habitat alteration and reduced vegetation the Kitsault Pit, TMF and WRMF. The proposed diversity associated with site reclamation. TMF and WRMF will be responsible for 99 percent (112 ha) of the total 113 ha of wetland area lost. For western red cedar and yellow cedar trees, the Approximately 16 of the 42 ha (38 percent of the Project is predicted to remove 35 ha or 2 percent of LSA) of red-listed Sitka-sedge – Peat-moss fen in available cedar trees in the LSA (~235 ha), mainly the LSA will also be lost to the TMF’s northeast in the mountain hemlock amabilis fir unit. The embankment and tailings beach. Wetland loss will proponent also noted certain areas of the Project result in removal of habitat used by wildlife and that can support the growth of pine mushrooms, alteration of water flow patterns. The extent of depending on an appropriate combination of soil, wetland loss associated with project development elevation and vegetation features. Loss of pine is shown in Table 4-6. mushroom habitat is estimated at 1 percent of available habitat (<1 ha) in the LSA. Table 4-6: Wetland Loss Associated with the Project Biogeoclimatic In terms of medicinal plants, the Project would Area Ecosystem Wetland Project lost result in the loss of 31 percent (369 ha) of Classification class component (ha) ecosystems with high or medium potential to Unit support medicinal plants. The Project is also Bog <1 predicted to remove 38 percent (274 ha) of habitat Swamp <1 CWHws2 Kitsault pit with medium or high potential to produce berries. Fen <1 Total loss 1 ha 4.8.3 Mitigation Measures Bog 5 Marsh <1 Measures to reduce the potential effects Swamp 9 on ecosystems and cultural plants include MHmm2 TMF and Fen 94 minimization of the project footprint, dust WRMF suppression, invasive species management, Shallow open 4 water salvage of topsoil and peat soils for reclamation, Total loss 112 ha and techniques for site preparation, fertiliser Total loss of wetland area: 113 ha application, reclamation and re-vegetation. (~ 22 percent of the wetlands in LSA) A Vegetation Management Plan will be developed Project activities could also potentially disturb or prior to construction to minimize and mitigate degrade wetland ecosystems that are not directly potential vegetation effects while meeting lost due to project development. Potential effects regulatory requirements for timber harvesting, to wetland community structures and function conservation of species and ecosystems at risk, relate to changes in water flow and colonization and control of invasive plant species. by invasive species.

46 CEAA—Comprehensive Study Report: Kitsault Mine Project The Reclamation and Closure Plan specifies the inform the development and implementation of process for reclaiming wetlands, ecosystems protocols for managing potential effects to the that support species at risk and cultural plants, lichen species that are identified. This assessment old forests and sparsely vegetated ecosystems in will be conducted by a lichen specialist and areas of the decommissioned mine infrastructure. reporting activities will be completed in In particular, the processing plant and associated consultation with Environment Canada. mine infrastructure will be reclaimed and reforested with native deciduous tree and shrub 4.8.4 Government, Aboriginal and species. The downstream slope of the WRMF will be Public Comments re-sloped, capped with reclamation material, and seeded. The TMF has been designed to maintain a Terrestrial ecosystem loss, including the loss lake over a portion of the tailings sand beaches in of wetlands in the project area, was of key perpetuity. The downstream slope of the Northeast concern to government agencies, the NLG Embankment and areas of the south and north and Aboriginal groups. Concerns were raised tailings beaches that are not inundated with water about the proponent’s approach to avoiding and will be reclaimed to an upland community. For mitigating the potential effects on species at risk, other facilities, surface material will be replaced including the residual effects associated with the once a facility has been decommissioned. loss of the red-listed Sitka-sedge – peat-moss fen community. Reviewers expressed concern Before construction, Terrestrial Ecosystem that a conceptual wetland habitat compensation Mapping will be used to identify wetlands and plan ought to be developed that includes further other environmental features for consideration characterization of the function of potentially during final footprint alignment and identification lost wetlands to wildlife and migratory birds, of construction laydown areas. A Wetland including those provincially listed that occupy Habitat Compensation Plan will be finalized to these areas. Other comments referred to a need replace the 16 ha of blue- and red-listed wetlands to examine the potential presence of Cryptic lost to the TMF through the implementation Paw Lichen in the project area. of compensation wetland sites that provide ecological functions equivalent to those of 4.8.5 Residual Effects the removed wetlands. The plan will follow Environment Canada’s mitigation hierarchy The loss and disturbance of vegetation framework to achieve no-net-loss to wetlands to communities, wetlands and cultural plants of the extent practical and will be based on a site terrestrial ecosystems will result in a change from survey and characterization of listed wetland baseline conditions with the permanent addition communities and their function as habitats for of the TMF, WRMF and Kitsault Pit lake on migratory birds and species at risk. Further the landscape. Complete restoration of baseline delineation of wetland compensation will be conditions after project closure is not possible undertaken through cooperation between the although the surrounding areas are expected to proponent and Environment Canada. Prior to the function in a similar manner prior to the Project. submission and implementation of the plan, the proponent will make reasonable efforts to consult Losses in the LSA after reclamation activities with the NLG and the Metlakatla First Nation. include 15 percent (35 ha) of large cedar trees, 1 percent (< 1 ha) of pine mushroom habitat, A site assessment survey will be undertaken 16 percent (193 ha) of ecosystems supporting within and near the mine footprint to determine medicinal plants, 13 percent (96 ha) of habitat the presence of Cryptic Paw Lichen and will supporting berry-producing plants, less than 1 ha

CEAA—Comprehensive Study Report: Kitsault Mine Project 47 of ecological communities at risk and 6 percent Appendix C, the Project is not likely to result (16 ha) of ecosystems considered as exhibiting in significant adverse environmental effects on medium and high potential to support species vegetation and plant communities. at risk. The TMF supernatant pond is expected to remain as an open water body resulting in 4.9 Land and Resource Use the permanent loss of 11 percent (195 ha) of baseline vegetation in the LSA. The Reclamation The effects assessment related to land and and Closure Plan will incorporate measures to resource use focused on the current use of lands integrate the new post closure WRMF, TMF and and resources for traditional purposes, trapping Kitsault Pit lake features with adjacent landscape and guide outfitting, cultural foods, and how the that is expected to function under pre-project environment effects of the Project might affect conditions, however, neither the losses in cedar these uses. The potential project-related effects trees or pine mushroom habitat will be lessened on land and resource use of the Nisga’a Nation by reclamation. are described and assessed in Chapter 7.

These localized residual effects occur once and are 4.9.1 Description of Baseline Environment considered low to medium in magnitude, long-term and reversible over many years. They have medium Current Use of Lands and Resources for ecological importance since changes in the baseline Traditional Purposes landscape and drainage directly influence the development and viability of ecosystems. The Metlakatla First Nation’s asserted territory overlaps with the proposed project footprint The probability of wetland loss is high in the TMF and with the proposed transportation corridor and WRMF area because the construction of these from Highway 16 to the mine site. During structures requires the clearing of vegetation and consultations with the Agency, the Metlakatla the draining and infilling of wetlands, including First Nation did not articulate any specific Patsy Lake. Following reclamation activities, land uses in the area of the mine and along the 77 ha (16 percent) of wetlands will still be lost in transportation corridors. However, existing the LSA (i.e., 36 ha reclaimed of 113 ha predicted information indicates that the Metlakatla First loss). The specific loss of Sitka-sedge – peat-moss Nation engages in hunting, trapping, fishing, and fen would be subject to wetland compensation gathering activities within their asserted territory activities as guided by Environment Canada. in and around the mine site. Given uncertainties associated with the potential loss of wetland function to birds and wildlife, Segments of the proposed transportation routes the residual effect is considered medium in both pass through the asserted traditional territories of magnitude and ecological importance. The long- the Kitsumkalum First Nation, Gitxsan Nation, term effect will be irreversible, localized to the Gitanyow Wilp Luuxhon, and the Gitanyow mine site, and occur within a discrete timeframe First Nation and through the Nass Area, NWA during construction of the mine. and Nisga’a Lands as defined by the NFA. The asserted territory of the Kitselas First Nation 4.8.6 Agency Conclusions lies outside the area of the Project; however, it was determined that project-related traffic along Based on the information in this report and with Highway 113 through Terrace and along parts the implementation of the mitigation measures of Highway 16 could affect the First Nation’s as described in this report and summarized in current use of lands and resources.

48 CEAA—Comprehensive Study Report: Kitsault Mine Project The Kitselas First Nation, Kitsumkalum First interests, marine water quality is important Nation, Gitxsan Nation, Gitanyow Wilp Luuxhon, for the continued Metlakatla First Nation and the Gitanyow continue to use areas along marine harvest. the transportation corridors for practicing the following traditional activities: The NFA specifies Nisga’a Nation rights to harvest marine resources, including fish, shellfish ••Hunting (moose, deer, grizzly bears, black bears, and intertidal bivalves. The maintenance of mountain goats, snowshoe hares, red squirrels, marine water quality is important to these and game birds) harvesting activities. The potential effects of ••Fishing (sockeye, pink, coho, chum, and Chinook the Project on Nisga’a Nation treaty rights of salmon, steelhead, rainbow trout, Dolly Varden, harvesting are assessed and discussed in and cutthroat trout) Chapter 5 of this report. ••Trapping ••Berry picking, medicinal plant gathering 4.9.2 Potential Environmental Effects and bark collecting In addition to the information contained in the Trapping and Guide Outfitting proponent’s EIS, the potential environmental effects of the Project on land and resource use The project footprint overlaps with one registered were also discussed by the TWG and through trapline (TR0614T088) that has been held since correspondence. 1994. Trapping activity is concentrated in the winter months and includes harvesting marten, The Agency’s assessment of potential effects mink, red squirrels, wolverines, black bears, specific to land and resource uses of the wolves, and beavers. The trapper also holds Nisga’a Nation is provided in Chapter 5. permits for trapline cabins near Clary Lake and Roundy Creek to harvest black bears, trout, and Current Use of Lands and Resources for berries. Eleven other trapline tenure areas were Traditional Purposes identified as overlapping with the RSA. Restricted access to the mine site is not expected The project footprint intersects a portion of the to block land-based access to Alice Arm for guiding tenure held by Coast Mountain Outfitters traditional use activities. However, access to the (also known as Milligan’s Outfitting), a non- portion of the Metlakatla First Nation’s asserted resident outfitting company that offers excursions territory that overlaps with the project footprint to observe and hunt different wildlife species and will be prohibited for purposes of public safety. fish in the Alice Arm area. Restricted access to this area may affect potential hunting, trapping and gathering activities of the Country Foods Metlakatla First Nation.

Marine resources are used by the Metlakatla The proposed transportation corridors from First Nation for food, social, ceremonial and the mine to Highway 16 (via Highway 113 or commercial purposes. Community members Highway 37) could increase non-Aboriginal locally harvest fish, shellfish, herring eggs, access and cause year-round land and resource oolichan, seal grease, berries and seaweed. use, particularly in winter where opportunities Oolichan and salmon are of particular importance exist for steelhead fishing, snowmobiling, trapping, to the Metlakatla First Nation’s economy, history, and hunting. Aboriginal groups expressed concern culture and seasonal activities. Considering these about potential effects to the declining moose

CEAA—Comprehensive Study Report: Kitsault Mine Project 49 population in the Nass Wildlife Area as a result anticipated considering the unlikelihood of life- of greater unregulated hunting and poaching that long, daily exposure to these contaminants. would come with winter access to areas of winter moose habitat along the Nass FSR. 4.9.3 Mitigation Measures

Trapping and Guide Outfitting Current Use of Lands and Resources for Traditional Purposes The trapper holding the registered trapline has expressed concerns about the potential effects Environmental management plans (EMPs) will to the trapline from increased access of a year- guide actions to mitigate effects on water and round open road, fur theft, increased harvesting sediment quality, transportation and access, fish of moose in the Clary Lake area, and the and fish habitat, vegetation, wildlife and their maintenance of access to the trapline taking habitat, and dust. Potential project-related effects into account safety issues. on the marine environment in Alice Arm will be managed and monitored as part of the MEMP, Local access restrictions around the Project could Groundwater Monitoring and Mitigation Plan affect access to the Coast Mountain Outfitter’s and Mine Site Water Management Plans. These guiding territory in the RSA. Noise, vibration and mitigation measures, which will be developed reduced aesthetics could disrupt the ambience in consultation with the NLG and Aboriginal and quality of the guiding and hunting experience groups, will help minimize the adverse effects near the mine. of the Project on the current use of lands and resources for traditional purposes. Country Foods Trapping and Guide Outfitting The human health risk from exposure to metals in cultural foods was a key concern examined An access management strategy for the mine site during the comprehensive study. A screening- will be developed in consultation with the local level human health risk assessment was trapper, Coast Mountain Outfitter Company, undertaken to estimate the maximum potential NLG, Aboriginal groups, and any other affected environmental exposure of project-related stakeholders, to manage public access to the mine contaminants to permanent Aboriginal residents area, prohibit hunting at the mine site, reduce in the LSA and RSA. No permanent residents possible wildlife-human conflicts and protect the were identified in the LSA and RSA; however, interests of wildlife-dependent land users. the proponent noted seasonal and temporary use of the areas. Country Foods

The potential exposure risks were modeled for Mitigation measures have been developed to individuals (babies and adults) who theoretically address a variety of effects relevant to cultural spend all of their time in the region and could foods, including the potential contamination potentially be exposed through direct contact of streams and fish, habitat loss, and the direct with soil, dust, and surface water, and the mortality or physical removal of animal and consumption of cultural foods. The assessment plant species. The MEMP will be designed to identified a potential for exposure to arsenic detect potential effects on ecosystem and human and molybdenum through human consumption health based on analyses of different marine of untreated surface water and terrestrial components including water chemistry, sediment plants. However, human health effects were not chemistry and toxicity, and tissue chemistry

50 CEAA—Comprehensive Study Report: Kitsault Mine Project (e.g., benthic invertebrates, intertidal fish, and cultural food consumed. Other comments focused shellfish). Human health issues and risks will be on including speciation analysis of seafood and analyzed and managed as part of the MEMP in other cultural foods (e.g., speciate inorganic accordance with the proponent’s human health risk arsenic in shellfish tissue) in monitoring programs framework. Results from the MEMP will be used and monitoring potential increases of cadmium to examine the effectiveness of mine mitigation and other contaminants in cultural foods. These and to determine whether additional mitigation or recommendations will be incorporated in the changes to the marine monitoring program would design of the proponent’s AEMP and MEMP. be required. 4.9.5 Residual Effects The proponent will also develop a communications procedure to inform concerned parties (e.g., Local The footprint of the mine site and associated Health Authority, Kitsault townsite) about any facilities will be inaccessible to any traditional health effect resulting from the Project. Measures activities, trapping and guide outfitting during would be developed in collaboration with the all phases of the Project. Land uses will cease in appropriate parties to identify and manage the the area of the Metlakatla First Nation’s asserted source of any potential exposure. traditional territory that overlaps with the proposed mine footprint. The area lost compared A Transportation Safety Plan will be implemented to the overall Metlakatla First Nation asserted that includes watering for dust suppression traditional territory is expected to be small and and identifying areas of high risk along the inadequate for land use purposes since it has transportation corridors that require additional already been disturbed by past mining activities barrier protection to minimize the potential effects (i.e., brownfield). Loss of this area is not on cultural foods resulting from road dust and expected to hinder the opportunity for Metlakatla accidental spills. First Nation members to use and access adjacent areas for their land use activities. Any further 4.9.4 Government, Aboriginal and clearing activities are anticipated to occur in Public Comments areas directly associated with construction and operations of the Project. Key issues related to land and resource use were associated with the potential effects of the Better road access due to winter snow Project on the marine environment and along ploughing and regular maintenance along the the proposed transportation corridors. These Forest Service Roads is predicted to increase issues include the potential effects on country vehicle-moose collisions and opportunities for food sources, land uses downstream of the mine unregulated hunting along these roads. Although site, and the regional moose population along implementation of mitigation measures will the proposed transportation corridors. Reviewers reduce the effects of project-related traffic on commented about the potential human health moose, the risk of moose mortality from the risk related to Nisga’a consumption of harvested cumulative effects of vehicular collisions and country foods exposed to concentrations of unregulated hunting along Highway 37 and the metals through soil and surface water. It was Nass Forest Service Road still remains. Efforts recommended that the proponent conduct a more to address these effects cannot be effectively detailed Nisga’a dietary survey (i.e., consumption managed by the proponent alone, but require rates, frequencies and portion sizes of cultural a coordinated multi-stakeholder approach that foods for different age and gender groups) and includes other proponents who are currently collect information on tissues from each type of using or are expected to use the same roads for

CEAA—Comprehensive Study Report: Kitsault Mine Project 51 transportation. The proponent will participate in deposition and transport zones in Alice Arm any cross-industry or government strategies related resulting from discharges from project-affected to road use adjacent to or intersecting moose watersheds (i.e., Lime Creek and Patsy Creek). habitat along the proposed transportation corridors. 4.9.6 Agency Conclusions The loss of 701 ha of area to the Project will result in a 0.03 and 3.3 percent reduction in the Based on the information in this report and with Coast Mountain Outfitter’s total guiding territory the implementation of the mitigation measures (2 680 823 ha) and the registered trapline holder’s as described in this report and summarized in total trap line (21 327 ha), respectively. Although Appendix C, the Project is not likely to result in most of the area lost overlaps the existing significant adverse environmental effects on land brownfield area where hunting and trapping is and resource use. limited, undisturbed areas adjacent to the mine site are considered more suitable for these land 4.10 Effects of Accidents uses. The disturbed area will be reclaimed after and Malfunctions mine closure when hunting and trapping activities are expected to resume. Under the former Act, an EA must consider the possible effects of accidents and malfunctions The potential remains for human exposure to that could adversely affect the environment at certain contaminants following mitigation, any stage of the Project from construction to including arsenic and molybdenum, through the post closure. Accidents and malfunctions have consumption of country foods in Lime Creek the potential to occur throughout the life of the and Alice Arm. As discussed in Sections 4.2 Project from mine site construction through to and 4.6, historical mining activities may have post closure. contributed to the existing elevated levels of these contaminants in water and sediments, The proponent will include consideration of which could affect freshwater and marine accidents and malfunctions in its Mine Emergency resources, including fish and shellfish. Actual and Spill Response Plan, which is a component of exposures to potentially contaminated cultural their Environmental Management System. foods are considered unlikely as there are no permanent residents and low numbers of The following potential malfunctions and temporary or seasonal users in the LSA. As such, accidents were identified: the risk of health effects from direct exposure to affected soil, dust, surface water and country ••fuel releases during truck transport foods is minimal. ••fuel releases from storage facilities and dispensing areas Based on these considerations and the ••motor vehicle accidents (non-hazardous and environmental effects assessments for freshwater hazardous materials) water quality, fish and fish habitat, and other ••chemical spills within contained facilities valued components, the residual effects to land ••release of sewage effluent and resource use are expected to be low in ••seepage containment pond failure magnitude, local to regional in extent, long-term, ••explosives accidents continuous and reversible except in the case of ••power outages potential exposures to contaminated country foods. ••failure of the TMF dam The effects would be localized to the harvest of ••pipeline leakage (water and tailings lines) resources in Lime Creek and nearby sediment ••failure of waste rock or overburden stockpile

52 CEAA—Comprehensive Study Report: Kitsault Mine Project ••release of metal leaching and acid rock drainage 4.10.3 Agency Conclusions ••fires associated with the Project ••chronic emissions (vehicle and incinerator) Based on the proposed operating, contingency and emergency response procedures, the measures Appendix D summarizes data on potential in the Geographic Response Plan and the malfunctions and accidents, the likelihood of implementation of the mitigation as described their occurrence, their possible environmental in this report and summarized in Appendix C, effects, preventative mitigation measures, and the Project is not likely to result in significant contingency and emergency response procedures. adverse environmental effects as a result of accidents and malfunctions. 4.10.1 Mitigation Measures 4.11 Effects of the Environment Measures specified in the Mine Emergency and on the Project Spill Response Plan and Geographic Response Plan are expected to deliver the necessary Under the former Act, and as part of the training and hazardous material spill response evaluation of effects, an EA must consider the strategies that will address concerns raised by potential effects the environment may have on government agencies, the NLG and Aboriginal the Project. The Agency considered the following groups regarding accidents and malfunctions environmental conditions that are the most likely along the transportation corridors. These to impact the Project: measures will also include the identification of appropriate forms of barrier protection along ••forest fires areas of the proposed transportation corridors ••geo-hazards with high aquatic values (e.g., fish) that could be ••seismic events at risk from spills of hazardous materials. The ••weather events proponent will make reasonable efforts to consult with the NLG and Aboriginal groups about these Increased industrial activity in the area could areas before approval by provincial ministries. lead to a higher risk of fire. The proponent will delay project activities during periods of high 4.10.2 Government, Aboriginal and fire risk, administer a fire training program for Public Comments employees and implement a fire response plan that includes working with the B.C. Ministry of Aboriginal groups expressed concerns about the Forests, Lands and Natural Resource Operations potential effects of accidents and malfunctions (BC MFLNRO) on an ongoing basis. All actions along the proposed transportation corridors, to manage the risk of forest fires are expected to particularly spills of chemicals and fuel into comply with the provincial Forest Fire Prevention important water bodies and environmentally and Suppression Regulation. sensitive areas. There is evidence of landslide activity near the Aboriginal groups also stated the need for more project area, with the highest risk of landslides coordination for training and operation of spill predicted along the steep, gullied terrain located response stations located along the transportation next to Patsy Creek and Lime Creek. No project corridors. In response, the proponent will develop infrastructure is expected to be situated in these the Geographic Response Plan to coordinate areas. The Coarse Ore Stockpile is situated training and spill response approaches between the close to the edge of the lava flow plateau with BC MOE and community members responsible for a conveyor (1.4 km) spanning up the cliff face spill response activities. of the lava flow (290 m elevation change)

CEAA—Comprehensive Study Report: Kitsault Mine Project 53 that traverses unstable areas on the cliff face 4.12 Capacity of Renewable escarpment. Any weakening of the toe of the Resources slope could lead to a higher risk of landslides; however, the project design incorporates Under subsection 16(2) of the former Act, a appropriate setbacks to minimize any potential comprehensive study shall address the capacity damage to project infrastructure. The proponent of renewable resources that are likely to be will also secure all potentially unstable slopes significantly affected by the project to meet prior to the start of construction activities and present and future needs. Renewable resources will monitor road use to identify, remove or within the project area include wildlife, aquatic stabilize any possible snow hazards. No major resources, and vegetation and plant communities, snow avalanche paths have been identified as which were assessed in detail as part of the EA. slope steepness in the area (i.e., 4° to 26° slope Significant adverse effects to these resources are angles) is not conducive to avalanche formation not anticipated. (i.e., 25° to 45°). Mineral resources are defined by such factors as All building and structure designs, such as the commodity pricing and mineral access. Under TMF, will meet anticipated flood and seismic certain circumstances, the development of a requirements to withstand any future potential given deposit could lead to future developments seismic events. The TMF has been designed to associated with that same deposit, or it could meet all current Canadian Dam Association Dam provide infrastructure that would improve the Safety Guidelines and specifications to withstand economic feasibility for other developments in extreme events, including a 10 000-year return the area. period earthquake event. 4.13 Cumulative Effects Assessment Variations in weather trends, such as precipitation, wind, temperature, atmospheric Cumulative environmental effects are defined pressure and humidity could potentially affect as the effects of a project that are likely to result the Project. Uncertainties in long-term weather when a residual effect acts in combination with patterns will be addressed through appropriate the effects of other projects or activities that project design and adaptive response measures. have been or will be carried out. For example, supply and mine haul roads are expected to be maintained during heavy 4.13.1 Approach snowfalls to allow for passable access while hot and dry conditions may require road watering The approach used by the Agency to assess and measures to guard against fires caused by the cumulative environmental effects of the lightning strikes or by construction activities. Project was guided by the Agency’s Operational Policy Statement (2007) and Cumulative Effects 4.11.1 Agency Conclusions Assessment Practitioner’s Guide (1999).

Based on the proposed mitigation strategies, The cumulative effects assessment (CEA) design criteria and adaptive response plans considered the effects of past, present, and future and the mitigation measures as described in activities and projects that will overlap spatially and this report and summarized in Appendix C, temporally with the residual environmental effects significant adverse effects of the environment of the Project. Emphasis was placed on cumulative on the Project are not likely. environmental effects arising from activities or projects that are certain or reasonably foreseeable.

54 CEAA—Comprehensive Study Report: Kitsault Mine Project The other projects and activities considered in Table 4-7 were identified as overlapping either the cumulative environmental effects assessment spatially or temporally with the Project, thereby were identified through a review of available having the potential to cause changes to the information on historical land use, existing biophysical or socio-economic environments (active) projects and land use activities, and when occurring in combination with the Project. reasonable foreseeable projects within the study area. The projects and activities summarized in

Table 4-7: Activities and Projects Included in the Cumulative Effects Assessment • Mineral exploration ••Alice ••Historical Kitsault Mine ••Silver Cord ••Illy Mine ••San Diego ••Macy Mine ••Tiger ••Esperanza Mine ••Kitsol ••Wolf Mine ••Wolf Historical land use ••Tidewater Mine ••Moose-climax ••La Rose ••Victory ••Dolly Varden Mine ••Robin ••North Star Mine ••Vanguard Cooper ••Torbrit Mine ••Sault ••Keystone • Kitsault Resorts Ltd. • Community of Alice Arm • Mineral exploration ••Roundy Creek ••Bell Moly • Nisga’a Nation hunting, trapping, fishing and other uses Current and future land use • Transportation and access • Trapping and guide outfitting • Fishing • Water licenses • Aboriginal hunting, trapping, fishing and other uses Reasonably foreseeable • KSM Mine Project projects • Northwest Transmission Line

4.13.2 Potential Cumulative Effects

The EA focused on VCs where residual effects ••wildlife and wildlife habitat (i.e., adverse environmental effects that will ••land and resource use likely persist after mitigation measures are applied) from the Project may act in combination The potential cumulative environmental with past, current, and reasonably foreseeable effects resulting from project-related residual activities and projects. The following VCs were environmental effects overlapping with the considered: residual environmental effects of other activities and projects are summarized in Table 4-8. ••surface water quality ••fish and fish habitat ••marine aquatic resources

CEAA—Comprehensive Study Report: Kitsault Mine Project 55 Table 4-8: Cumulative Effects from Past, Present and Reasonably Foreseeable Projects and Activities Valued Residual environmental effects of Potential cumulative environmental effects Component the Project • Changes in surface water quality in • Interaction with the residual effects of past mining activities the Lime and Patsy Creek watersheds and past development of the Kitsault townsite. These Surface Water due to surface runoff and seepages effects are reflected in the baseline data that inform the Quality • Changes in sediment quality in Lime proponent’s assessment and mitigation planning. Creek and Clary Creek • Interaction with residual sediment quality effects from historical mining Dolly Varden and coho salmon • Interaction with the residual effects of previous mining operations and mineral exploration in the Alice Arm area, • Changes to surface water quality (i.e., exceedances of BC WQGs and including tailings deposition and waste rock dumps that CWQGs) in Lime Creek affect water quality in streams frequented by Dolly Varden • Changes to stream flows and water and coho salmon temperature in Lime Creek • Interaction with the residual effects of the former Kitsault Mine on rainbow trout in Clary Lake, including fish mortality • Changes in the BMI community in lower Lime Creek by entrainment • Interaction with the residual effects on Dolly Varden and Rainbow trout coho salmon associated with habitat alteration of lower Lime Creek resulting from channelization and armouring • Loss of fish habitat under the TMF when the Kitsault townsite was constructed Fish and Fish • Stream flow reductions in the Clary • Interaction with potential water quality and streamflow Habitat Creek watershed effects resulting from future exploration of the Bell Moly • Changes to lake levels in Clary Lake deposit in the Clary Creek watershed and from the Roundy and Lake 901 Creek deposit in the Roundy Creek watershed. These changes may affect Dolly Varden and coho salmon moving from Lime Creek into these watersheds and rainbow trout moving within the Clary Creek watershed. • Interaction with the residual effects from angling, where Nisga’a Nation anglers holding guide tenures specified under the NFA for the Illiance and Kitsault Rivers, may capture Dolly Varden and coho salmon parr moving from Lime Creek into either river and remove these fish from the pool of potential Lime Creek spawners • Residual effects are not predicted for • Interaction with recreational fishing in Alice Arm by non- the marine environment guided recreational fishermen Marine Aquatic • Interaction with the residual effects of previous mining Resources operations and mineral exploration in the Alice Arm area, including tailings deposition in Alice Arm • Loss or alteration of wildlife habitat • For the residual transportation effects only, interaction • Disruption of wildlife movement from of project-related traffic with anticipated traffic from the siting of mine infrastructure following projects: • Sensory disturbance causing wildlife ••Northwest Transmission Line displacement and alteration of ••KSM Mine Wildlife and movement patterns ••Schaft Creek Mine Wildlife Habitat • Wildlife mortality due to vegetation ••Galore Creek Mine clearing, attraction to site, vehicle ••Morrison Mine collisions, and winter access along the ••Red Chris Mine Nass FSR that increases the potential ••Kutcho Creek Mine for unregulated hunting

56 CEAA—Comprehensive Study Report: Kitsault Mine Project Table 4-8: Cumulative Effects from Past, Present and Reasonably Foreseeable Projects and Activities continued • Reduction or removal of access • Interaction with the effects of mineral exploration, local and to trapping and guide outfitting regional traffic linked to other land uses, and shared use of opportunities the proposed transportation corridors with other projects • Effects to wildlife populations linked to • Interaction with traffic to and from Kitsault Resorts and Alice greater winter access along the FSRs Arm community, with trapping and guide outfitting activities Land and (i.e., wildlife-vehicle collisions and in the region, and with Nisga’a Nation use Resource Use increased hunting pressure) • Interaction with effects of past mining activities on • Increased access along the country foods transportation routes servicing the mine • Potential human health risk from exposure to metals in country foods

4.13.3 Government, Aboriginal and phases of the Project. Water quality conditions Public Comments in Lime Creek and Alice Arm will be monitored and analysed as part of the AEMP and MEMP for During the review of the EIS, BC EAO and any effects that may arise from the Project. With members of the TRWG requested that the proponent successful implementation of the Mine Site Water revise its cumulative effects assessment to include Management Plan, the cumulative environmental other potential projects that could utilize Hwy 37. effects on water quality are expected to be low. The proponent incorporated the anticipated traffic of other existing and planned projects in the Fish and Fish Habitat assessment of cumulative effects of transportation on wildlife, in response to this concern. The historical and current land use and reasonably foreseeable projects that could interact with the 4.13.4 Summary of Cumulative Project’s residual effects on fish and fish habitat Environmental Effects include past mining activities at the historical Kitsault mine, reconfiguration of lower Lime Surface Water Quality Creek during construction of the Kitsault townsite, commercial and recreational fishing, and ongoing Historical Kitsault Mine activities and effects on exploration activities at the Bell Moly deposit. surface water quality overlap with project-related These projects have resulted in the loss of fish effects. The historical mine is currently in the habitat and a decline in water quality. post closure phase, having completed provincial reclamation requirements. Water quality in Lime The proponent’s Mine Site Water Management Creek is currently influenced by past mining Plan is predicted to achieve water quality structures that remain onsite, including the Patsy conditions in Lime Creek for protecting aquatic and Clary waste rock dumps and the Kitsault life. A conceptual FHCP has been prepared that Pit. Ongoing and increasingly significant effects describes ways to offset the potential loss of fish could be expected over time due to ML/ARD of habitat productivity associated with the Project. waste rock, if left unmanaged. The adverse residual environmental effects on fish and fish habitat will be offset by the FHCP, Taking account of the residual effects of the and long-term cumulative effects between the historical Kitsault Mine, the proponent has Project and other past, present or future projects developed a comprehensive Mine Site Water on the fish and fish habitat are not expected. Management Plan that includes measures to meet BC WQG, and water treatment during all

CEAA—Comprehensive Study Report: Kitsault Mine Project 57 Wildlife and Wildlife Habitat make similar efforts to managing the cumulative road use effects on wildlife and human safety in Cumulative environmental effects related to the region. increased vehicular traffic of the Project has the potential to interact in combination with the Lands and Resource Use potential transportation effects from past, present and reasonably foreseeable projects. The spatial boundary for the cumulative effects assessment of Current Lands and Resources Moose and grizzly bear mortality from vehicle Use for Traditional Purposes is defined by the collisions associated with year-round access to approximate boundaries of the asserted traditional the network of FSRs will act cumulatively with territories of each Aboriginal group. The potential the residual road use effects of other projects cumulative effect on land and resource use is a and activities along the Nass FSR (Cranberry change to current traditional use patterns. Connector) and Highway 37. An increase in winter road traffic along these roads resulting from Residual effects on current land and resource cumulative road use in the region is expected to use from the activities and projects identified increase the risk of mortality to moose and grizzly in Table 4-8 have the potential to overlap with bears. The mortality risk to moose is further the residual effects of the Project. Ongoing complicated and compounded by ongoing illegal exploration projects (e.g., Keystone, Alice) near and unregulated moose harvesting by Aboriginal Alice Arm and two prospective developments, communities. Bell Moly and Roundy Creek, could further disturb resources (e.g., wildlife, vegetation, and A suite of transportation safety measures has been aquatic resources) and limit areas for traditional developed to minimize the effects of project- harvesting activities, while traffic from the related road use on wildlife and human safety. Project, regional exploration activities and local However, reducing the cumulative effects to the road use could increase access into and affect regional moose and grizzly bear populations existing traditional land use areas. Mitigation would require a coordinated regional planning measures have been developed for the Project approach involving all applicable road users. that will reduce any cumulative effects with Government examination of feasible solutions respect to these uses. Other planned and future to address other underlying causes of moose projects and activities within the RSA that could mortality (i.e., increased enforcement against potentially affect traditional lands and resources illegal and unregulated hunting) is ongoing and will be required to develop similar mitigation local conservation initiatives for moose have been measures, which would further minimize the integrated into regional resource management cumulative effects on these lands and resources. plans. In supporting these initiatives, the proponent will: 1) participate in cross-industry, government The potential residual effects of the Project strategies or planning exercises to address road on country foods will overlap with the use effects on moose habitat along the proposed residual effects of past mining activities at transportation corridors; 2) exchange traffic the historical Kitsault Mine and in Alice Arm, and wildlife and human accident data with including tailings deposition in Lime Creek. other proponents; and, 3) participate in regional The significance of the cumulative risk of cumulative effects assessments related to traffic human exposure to metals in country foods is along Highway 37 and Highway 113. Proponents low considering the absence of any permanent of planned and future projects are expected to also residents in the LSA that could be subject to daily, life-long consumption of country foods and

58 CEAA—Comprehensive Study Report: Kitsault Mine Project the availability of the country foods in the RSA. In addition, the proposed mitigation measures are expected to minimize any residual water quality effects in Lime Creek and Alice Arm. 4.13.5 Agency Conclusions

Based on the information in this report and with the implementation of the mitigation measures as described in this report and summarized in Appendix C, the Project is not likely to result in significant adverse cumulative environmental effects.

CEAA—Comprehensive Study Report: Kitsault Mine Project 59 5. Nisga’a Nation Effects Assessment

The Project is subject to the NFA because of the In addition to the EA decision statement, potential effects of the Project on residents of the Minister of the Environment will issue a Nisga’a Lands, Nisga’a Lands or Nisga’a Nation NFA Project Recommendation as to whether interests. In accordance with Chapter 10 of the the project should proceed in light of NFA NFA, the Agency assessed 1) whether the Project considerations. Any subsequent permitting or can reasonably be expected to have adverse approval decisions by responsible authorities environmental effects on residents of Nisga’a must take both the EA decision and the NFA Lands, Nisga’a Lands, or Nisga’a interests set out Project recommendation into account. in the NFA (paragraph 8(e) of Chapter 10) and 2) the effects of the Project on the existing and 5.1 Assessment of Environmental future economic, social, and cultural well-being of Effects (8e of NFA Chapter 10) Nisga’a citizens (paragraph 8(f) of Chapter 10). 5.1.1 Lands To meet the obligations under the NFA, Canada incorporated the NFA factors (i.e., 8(e) and 8(f)) Among other things, Chapter 3 of the NFA into the federal comprehensive study of the Project. describes Nisga’a Lands and sets out the nature The 8(e) effects were examined using information of Nisga’a Nation ownership of Nisga’a Lands, and analyses generated by the EA process. The and Nisga’a Fee Simple Lands (Category A approach used to assess the effects to the economic, Lands and Category B Lands), which are situated social and cultural well-being of Nisga’a citizens outside of Nisga’a Lands. The Nisga’a Lands was developed in close cooperation with the NLG comprise approximately 2 000 km2 around the and B.C. It was informed by the proponent’s lower Nass Valley. The NFA also sets out that the ESCIA and related documents, as well as issues Nisga’a Nation owns the mineral resources on raised by the NLG, B.C., Canada and the proponent and under Nisga’a Lands. throughout the EA. The Project is situated within the Nass Area and The approach to assessing NFA factors and the NWA defined by the NFA, but falls outside the subsequent analysis of effects involved of Nisga’a Lands, which are located 25 km east several federal departments with expertise in of the mine site. Ten kilometres of the Kitsault pertinent areas. These include Fisheries and FSR overlap with the Nisga’a Lands while Oceans Canada, Natural Resources Canada, the transportation corridor proposed along the Environment Canada, Health Canada, Canadian Nisga’a Highway to Terrace intersects 25 km of Heritage and Aboriginal Affairs and Northern Nisga’a Lands and 25 km of the NWA. The other Development Canada. The expert advice from proposed transportation corridor along the Nass these departments contributed to the Agency’s FSR and south on Highway 37 to Kitwanga is assessment of NFA factors. expected to encompass 75 km of the NWA.

The following sections describe the outcomes of Chapter 3 of the NFA also sets out the Nisga’a the assessment of NFA factors examined during Nation’s commercial recreation tenure, provincial the EA, including comments from the NLG, and heritage sites and key geographic features, the Agency’s conclusions on the potential effects the Nisga’a Memorial Lava Bed Park, and the of the Project on Nisga’a Nation interests defined Gingietl Creek Ecological Reserve. The Project in the NFA. is located 5 km southeast of Gits’oohl that are Fee Simple Category A lands under the NFA.

60 CEAA—Comprehensive Study Report: Kitsault Mine Project Agency Conclusions

The Project will be constructed and operated In addition to the EA on lands that will not be publicly accessible for Nisga’a citizens to undertake activities pursuant decision statement, the to their treaty rights under the NFA. The mine footprint will remove the potential value of a Minister of the Environment portion of the NA and NWA as a location to carry out such activities in the future. Land- will issue a NFA Project based and aquatic resources such as wetlands, lakes and forests will be either removed or Recommendation made inaccessible in the immediate mine site area. However, the general availability of such resources in the areas adjacent to the Project footprint is not expected to diminish and alternative locations to exercise Nisga’a Adjacent to these lands is a parcel of land that is Nation rights under the NFA may exist in close Nisga’a Nation commercial recreation tenure. proximity. While the locations of land use practices will be restricted to areas outside the Potential Effects of the Project project footprint, it is expected that Nisga’a citizens will be able to continue to exercise To ensure public safety, the proponent will their treaty rights as defined by the NFA. maintain a 500 m buffer around the mine site that Residual effects on land use will, as appropriate, will be restricted to only mine-related activities be addressed through the development and during the life of the Project. Non-project land use implementation of the Social and Cultural activities, including activities that would otherwise Management Plan. be carried out pursuant to Nisga’a interests as set out in the NFA, would be prohibited within 5.1.2 Access the buffer area. With the mine footprint and buffer covering a total area of 1 980 ha and the NWA and Chapter 6 of the NFA includes provisions for access the NA spanning 1 610 100 ha and 2 700 000 ha, onto and through Nisga’a Lands for public, private respectively, the proponent expects that 0.07 percent and federal and provincial government land and of the NA and 0.12 percent of the NWA will not be resource use. The Chapter also describes public available for use by Nisga’a citizens or other users. access to Nisga’a Public Lands for temporary non-commercial and recreational purposes and Mitigation Measures for hunting and fishing. Provisions in the Chapter also cover Nisga’a citizens’ access to Crown lands No measures are proposed to mitigate the loss outside Nisga’a Lands. of use of those portions of the NA and the NWA restricted for active mining during the life of the Chapter 7 of the NFA describes the ownership, Project. The proponent will work with the NLG administration and control of roads, their corridors to accommodate the inability of Nisga’a citizens (if applicable) and rights-of-way within Nisga’a to carry out activities specified in the NFA in Lands. These provisions affect the Nisga’a these areas through the Social and Cultural Highway, Nass FSR and Alice Arm FSR. The Management Plan. More details on this plan Chapter includes a section that sets out that B.C. are found in Table 5-2. will consider extension of Highway 37 in line with

CEAA—Comprehensive Study Report: Kitsault Mine Project 61 provincial priorities and B.C.’s long-term goal Agency Conclusions of completing that extension. It also includes a section that sets out that the Nisga’a Nation will The proponent’s proposed use of the existing grant a right of way to B.C. or a public utility for network of FSRs and provincial highways, secondary provincial roads. Chapter 7 also sets including the upgrade of the Nass FSR to out that B.C. may have access to areas outside Highway 37, is not expected to result in adverse of the Nisga’a Highway corridor and secondary environmental effects on Nisga’a Nation’s treaty road right of ways on Nisga’a Lands subject to rights to access Nisga’a Lands and other lands requirements set out in the Chapter. as set out in Chapter 6 of the NFA. Improved access may benefit the Nisga’a Nation as Nisga’a Potential Effects of the Project citizens are able to pursue land use and cultural activities on a year-round basis. The proponent predicts that year-round maintenance activities associated with the 5.1.3 Water proposed transportation corridors, particularly the network of FSRs will create land use effects Chapter 3 of the NFA establishes the Nisga’a related to access. As the holder of a provincial Nation’s water reservation of 300 000 decametres Special Use Permit for the roads from the per year from the Nass River and other streams mine site to the Nass FSR at Highway 113, the wholly or partially within Nisga’a Lands, for proponent is responsible for maintaining these domestic, industrial and agricultural purposes. roads during the winter and spring. The Nisga’a Nation was issued an angling guide license for 15 rivers outside Nisga’a Lands, Greater access along the transportation corridors including the Illiance River and the Kitsault is expected to enhance Nisga’a citizen access River, both of which are close to the mine site. to areas for pine mushroom picking, hunting, snowmobiling, fishing and trapping. The location Maintaining the hydrology of local water bodies, of the mine site is predicted to not hinder land- particularly the Illiance River and Kitsault based access to Alice Arm. Access to and use of River, is essential to protect fish stocks, marine different land use sites along the Nass FSR and ecosystems and aquatic plants that are important Hwy 113, however, could be impeded due to to the Nisga’a Nation. Changes to flow volumes vehicular accidents and spills during the Project. can also affect surface water quality, which, in turn, can have implications for human health and Mitigation Measures the health of fish and wildlife that the Nisga’a Nation harvests for subsistence. The ploughing of otherwise inaccessible roads in the winter and the grading and management Potential Effects of the Project of vegetation along the road right of ways in the spring are expected to provide Nisga’a citizens Three rivers located partially within Nisga’a with improved access for land use and to cultural Lands–Kwinatahl, Tchitin, and Kshadin Rivers–are sites in the NA and NWA. Where normal public close to either the mine site or the access road. The access is restricted, the proponent is expected to Kwinatahl River is the closest, flowing 2 km from provide reasonable alternative access that enables the mine site. The Project is not predicted to affect Nisga’a citizens to exercise their treaty rights as water bodies outside the LSA and RSA, including per the NFA. the Kwinatahl, Tchitin, and Kshadin Rivers. The proponent is required to implement measures to mitigate water quality effects and effects associated with accidents or spills.

62 CEAA—Comprehensive Study Report: Kitsault Mine Project Water management measures and structures will plants for domestic use (i.e., food, ceremonial control and contain water-related effects within and social), and barter or trade fish and aquatic the local mine site footprint. Potential effects plants harvested in Nisga’a fisheries, subject are confined to the Lime, Patsy, and Clary Creek to conservation and laws for public health and watersheds and Illiance River watershed, all of safety. Nisga’a citizens are also entitled to harvest which drain into Alice Arm and are located within wildlife fish pursuant to their right to harvest the Nass Area, but not Nisga’a Lands. As these wildlife as defined in Chapter 9 of the NFA. watersheds drain directly into Alice Arm, they are not expected to influence water quality or stream The Nisga’a Nation, B.C. or Canada may propose flow in the Nass River or Kitsault River. the establishment of Nisga’a fish allocations for non-salmon species or aquatic plants. According Accidents or spills may occur along the proposed to paragraphs 11 and 12 of the Nisga’a Annual transportation corridors transecting the NA and Fish Plan, fishing, other than for intertidal NWA, which could affect nearby water bodies. bivalves and oolichans, is restricted to the NA. Under the Harvest Agreement, additional pink Mitigation Measures and sockeye salmon allocations are set out and Nisga’a citizen may sell salmon harvested under Since project-related activities are not expected to this agreement. extend to the Nass River and other water bodies referenced in Chapter 3 of the NFA, no mitigation Under Chapter 8, paragraph 64, Nisga’a citizens measures have been proposed by the proponent have the right to harvest intertidal bivalves for for these particular rivers. However, the proponent domestic purposes within those portions of the has developed the Mine Emergency and Spill NA set out in Appendix I of the NFA. Intertidal Response Plan and the Geographic Spill Response bivalves are defined in Chapter 1 as littleneck Plan to address the potential risks of accidents or clams, butter clams, horse clams, cockles, spills associated with road use. mussels and manila clams.

Agency Conclusions The closest boundary of the intertidal bivalve harvest area identified in Appendix I of the While mine-related activities are expected to affect NFA is located approximately 15 km southwest water resources in the Lime, Patsy and Clary of the Project, near the entrance to Alice Arm Creek watersheds, these effects do not extend to in Observatory Inlet. Nisga’a citizens harvest or affect the water bodies specified in Chapter 3 intertidal bivalves in Alice Arm even though of the NFA. The EA identified and evaluated the Appendix I of the NFA does not identify intertidal potential for water-related effects resulting from bivalve harvest areas near the Project’s marine accidents or spills along the proposed transport receiving environment in Alice Arm at Lime corridors. Following the implementation of Creek estuary, or near the Kitsault and Illiance mitigation measures related to spill response, River estuaries at the head of Alice Arm. speed limits and road side barrier protection, adverse environmental effects to local water Potential Effects of the Project bodies from accidents or spills are not expected. Sections 4.5 and 4.6 of this report assessed VCs 5.1.4 Fisheries for fish and fish habitat in both freshwater and marine aquatic environments. Findings from Chapter 8 sets out the Nisga’a Nation right to these assessments indicate that the Project has the fish and fisheries allocation entitlements. Nisga’a potential to affect fish and fish habitat as a result citizens have the right to harvest fish and aquatic of changes in water quality and quantity, physical

CEAA—Comprehensive Study Report: Kitsault Mine Project 63 habitat loss and effects caused by accidents and (e.g. shellfish, sculpins and other marine fish malfunctions along the proposed transportation species) in the Lime Creek estuary that in corridors. More details on the project-related turn could affect other marine biota through effects to water quality, water quantity, and fish ecosystem trophic interactions with marine and fish habitat are provided in Sections 4.2, 4.3, biota in Alice Arm. 4.5, and 4.6, respectively. In Alice Arm, potential marine environmental The lower section of Lime Creek, extending 1.8 km effects include increased concentrations of metals upstream from the estuary in Alice Arm to an in sediment, benthic organisms and fish tissue. 8 m high waterfall (barrier to fish migration), Marine sediment and shellfish tissue in Alice Arm which is 6 km downstream of the mine site currently exhibit elevated metal concentrations, effluent discharge into Lime Creek, provides likely due to historical tailings deposition from marginal fish habitat for Dolly Varden char and previous mining operations in the area. coho salmon parr. No fish were found above the barrier. Potential changes to surface water A risk assessment based on the potential for quality have the potential to affect Dolly Varden accidents or malfunctions along the transportation and coho salmon including mortality of fish and corridors concluded that spills of chemicals eggs. Details on the assessment of project-related or fuel near water bodies could affect aquatic effects on Dolly Varden and coho salmon are organisms, including fish. While the assessment provided in Section 4.5 of this report. predicted a low likelihood of spills from transportation accidents, the environmental Killam Lake, which is confluent with the Clary damage may be moderate to high depending on Creek watershed, was stocked with rainbow trout the size of the spill and the water body affected. fry and yearlings by provincial agencies between 1988 and 2003. Rainbow trout are the only fish Mitigation Measures species in the Clary Creek watershed and the potential effects of the Project on this fish species A complete discussion of the water quality are limited to the reach of Clary Creek upstream and quantity mitigation measures is provided of a large impassable waterfall (>30 m in height) in Sections 4.2 and 4.3. located near the confluence of Clary Creek and the Illiance River. Development of the Project Water quality in lower Lime Creek is expected would result in the harmful alteration, disruption to be protective of aquatic life over the life of or destruction of rainbow trout spawning habitat the Project, following implementation of water in a portion of the Clary Creek watershed that management measures and water treatment. The affects two inlet tributary streams to Lake 901: Mine Site Water Management Plan will include Streams 76800 and ILP 887. The lower section strategies for water treatment, erosion and of Clary Creek downstream of the Clary Creek seepage control, water recycling, monitoring, and Illiance River confluence provides habitat and water diversion. Surplus water from the for steelhead (anadromous rainbow trout), coho TMF will be treated prior to discharge into Lime salmon, Dolly Varden and other fish species of Creek, with the purpose of maintaining water interest to the Nisga’a Nation. No effects on areas quality and flows that will protect aquatic life. downstream of Clary Lake are expected. The proponent will design the Project to enable Water quality changes in Lime Creek during water treatment and ensure water quality at operations have the potential to affect marine LC1, LC2 and Lake 901 meet BC WQGs or water and sediment quality and aquatic life Site Specific Water Quality Objectives approved by BC MOE.

64 CEAA—Comprehensive Study Report: Kitsault Mine Project Residual effects to fish habitat in the inlet tributaries predicted levels show an improvement over of Lake 901 will require the development and current water quality conditions (i.e., reduced implementation of a FHCP to offset losses of concentrations) in lower Lime Creek where fish bearing habitat. The plan, to be finalized in cadmium greatly exceeds BC WQGs along with consultation with the NLG, is required by DFO to exceedances of other parameters. provide no net loss or a net gain of the productive capacity of fish habitat affected by the Project The proponent will ensure that water quality in prior to the issuance of an authorization under Lime Creek will meet BC WQGs or site-specific the Fisheries Act. More information can be found water quality objectives approved by the BC in Section 4.5. MOE. Potential residual effects to the marine environment in Alice Arm are not predicted given The monitoring programs related to aquatic the mitigation of project-related effects to water effects and to the marine environment (AEMP quality, stream flows and aquatic life in lower and MEMP) will be implemented, based on a Lime Creek. conceptual framework that has been developed in collaboration with the NLG, Metlakatla First Future monitoring of the marine environment Nation, and federal and provincial authorities. in accordance with the MEMP will identify and These monitoring programs are designed to determine the extent of any unforeseen residual detect potential project-related effects, and project effects on marine resources, including fish include adaptive management responses to ensure and shellfish. Both the AEMP and MEMP will impacts to the freshwater and marine environment be centred on baseline information from which are mitigated. Analysis and management of human future effects can be appropriately assessed, health issues and risks will be undertaken as part including water chemistry and toxicity and of the AEMP and MEMP as per the framework fish tissue analysis. The final details of these developed by the proponent. monitoring programs will be undertaken during the permitting phase with government agencies, Strategies in the Transportation Safety Plan the NLG and Aboriginal groups. and Geographic Response Plan are expected to address the potential effects on fish As for potential road use effects on fish, the from accidents and malfunctions along the proposed transportation corridors pass through transportation corridors (e.g., spills of process areas of sensitive fish habitat and along riparian chemicals and fuel into waterways), while areas including the Nass River, which is an coordinating the delivery of training and spill important fish bearing river to Nisga’a Nation response among provincial authorities and and local communities. Transportation safety community members responsible for spill and emergency and spill response measures will response activities. be established to manage, with the cooperation of the NLG and Aboriginal groups, the potential Agency Conclusions effects of a spill on nearby fish populations along the transportation corridors. With the implementation of the Mine Site Water Management Plan that includes measures for Residual adverse environmental effects to fish water management and water treatment for each and aquatic life in Lime Creek and Clary Creek phase of the Project, the resulting water quality watersheds may occur following implementation for all parameters is expected to meet BC WQGs of mitigation measures. As noted in Section 4.5.5, except for cadmium, sulphate and aluminum. As these effects are not expected to be significant, shown in Appendix F, although these exceedances however, they have the potential to adversely are expected to persist after mitigation, their affect Nisga’a Nation treaty rights and fisheries

CEAA—Comprehensive Study Report: Kitsault Mine Project 65 interests as set out in Chapter 8 of the NFA. remote location of the Project, displacement of Residual effects will be addressed through the moose further away from Nisga’a Lands could implementation of the AEMP, MEMP and FHCP. pose access issues for Nisga’a harvesting of moose. The Project will also displace grizzly 5.1.5 Wildlife and Migratory Birds bears from the immediate area and disrupt their movement to habitat areas near the mine site. Under Chapter 9 of the NFA, Nisga’a citizens have the right to harvest, for domestic purposes, Clearing of forested area has the potential wildlife in the NWA and migratory birds within to remove forage and wintering habitat for the Nass Area, subject to measures necessary for American marten and migratory bird breeding conservation, public health and safety legislation. habitat for Olive-sided Flycatcher, Northern Nisga’a citizens’ harvesting of wildlife and goshawk and sooty grouse. The clearing of old migratory birds must align with the communal growth forest during American marten birthing nature of the Nisga’a Nation domestic (i.e., food, periods (i.e., late March) could cause some social and ceremonial) harvest and traditional incidental mortality of females and offspring. harvest seasons. No wildlife harvesting can interfere with other authorized uses of Crown land. Wildlife Mortality The Project is expected to result in mortality Nisga’a citizens have treaty rights to harvest of moose, grizzly bears, American marten and wildlife, including moose, grizzly bears, mountain mountain goats from collisions with vehicles. goats, and migratory birds for domestic purposes and to trade or barter wildlife or migratory birds Moose and grizzly bear winter range habitat is with other Aboriginal groups and/or amongst known to overlap with the network of FSRs, themselves. Nisga’a Nation wildlife harvesting Highway 113 and Highway 37. Higher risks of rights have the same priority as recreational and moose and grizzly bear mortality are expected commercial harvesting interests. to occur as traffic volumes increase near or adjacent to winter ranges. Bear accidents with The NFA lists Nisga’a Nation trap lines held mine-related traffic are likely to be concentrated by Nisga’a citizens that are outside of Nisga’a in the active bear season between the months Lands and subject to provincial law. Four trap of April and October. Mortality risk will be a lines fall within the Project’s land and resource function of the habitat suitability adjacent to the use study area, but do not overlap with any mine road, the speed limit on the road (e.g., higher infrastructure. Nisga’a citizens have identified for highways) and visibility (e.g., blind turns, Nisga’a Nation hunting and fishing cabins close whiteout conditions). The existing network of to the Project. The issuance of hunting licenses FSRs from the mine site to Highway 37 has not by the NLG in the NWA varies each year. been accessible during recent winters, and has experienced limited traffic relative to Highway 37 Potential Effects of the Project and Highway 113 over the remaining months of the year. Snow ploughing along these FSRs Habitat loss or alteration to allow vehicle traffic is expected to increase Habitat loss or alteration causing moose and the risk of moose and grizzly bear mortality and grizzly bear displacement is expected to occur result in greater use of the area for illegal and during construction and operations. The Project unregulated hunting. is expected to remove 113 ha of forage wetland habitat and 31 ha of potentially suitable winter Aerial surveys did not identify mountain goats habitat for moose in the NWA. Considering the close to the mine site. Suitable terrain to support

66 CEAA—Comprehensive Study Report: Kitsault Mine Project mountain goats was not identified in the RSA and population. With regard to regional road use, the existing access roads do not cross suitable the proponent will participate in any industry or mountain goat habitat, including low elevation government initiatives around use of the Nass canyons that are used by mountain goats during FSR and the Highway 37 corridor, which are the summer. Mountain goats were found to use important winter range habitat areas for moose. lower elevation conifer forest habitat further A summary of mitigation measures is provided away from the project (i.e., >5 km), but there in Appendix C. is potential for mountain goats to cross existing access roads and collide with Project-related Agency Conclusions traffic. Mountain goats could also be subject to illegal and unregulated hunting along the existing Mitigation measures were developed during the network of FSRs. EA in collaboration with the NLG and the TWG to minimize project-related effects on wildlife and American marten could be attracted to carrion wildlife habitat. Residual effects are considered along access roads (e.g., hares) leading to minor for most wildlife species, given the low increased mortality risk from vehicle collisions. quality habitat within the LSA and the availability of suitable habitat in the surrounding RSA. Sensory disturbance Encounters with grizzly bears could also Year-round project-related road use of the contribute to bear morality and pose safety risks network of FSRs, particularly the Nass FSR, is to humans. Grizzly bears could be attracted to likely to result in mortality of individual moose. waste and garbage at the mine site and may These losses could affect the regional Nass Valley need to be destroyed to protect human safety or moose population that has been in decline since relocated elsewhere either with other bears or with 2001. While the proposed mitigation measures relatively less suitable habitat. Salt used along the are anticipated to reduce the potential for moose access roads could also attract mountain goats to collisions with project-related vehicles, the risk congregate near roadways, leading to potential of moose mortality from cumulative vehicular collisions. collisions and other causal factors, including illegal and unregulated hunting, still remains. Mitigation Measures Efforts to minimize this mortality risk in concert with complex recovery planning for the The following management plans will address the regional moose population cannot be effectively adverse effects of the Project, including the effects managed by the proponent alone, but requires a of road use, on wildlife and wildlife habitat: coordinated planning approach involving relevant government agencies, the NLG, Aboriginal ••Wildlife Corridor Management Plan groups, the proponent and other industrial ••Transportation Safety Plan companies who use or are planning to use the ••Wildlife Management Plan same roads for transport. As such, the proponent ••Bear Interaction Management Plan will participate in any future regional CEAs, and ••Reclamation and Closure Plan management and planning efforts related to traffic along the proposed transportation corridors. The Wildlife Management Plan will include Nisga’a Nation participation in additional Residual adverse environmental effects to enforcement when access along the Nass FSR wildlife and wildlife habitat, including migratory increases during the winter. The proponent will birds, may occur following implementation of also support recovery efforts of the Nass moose mitigation measures. As noted in Section 4.7.5,

CEAA—Comprehensive Study Report: Kitsault Mine Project 67 these effects are not expected to be significant, Pine mushrooms were evaluated for their however, they have the potential to adversely importance as a food source and economic value affect Nisga’a Nation treaty rights and wildlife in the region. The coastal western hemlock- interests as set out in Chapter 9 of the NFA. lodgepole pine-feathermoss unit was determined Residual effects will be addressed through to have the greatest potential for producing pine the development and implementation of the mushroom with pine mushroom habitat covering management plans. 2 percent of the unit. Project activity is expected to clear <1 ha of this mushroom habitat, representing 5.1.6 Forest Resources a 1 percent loss of the available habitat in the LSA. Reclamation would not reduce this habitat lost. Chapter 5 of the NFA sets out that the Nisga’a Nation owns all forest resources and non-timber The Project is estimated to affect 369 ha forest resources on Nisga’a Lands. Provisions in (31 percent) and 274 ha (38 percent) of Chapter 5 establish timber harvesting rights and ecosystems with high or medium potential to rates on Nisga’a Lands. The NFA also sets out the support medicinal and edible-berry producing process for the NLG to apply and acquire Tree plants, respectively. Reclamation would reduce Farm Licenses. One Tree Farm License owned these losses by 193 ha (16 percent) and 96 ha and operated by Coast Tsimshian Ltd, intersects or (13 percent) for medicinal plant and edible the northern part of Nisga’a Lands, 25 km east of berry-producing habitats, respectively. the mine site. The Project is expected to result in the loss of The Department of Forest Resources of the NLG 113 ha of wetland, with 99 percent (112 ha) of manages and regulates the harvest of botanical this loss attributed to the construction of the forest products, including pine mushrooms, TMF and WRMF. Approximately 16 of the 42 ha 10 other mushroom species and fiddleheads within (38 percent of the LSA) of red-listed Sitka-sedge Nisga’a Lands. All Nisga’a Nation and non- – Peat-moss fen in the LSA will be lost to the Nisga’a Nation harvesters and buyers must apply TMF. One hectare (4 percent in LSA) of the for permits for the harvest of pine mushroom. blue-listed amabilis fir-western-red cedar-oak fern in the LSA would also be removed by Potential Effects of the Project project-related construction.

A summary of the potential effects of the Project Mitigation Measures to cultural plants is described below with more information related to the vegetation effects As an existing brownfield site, the use of previous assessment provided in Section 4.8. disturbed areas would be maximized wherever possible to help maintain a compact Project Cultural plants that were assessed include large footprint. Specific mitigation measures include: cedar trees, pine mushroom, medicinal plants and edible berry-producing plants. Loss of cultural ••Preserving the existing on-site hydrological plants is anticipated throughout the project regime to the extent possible; footprint as a result of vegetation clearing and ••Preventing the introduction of invasive species surface disturbance. by vehicle washing and use of native species for site reclamation; The Project is expected to remove 35 ha (2 percent) ••Salvaging and stockpiling topsoil and peat soils of the 235 ha of ecosystems in the LSA that could for use in reclamation; potentially support large cedar trees. This loss ••Plant transplanting and seed collection; and, would not be reduced by reclamation.

68 CEAA—Comprehensive Study Report: Kitsault Mine Project ••Site reclamation and re-vegetation (with native Nisga’a Nation can negotiate and attempt to reach species, including species used by members of custodial agreements for certain other artefacts. Nisga’a Nation, when operations cease). Future artefact discoveries in British Columbia or in Canada, but outside lands owned by the Nisga’a The proponent will develop a detailed Wetland Nation can either be lent to the Nisga’a Nation Habitat Compensation Plan to address residual or transferred to the Nisga’a Nation. The Chapter effects resulting from the development of the also has provisions that allow for processes to be TMF to red- and blue-listed ecological wetland developed by B.C. or the Nisga’a Nation for the communities and their functions. protection of heritage sites.

Agency Conclusions The NFA Appendix F-1 identifies five Nisga’a heritage sites, one of which (the Grease Trail at Reclamation and other mitigation measures are the Cranberry River) is located two kilometres expected to minimize the loss of ecosystems from a transportation corridor. Other sites of that support large cedar trees and medicinal and Nisga’a interest, including old village sites, trails, berry-producing plants, but existing ecosystems grave sites, house sites, oral history landmarks will not be completely restored at project closure and culturally-modified trees, have not been (i.e., loss of wetland habitat). Residual losses of identified in the LSA. cultural plants may affect the availability of such plants for harvest and use by Nisga’a citizens. Potential Effects of the Project The plant ecosystems affected by the Project also occur in surrounding areas that are not subject The proponent did not identify archaeological or to any project-related disturbance and therefore heritage sites within the LSA during archaeological alternative locations for harvesting cultural plants surveys, but recorded seven historical features may exist nearby. linked to early mineral exploration–blazed trees as trail markers, a partially buried wooden Residual adverse environmental effects to board, nails, wire of a drill pad and a section of vegetation and plant communities may occur telegraph line. Since these features post-date 1846, following implementation of mitigation measures. they are not protected under the B.C. Heritage As noted in Section 4.8.5, these effects are not Conservation Act. expected to be significant, however, they have the potential to adversely affect Nisga’a Nation treaty The nearest archaeological site is located rights and forest resource interests as set out in northwest of the Project at the mouth of the Chapter 5 of the NFA. Kitsault River. Most archaeological sites are found along the Nass River Valley. It is predicted 5.1.7 Cultural Artefacts and Heritage that these sites may date as early as 10 000 Before Present2, placing them within the North Chapter 17 of the NFA specifies provisions for the Coast Microblade Tradition. A historical fishing return of certain Nisga’a artefacts that are in the camp at Gitzault, approximately 15 km north Royal British Columbia Museum and the Canadian of the mine site at the head of Alice Arm, was Museum of Civilization, and sets out that the identified as the closest heritage site.

2 Before Present years is a time scale used in archaeology, geology, and other scientific disciplines to specify when events in the past occurred. Because the “present” time changes, standard practice is to use 1 January 1950 as the origin of the age scale, reflecting the fact that radiocarbon dating became practicable in the 1950s.

CEAA—Comprehensive Study Report: Kitsault Mine Project 69 Land clearing and excavation activities, including for each VC, and in Section 6.4.1 on the summary revegetation and remediation of lands, during all of key issues raised by the Nisga’a Nation. phases of the Project have the potential to uncover unidentified archaeological and cultural heritage 5.1.9 Agency Conclusions on sites. While direct effects to archaeological and 8e Assessment heritage sites identified beyond the LSA are not anticipated, unidentified sites potentially could be Chapter 10, paragraph 8(e) of the NFA sets discovered as the Project is constructed. out that for all EAs covered by the NFA, B.C. and Canada are required to “assess whether Mitigation Measures the project can reasonably be expected to have adverse environmental effects on residents The proponent will implement an Archaeological of Nisga’a Lands, Nisga’a Lands or Nisga’a and Cultural Heritage Resource Management Plan interests set out in this Agreement and, where in collaboration with the NLG. This plan will appropriate, make recommendations to prevent establish protocols to protect any archaeological or mitigate those effects.” and cultural heritage resources that are discovered within the project footprint during construction and During the EA, the potential environmental operations and to identify, record, communicate effects of the Project were evaluated and about, and manage these resources. Consultation mitigation measures were revised or developed with the NLG will inform and guide the options in collaboration with government agencies, the for mitigating potential effects to archaeological NLG and Aboriginal groups. Additional measures and heritage sites. were developed by the proponent in response to specific issues raised by the NLG and Aboriginal Agency Conclusions groups. The Agency considers the mitigation measures described in this report and summarized The Project is not expected to affect Nisga’a in Appendix C appropriate to prevent or minimize interests as defined in Chapter 17 of the NFA as the adverse environmental effects associated with no archaeological and heritage resources were the Project. identified within the mine footprint area. The anticipated increase in the level of activity in Based on the information in this report, the Project the LSA during construction, however, has the is likely to result in adverse, but not significant, potential to uncover unrecorded archaeological environmental effects on residents of Nisga’a or heritage resources. The management of such Lands, Nisga'a Lands and Nisga'a interests related resources would be guided by the proponent’s to fisheries, wildlife and migratory birds and Archaeological and Cultural Heritage Resource forest resources. No adverse effects are predicted Management Plan and through consultations with to water and to cultural artefacts and heritage as the NLG and the Archaeology Branch of the BC described in the NFA. MFLNRO. 5.2 Assessment of Economic, 5.1.8 Nisga'a Nation Comments Social, and Cultural Effects (8f of the NFA Chapter 10) Comments received from the Nisga’a Nation regarding the environmental effects of the Project Chapter 10, paragraph 8(f) of the NFA requires can be found in Chapter 4, within the discussion that all EA processes, as defined in the NFA, of Government, Aboriginal and Public Comments “assess the effects of the project on the existing and future economic, social and cultural well-

70 CEAA—Comprehensive Study Report: Kitsault Mine Project being of Nisga’a citizens who may be affected The ESCIA Guidelines also include consideration by the project.” of cumulative and incremental impacts of the Project in the context of projects that have In November of 2010, the NLG circulated its already taken place or are expected to take draft ESCIA Guidelines to the Agency and the place over the same timeframe as the Project. BC EAO to guide how the 8(f) requirement under the NFA should be addressed for the EAs of the To assess cumulative and incremental impacts Project and the proposed KSM Project. The draft as part of the 8(f) assessment, the proponent ESCIA Guidelines establish a comprehensive formulated several scenarios that assume varying approach to evaluating specific economic, social levels of economic development in the region and cultural effects of a project on the well-being and provide a basis for comparison of the net of Nisga’a citizens, including those residing effects of the Project in relation to other potential in the four Nisga’a Villages (i.e., Gingolx, projects. Laxgalts’ap, Gitwinksihlkw, and Gitlaxt’aamiks), Terrace, Prince Rupert and other parts of B.C. The federal EIS guidelines required the proponent to develop and submit a work plan that outlined The potential economic, social and cultural how it would collect and analyse the necessary effects identified in the ESCIA Guidelines information to address the draft ESCIA include: Guidelines. With guidance from the NLG, Agency and BC EAO, the proponent developed a study 1. Economic Effects methodology for data collection and analysis ••Nisga’a employment and income that included a combination of surveys, formal ••Nisga’a business activity, earnings and interviews, focus groups, informal discussions investment activity with Nisga’a citizens and representatives, Nisga’a ••Nisga’a natural resource activity and related literature research and reviews, and information earnings or values from relevant sections of the proponent’s EIS. ••Nisga’a Government revenues and The study focused on Nisga’a citizens residing in expenditures the four Nisga’a Villages, the NA, and other areas ••Future Nisga’a Nation economic outside Nisga’a Lands including Terrace, Prince opportunities and economic development Rupert and other communities in B.C.

2. Social Effects Results of the data analyses, which were based ••Migration and population effects on an estimated mine life of 16 to 17 years, were ••Impacts on infrastructure and services incorporated in the proponent’s Nisga’a ESCIA ••Occupational and non-occupational report that assisted the federal and provincial health risks governments in completing their 8(f) assessments ••Occupational and non-occupational under the NFA. accident risks ••Family and community well-being This section provides an overview of the assessment of project-related effects on the 3. Cultural Effects economic, social and cultural well-being of ••Effects on cultural activities and Nisga’a citizens as defined in the NFA, based practices including: on the information contained in the proponent’s ••changing work patterns and incomes ESCIA report. ••Nisga’a language

CEAA—Comprehensive Study Report: Kitsault Mine Project 71 5.2.1 Economic Well-being region and compared that demand against the Nisga’a employable labour supply3 to meet this The proponent’s work plan acknowledged that potential demand. other unrelated developments that may take place in the region will affect economic issues The total number of jobs in the region, based such as employment, migration and business on estimates of labour demand projections, opportunities. Therefore, project-related effects is expected to grow within the next decade were evaluated within the broader context of as projects, both existing and planned, are regional change and development. constructed and operated.

The proponent, with advice from the NLG, Labour demand was estimated for the three the Agency, federal departments and the BC scenarios. For the low development scenario, the EAO, created low, medium and high scenarios number of available jobs of all projects peaked to estimate potential employment and business at 1 145 person years in 2012 (construction of activities relative to the level of development the Project) before dropping to 308 for the next (i.e., number and types of projects) predicted 16 years and then further declining to 11 person to occur in the region. The proponent used data years by 2052 when most projects have ceased from other proposed or planned projects in the operations. Under the high development scenario, region to derive the different scenarios. Details of the total available jobs would peak at 3 275 person the scenarios are summarized in Table 5-1. years in 2016 and would continue at these Table 5-1: Projects Considered in Regional numbers during the life of the Project and Development Scenarios the proposed KSM Project. Scenario Projects [KMP], Northwest Transmission The Project is expected to contribute to this Low regional Line (NTL), Forrest Kerr Hydro, regional labour demand with up to 720 jobs development and McLymont Creek Hydro during construction, 300 jobs during operations Medium regional [KMP], NTL, Forrest Kerr Hydro, and 51 positions during decommissioning and development McLymont Creek Hydro, and KSM closure. No direct employment is expected [KMP], NTL, Forrest Kerr Hydro, during post closure. High regional McLymont Creek Hydro, KSM, development Galore Creek, Red Chris, and Schaft Creek The current employable Nisga’a labour supply was estimated at approximately 1 140 Nisga’a citizens with 370 residing on Nisga’a Lands and Description of Baseline Information 775 living off Nisga’a Lands. This labour force will reach near 1 480 Nisga’a members by 2051. Nisga’a Employment and Income To examine the potential effects of the Project on The ESCIA noted that the median incomes Nisga’a employment and income, the proponent earned by Nisga’a citizens range from $17 200 analyzed the potential demand for workers in the to $43 700 annually. For some Nisga’a citizens,

3 The potential employable labour supply was defined as Nisga’a citizens who: • are employed (part-time or full-time) or unemployed and looking for a job, and are 15 years of age or older, • have expressed an interested in working at the mine or are willing to work under mine conditions, and • have the minimum required skills to work at the mine (defined as high school education or higher).

72 CEAA—Comprehensive Study Report: Kitsault Mine Project some or all of their income is derived from 85 employees at the height of the harvest season. government assistance. In 2002, a total of a 100 people were employed.

Nisga’a Nation Business, Earnings, and The Nisga’a Nation traps animals for pelts Investment Activity that are used to make traditional apparel and The proponent conducted a survey of existing ceremonial gifts. Marmots, fisher, American Nisga’a businesses as part of the ESCIA to marten, mink and weasel are all trapped for their understand the sectors that they serve, the goods pelts, with American marten offering the most and services they provide, and the potential value. In 2006, marten accounted for 69 percent business opportunities and effects associated of the total value of wildlife pelts trapped in B.C. with the Project. The ESCIA noted that Nisga’a ($1.6 million of total value) and approximately businesses provide goods and services to a 58 percent of the furbearers harvested in the wide range of sectors such as tourism and food Skeena Region. To maintain an active trapline, services, retail and wholesale sales, culture and trappers are required to harvest 50 pelts or earn recreation, business and other support services. $200 from pelt sales per year. The majority of these businesses are small, having five employees or less, while only one Nisga’a Nation hunters on Nisga’a Lands and business comprises more than 100 employees. the NWA are regulated by annual allocations Key clients for most Nisga’a businesses include established by a joint management committee the NLG or Nisga’a Village governments, social comprising the NLG and provincial and federal or education agencies, and provincial and federal authorities. The NLG is responsible for monitoring governments. Approximately one in five Nisga’a and enforcing wildlife harvesting allocations under businesses have worked in the mining sector, the Nisga’a Fisheries and Wildlife Act. Moose and with the same number of businesses working bear (grizzly and black bears) were the species in construction and forestry, all of which are primarily hunted based on harvest data of resident relevant sectors that could support the Project. hunters from 1996 and 2005.

Nisga’a Natural Resource Activity Pine mushrooms are an important resource Nisga’a citizens depend on the natural resources found in Nisga’a Nation forests. Harvesting within the NA to practice and pursue their is prevalent in areas such as the Kitsumkalum traditional, cultural, and commercial activities. valley, Cranberry Junction and the Nass Valley, They use the land for hunting, trapping, gathering, and is regulated through the sale of permits to fishing, country foods, medicines, material, and Nisga’a and non-Nisga’a harvesters. From 2000 other culturally-important resources. to 2008, the annual pine mushroom harvest ranged between 1 500 and 45 000 kilograms and Nisga’a businesses also depend on certain natural generated a total of $4.2 million. Despite the resources for commercial activities, including, highly variable economics of pine mushrooms, but not limited to, fishing, hunting and trapping. the annual harvest added approximately $1 million to the local economy while permit The annual Nisga’a Nation harvest of salmon and surcharges provided nearly $80 000 for individual sale, domestic and commercial towards management of the program. purposes, since the year 2000, has ranged between 22 000 and 128 000 fish and generated NLG Revenues Expenditure over a total of $6.6 million. Thirty full-time The ESCIA indicated that the NLG collects employees were working in Nisga’a fisheries approximately $73 million in revenue annually management in 2000–2001, with an increase to with $6 million excess revenue (i.e., adjusted

CEAA—Comprehensive Study Report: Kitsault Mine Project 73 for expenses) in 2011. Most NLG finances are income estimates, the incremental net income channelled towards supporting the operations for Nisga’a workers that may be employed at and administration of NLG including transfers the mine was calculated at $36 000 per year, to the Nisga’a Village Governments, Nisga’a which would result in an overall Nisga’a Nation Valley Health Authority and the Nisga’a School net income effect of $5.2 million a year during Board. Operating surpluses from commercial construction and $3.2 million a year during entities, such as Nisga’a Fisheries, Lisims Forest operations, assuming maximum employment Resources and enTel Communications, also is achieved. contribute to the NLG revenue stream. Nisga’a Nation Business, Earnings and Potential Effects of the Project Investment Activity Potential revenue to Nisga’a businesses is Nisga’a Employment and Income expected to vary depending on the extent of The proponent’s original estimate of potential industrial development in the region and the jobs for Nisga’a Nation (i.e., 60 jobs during involvement of these businesses in providing construction, 36 jobs annually during operations goods and services to the mining industry. Under and 24 jobs during closure) in the EIS was low regional development, peak business revenue based on calculations of available jobs relative is predicted to be $7.9 million in 2013, while to Nisga’a citizens who expressed interest in under the high regional development scenario, working at the Project. As these numbers did Nisga’a businesses can expect peak revenues not take into account any employment strategies of $16 million by 2014. For all scenarios, the to improve job readiness Nisga’a citizens, incremental net income from the Project for the they represent the low end of the potential first two years of construction is forecasted to employment spectrum. reach $500 000 in year one and $700 000 in year two, after which net income would decline and The ESCIA provided a different set of labour remain at $200 000. supply and demand estimates that were specific to Nisga’a communities in the context Nisga’a businesses expect their operations to of labour demand from other development grow over the next 10 years (irrespective of the projects occurring in the region. Considering Project) and over 90 percent of Nisga’a business the implementation of intensive training, local respondents expressed an interest in becoming hiring strategies and career awareness measures, suppliers to the Project. the proponent estimated a maximum of 144 jobs occupied by Nisga’a citizens during construction, The largest barriers to benefits to local 90 jobs per year during operations, 21 jobs during Nisga’a businesses include access to capital decommissioning and 3 during closure and post and financing, and the costs of running and closure. These numbers are considered at the maintaining infrastructure and equipment. high end of potential employment spectrum. Implementing business policies (e.g., health and safety plans) could be a challenge, as many In terms of incremental income, the average Nisga’a businesses did not have these measures annual earnings at the mine for all positions were in place at the time of the survey. predicted to be approximately $62 600 per year, inclusive of wages and benefits. The median Opportunities during operations are expected to income in the region for Aboriginal workers was be of most benefit for Nisga’a businesses as local estimated at $17 200 for all workers and $43 700 suppliers may find it difficult to competitively for those working full-time. Considering these respond to procurement requests within a

74 CEAA—Comprehensive Study Report: Kitsault Mine Project short period of time for specialized supply as most of the necessary financial information is requirements that are needed for construction. appropriately collected and disseminated by the Local businesses will have more time during NLG. As a result, it was not possible to determine operations to better understand the supply project-related effects on NLG revenues, needs and requirements of the Project and particularly from changes in revenue of Nisga’a foster meaningful working relationships with businesses where the NLG has invested or has a the proponent. Some of the potential goods business interest. and services needed for operations include road maintenance, bus services, camp catering, With respect to NLG revenues and expenditures, concentrate haulage and winter gravel. the NLG does not have sufficient information to estimate the costs of participating in the Data from other projects in Canada indicated that regulatory phase of the Project, including costs project expenditures for Aboriginal businesses for monitoring, project-related education and ranged from 14 percent to 50 percent, although training and other economic development many factors influenced those success rates. strategies during construction and operations. However, the proponent has provided funding, Nisga’a Natural Resource Activity pursuant to funding agreements, for the NLG’s The Project has the potential to affect the Nisga’a participation in the EA. Nation’s traditional, cultural and commercial natural resource activities. These activities are In terms of the costs related to community services an important part of Nisga’a Nation culture and and infrastructure, the proponent will cover the contribute to the economic welfare of individuals, costs for local road upgrades and maintenance. households and communities. Changes in the Incremental migration of citizens to Nisga’a ability to participate in these activities could communities may incur a cost to the NLG for the result from adverse environmental effects of the provision of additional services associated with mine and alterations in employment patterns. housing, education, recreation and water and Survey results described in the ESCIA did not sewer. Aside from housing and recreation facilities, identify trends related to the effect of project most of the existing community infrastructure, employment on the harvesting activities of facilities and services are expected to absorb any Nisga’a citizens. Those citizens who believed additional demands caused by increased migration. employment would affect harvesting attributed Under each of the three development scenarios, this primarily to having less time to harvest and in-migration is expected to result in additional noted that the effects would be seasonal. housing needs. For the low regional development scenario, three houses a year for a total cost of The assessment of adverse environmental effects $700 000 was estimated while six to eight houses on residents of Nisga’a Lands, Nisga’a Lands and per year at a cost of $1.5–$1.8 million a year was Nisga’a interests set out in the NFA is discussed estimated under the high regional development in Section 5.1 of this report with additional scenario. Alternatively, Nisga’a citizens may information on effects on key environmental VCs choose to live outside the Nisga’a Villages (e.g., provided in Chapter 4. Terrace) in which case additional housing would not be required. NLG Revenues Expenditure The ESCIA identified different components of revenue to the NLG, but the quantification of effects, either positive or adverse, on revenues to the NLG could not be reasonably estimated

CEAA—Comprehensive Study Report: Kitsault Mine Project 75 Management Plans Once implemented, the management plans are expected to identify and reduce barriers ESCIA-related frameworks (see Table 5-2) have to employment opportunities by facilitating been developed with input from the NLG, the educational support and skills training, increasing BC EAO, the Agency and federal authorities to awareness of career and business opportunities maximize employment and income opportunities among Nisga’a citizens and exposing prospective for Nisga’a citizens and to enhance the retention workers to industry networks and contacts. of Nisga’a workers. These frameworks provide However, the nature and number of jobs taken the basis for the following management plans that up by Nisga’a citizens will depend on various must be completed and approved by appropriate factors, including the uptake and quality of regulatory authorities as part of the B.C. EA training, job opportunities elsewhere in the Certificate: Nass Valley and in the province, the range of salaries and working conditions at the mine ••Social and Cultural Management Plan site, provincial economic conditions and an ••Recruitment, Training, and Employment Plan individual’s own priorities and commitments. ••Business Capacity Plan ••Economic Closure Plan The Project is also expected to provide some ••Communication Plan contracting and business opportunities for the Nisga’a Nation, the benefits of which will not Further refinement and implementation of these likely occur until operations get underway and plans will involve close collaboration with the key goods and services are needed, including NLG and Nisga’a Villages and is expected to road maintenance, business services, camp build capacity and augment the skills base of the catering and concentrate hauling. The proponent Nisga’a Nation. The proponent will consult with will support Nisga’a Nation involvement in the NLG prior to submitting these plans to the construction-related procurement requests; regulatory authorities and implement the plans however, any benefits from these opportunities upon receipt of approval. would depend on the success of Nisga’a businesses in competitive bidding, based on Agency Findings the temporary nature of the proposed business opportunities. Successful implementation of the The Project will provide employment and business Business Capacity Plan is expected to address opportunities for Nisga’a citizens and businesses some of the barriers facing Nisga’a businesses during all phases and, in turn, offer prospects for looking to secure contracts for the Project. increasing income and revenue. Construction of Full and cooperative support of the NLG in the Project is estimated to provide a maximum developing and implementing the management of 144 jobs, while operations and closure are plans will be essential to addressing these expected to create 90 and 24 jobs, respectively. In economic well-being effects. Potential business view of the incremental increase in wages (taking opportunities may also be negotiated through into account the opportunity cost of existing an agreement between the proponent and the positions), the overall net income that the Project NLG concerning the effects of the Project. It is is expected to generate could reach as high as anticipated that any such agreement would benefit $5.2 million during construction to $3.2 million the Nisga’a Nation; however, details regarding an during operations, and if all proposed projects agreement are not presently available. in the region are realized (i.e., high regional development), as low as $1.6 million a year. Potential project-related effects to traditional or commercial natural resources activities are

76 CEAA—Comprehensive Study Report: Kitsault Mine Project not anticipated provided the mitigation measures Villages with nearly 70 people on waitlists for to address the effects on environmental VCs are new homes. Depending on the community, successfully implemented and monitored for different approaches have been used to manage effectiveness (see Chapter 4). While the location the housing demand including building new of such activities will shift as a result of the houses on available lots, redeveloping existing mine footprint, the economic value or costs of housing lots, and acquiring funding for home undertaking these activities are not expected to renovations. Temporary accommodations in New change. Aiyansh and Gitwinksihlkw (i.e., hotels, motels, bed and breakfasts and RV campgrounds) have a In terms of revenue expenditures, the NLG will capacity of 272 units. incur residual costs related to environmental and community well-being monitoring over the life Community utilities within Nisga’a Lands such of the Project, and expenditures for upgrading as water, sewer, garbage collection and landfill community facilities, including additional services are operated by the NLG and the Nisga’a housing units. Village governments. The community landfill, which is funded by the Regional District of 5.2.2 Social Well-being Kitimat-Stikine, is located near Gitlaxt’aamiks and services the Nisga’a communities and Description of Baseline Information surrounding area. The ESCIA noted that all of the water systems in Nisga’a Villages have been Migration and Population or are in the process of being upgraded. The The ESCIA assessed the potential for migration majority of the community sewer systems are to Nisga’a Villages and the NA and the growth in good working order with only one system in these communities. The assessment, based needing a recent upgrade in 2011. High-speed on provincial statistics, was used to predict internet services are provided to all Nisga’a population growth of the Nisga’a Nation. Villages by enTel, a company that is part of the Between 2006 and 2026, the population is Nisga’a Commercial Group. predicted to grow before a decline from 2026–2036. This growth is expected to result Each Nisga’a Village operates a recreation in a 1.8 percent net increase of population centre that houses community-based recreation (35 individuals) to a population of 2 080, programs funded by Nisga’a Child and Family which represents marginal or no in-migration. Services. In addition, the Nisga’a Memorial Lava Bed Provincial Park provides the setting and Community Infrastructure and Services facilities for a variety of recreational activities. The ESCIA noted that in 2006, based on census information, there were 531 occupied The Nisga’a Nation School District No. 92 private homes in the Nisga’a Villages of which administers education services to the Nisga’a 25.3 percent were rented and 74.7 percent were Villages and employs a staff of 32 teachers owned. Many of the dwellings (40 percent) as of 2011–2012. The district is considering were identified as needing major repairs and new proposals that focus on reorganization on average there were about three persons of the school system in the Nass Valley and per household. development of a trades program. The Wilp Wilxo’oskwhl Nisga’a Institute also provides More recent information in the ESCIA estimated post-secondary education opportunities in approximately 473 homes in three Nisga’a different academic and vocational sectors.

CEAA—Comprehensive Study Report: Kitsault Mine Project 77 The Gitlaxt’aamiks Volunteer Fire department NA due to the Project, the result is a net increase and RCMP Lisims-Nass Valley police detachment of 26 people. Annual in-migration would provide emergency services in Nisga’a decline by one person per year over the life the communities with ambulance services provided Project, leaving a steady in-migration in the by the B.C. Ambulance Service for the northern NA population that would result in an increase region. Healthcare services (e.g., physician of about 1 800 people by 2022. At the end of services, public health, dental and mental the Project’s life in 2030, the population would health) in the Nisga’a Villages are delivered and have increased by one-third to 2 025, an annual managed by the Nisga’a Valley Health Authority. increase of 3.4 percent. Each Nisga’a Village government provides social services in its community while the Nisga’a Under the Low Net Migration Scenario, in- Child and Family Services coordinates services to migration is expected to be the same as in the ensure the protection and well-being of Nisga’a High Net Migration scenario, but out-migration children and youth in all Nisga’a communities. rates would be higher. The result over the life the Project is a population increase of 1 676 people Social Risks to Family and by 2022, an 11 percent increase. By the end of Community Well-being the Project in 2030, the population could reach The ESCIA reported on different socio-economic 1 800 people, representing an annual increase indicators to examine the current well-being of 1.06 percent, about double the natural annual in Nisga’a communities. For most indicators, population growth rate. including children at risk, youth at risk, human economic hardship, crime, health and education, These predicted population changes described in the rates in Nisga’a communities were found to be the ESCIA have the potential to positively and double or triple the relevant provincial average. adversely affect Nisga’a communities. Although The assessment recognized the importance of the the predictions reflect linear growth rates, both local context and the perceptions of well-being in in-migration and out-migration will fluctuate the community despite the higher results compared depending on the stage of the Project, the to provincial averages. influence of other development expected to occur in the region and broader socio-economic drivers. Potential Effects of the Project The reasons why individuals might decide to Migration and Population move away or move to (or move back to) the The ESCIA identified different scenarios of NA were also explored. Mining experiences migration of Nisga’a citizens in and out of the in B.C. have shown that people moving into NA that could be expected to occur. Under the northwest region are more likely to move the High Net Migration scenario, the ESCIA to larger centres such as Terrace or Smithers predicted a net in-migration of 52 people to the because of the diversity of services that are not Nass Area within the first several years of the found in smaller communities like the Nisga’a Project being constructed. This in-migration Villages. Those who do decide to move to the scenario was based on 65 people moving to Nisga’a Villages from outside the region or from the Nass Area with their families, totalling the large regional centres are likely to have social 113 people, minus those individuals who choose connections in those villages and actively seek to live in Terrace or Prince Rupert. With the available employment opportunities. predicted out-migration of 26 people from the

78 CEAA—Comprehensive Study Report: Kitsault Mine Project Other Nisga’a citizens, however, have expressed • If more people come to the Nisga’a Villages, the intention to move away from the NA if the there is likely to be an increase in Project was to proceed. The ESCIA revealed that over-crowded households. some citizens were likely to leave because of • Additional overcrowded housing will deter environmental concerns associated with the Project. those deciding whether to move to (back to) the NA for jobs. Compared to the Project’s operations phase, the • Employment, businesses, and revenues generated construction phase is likely to have less influence by the Project may prompt investment to upgrade on people’s decisions to (or not to) move to (or and augment local housing in some or all of the back to) the NA because of the temporary nature Nisga’a Villages. of construction work. The ESCIA noted that there could be exceptions to this trend particularly for It is predicted that until additional housing those individuals who have some other reason becomes available, Nisga’a Villages are likely to to move to (or back to) the NA or who seek the face adverse social impacts due to a shortage of opportunity to make a first impression with the housing and overcrowding of existing housing. proponent to secure future work during operations (e.g., young, single workers). With Nisga’a The potential influx of people to the Nisga’a citizens showing a moderate interest in working Villages is also expected to increase usage at the Project, it is expected that the long-term and demand on community infrastructure. employment associated with the operations For most necessities, such as electricity and phase and the close proximity of the Project to communications, the existing community Nisga’a communities will influence decisions to infrastructure would be able to absorb the permanently move to (or back to) the NA. additional demand. Similarly, water and sewer facilities in each Nisga’a Village either have Community Infrastructure and Services ample capacity to service a larger population The net impact of potential mine-related or are in the process of being upgraded. migration on housing and infrastructure within the Nisga’a Villages is a function of Recreation facilities; however, have been identified the quality and quantity of existing housing, by Nisga’a citizens as an element of community current occupancy and the degree to which infrastructure that would require upgrades to expected migration might exceed the combined accommodate more people. Improving these stock of housing and infrastructure, including facilities is considered necessary to not only attract consideration of any upgrades or additions that people to (back to) the Nisga’a Villages, but also to may be proposed. provide an incentive to keep people from moving away. Local schools have the classroom space to The ESCIA indicated that overcrowded residences take in more students, but would likely need to continue to be an issue in Nisga’a communities hire additional teachers. as housing is close to or at capacity. For Nisga’a citizens living outside of the Nisga’a Villages, the An increase in the number of people in the lack of adequate housing represents a key deterrent Nisga’a Villages and to a lesser extent, individual to moving back to the NA. In the case of the High behaviour and choices (e.g., higher income Net Migration scenario (i.e., 26 people per year), leading to substance abuse, domestic disturbance) the following effects could occur: have the potential to affect the delivery of services (e.g., education, emergency response and transportation). An increase in students is not likely to strain education services as schools

CEAA—Comprehensive Study Report: Kitsault Mine Project 79 are facing the challenges of managing declining the risk of damage to culturally important sites school enrolment. The ESCIA noted that a review due to more traffic or vandalism. of the education system and services in Nisga’a communities is ongoing to address issues such as Occupational and non-occupational health risks teacher staffing levels and facility conditions. The potential risks of environmental exposures on Nisga’a citizens are generally expected to With an anticipated increase in project-related be localized to the mine site. The proponent traffic on the Nisga’a highway and roads conducted a human health risk assessment, which (i.e., 6 206 vehicle trips during construction; identified arsenic and molybdenum as chemicals 6 724 per year during operations), an increase of potential concern that could affect humans in the number of accidents is expected, and consuming untreated mine contact water, soil depending on where these accidents occur, and plants at the mine site. The assessment noted a greater demand on existing police and that the likelihood of health effects from these ambulance services will result. Responding to chemicals is low, based on conservative exposure these additional incidents will draw Nisga’a scenarios. Surface drinking water sources for the emergency resources – Nisga’a Lisims RCMP Project are limited to the Clary Creek watershed, and Nisga’a volunteer fire department – away with no potential pathways of exposure to from other emergency needs in the community Nisga’a communities. for periods of time. Road blockage caused by accidents could inconvenience travellers by Occupational and non-occupational preventing or delaying Nisga’a citizens from accident risks reaching their destination. The proponent conducted an assessment as part of the EIS to identify the different occupations Nisga’a emergency services may also have to associated with the Project that would be contend with a potential increase in public and considered high-risk. The potential risk of domestic disturbances that are associated with injury or death caused by job site accidents higher disposable incomes in communities. It was estimated using Worksafe B.C. statistics. has been noted that, to some extent, mine-related The results forecasted 35 injuries per year employment and incomes will lead to increased during construction and six per year during incidents of alcohol and drug abuse and necessitate operations. For decommissioning and post the need for more community policing. closure, 0.1 injuries per year are expected. These numbers provide a general indication of the level Potential effects related to transportation services of accident risk that could occur for Nisga’a and infrastructure include pollution and other citizens working at the mine, which is no greater environmental impacts resulting from vehicle or lesser risk of job site injury or death than for accidents and spills and risks to wildlife and the broader employee population. humans from higher levels of industrial traffic. Improved access caused by snow ploughing and In terms of non-occupational accident risk, regular maintenance along the Forest Service mine-related traffic, including buses, heavy Roads could attract non-resident parties to the trucks and equipment, and other industrial transport area and lead to increased land use activities vehicles on Nisga’a roadways is expected to pose by outsiders. These activities and those that some risk to Nisga’a citizens whether as drivers, are deemed illegal (i.e., illegal and unregulated passengers or bystanders. However, measures will hunting) could impose additional pressure be implemented to manage this potential risk, as on Nisga’a resources and elevate the risk of described in Section 4.7 of this report. accidents. Unintended access can also increase

80 CEAA—Comprehensive Study Report: Kitsault Mine Project Social Risks to Family and partially address these issues, two of the Nisga’a Community Well-being communities have developed portions of land for The inflow of transient workers into Nisga’a new housing. During Project decommissioning communities not only has the potential to and closure phases, there will be a loss of jobs and change people’s behaviours, social conditions income, which could lead to an outward migration and community dynamics, but can also increase and negative effects on the community. demand on existing community services, infrastructure, housing and traditional culture. Schedules related to shift work can strain Workers that engage in disruptive or illegal family and community dynamics as workers activities could also cause other adverse effects are separated from their families for periods of in the community including crime, alcohol abuse time. The potential effects on the worker include and family dysfunction. feelings of loneliness and separation and the temptation to engage in substance and alcohol Increased income associated with project abuse. For the spouse at home, an absent partner employment can have both positive and negative can mean managing a busier household workload, effects on communities. It can improve the making more independent decisions and feeling standard of living in which individual and family more anxiety for the partner. The ESCIA noted decisions can be made to improve housing, seek that the stress caused by a rotational schedule can higher education, practice cultural activities increase family fragmentation, family break-ups or invest and save for the future. The ESCIA and violence, and altered behaviour in children. indicated that Nisga’a citizens with increased In addition, time away from the community income, although working away from their can reduce a worker’s community involvement families for periods of time, would feel better and ability to fully participate in subsistence knowing that they could provide a better life for and traditional activities. Removal of workers their children. Higher incomes have also been from the community has the potential to remove noted to improve people’s health, self-esteem the most skilled and employable workers from and choices, particularly for young children. the community (i.e., brain drain) and redirect spending away from local businesses to larger Conversely, increased incomes can also exacerbate centres such as Terrace. negative behaviours such as alcohol and substance abuse, in communities that are already fraught The ESCIA reported that resource harvesting with social issues. These behaviours can, in turn, and activities are strongly internalized for most lead to other family-related problems including Nisga’a citizens. Workers living away from the child neglect and domestic violence. Substance community might have less time or lose the and alcohol abuse can contribute to suicides, opportunity to participate in resource harvesting, overdoses and death. Poor spending decisions whether for subsistence or community cultural can dually reduce the well-being of the individual purposes. Instead of harvesting country foods, and the wider community that is affected by the workers on shift work may rely more on store negative behaviour. bought foods, which have been linked to health problems in northern communities. At the same As mentioned in previous sections, Nisga’a Villages time, with higher incomes, workers are able to are already experiencing overcrowded residences purchase the necessary equipment to efficiently and a shortage of housing such that trying to partake in resource harvesting activities. accommodate new families would be difficult. To

CEAA—Comprehensive Study Report: Kitsault Mine Project 81 Management Plans Monitoring indicators and triggers will be developed in collaboration with the NLG and The proponent will implement policies that guide will, at a minimum, track changes related to the movement of workers and contractors to and population and housing, school enrolment, from the mine site, including: individual and family dysfunction (e.g., children in care, serious crime rates), participation rates ••housing external contractors and their workers in in harvesting and cultural activities, and mine- camp at the site; related traffic volumes and accidents along the ••prohibiting private vehicles from driving to and Nass FSR. Where monitoring results exceed from the site from regional communities and specified triggers, the proponent and the NLG other parts of B.C.; will investigate the underlying issues, develop ••transporting workers and contractors by bus to appropriate action plans and take action to and from the mine site from Terrace; and, address the issues. ••prescribing work rotation schedules and providing on-site accommodation camps. Human resources policies will prohibit drug and alcohol use at the mine, before and during shift These policies are intended to reduce the need for work, and will provide leave with pay for those people outside the Nass Valley to move to (back workers willing to address substance abuse issues. to) the region to work at the mine. They have The proponent will also provide Nisga’a workers the potential to lessen in-migration to Nisga’a with scheduling options that suit their needs for communities and temper any additional demand participating in cultural and harvesting activities. on existing community infrastructure and services. Potential accidents associated with the Project Beyond these policies, the proponent will will be managed through the Occupational Health implement the management plans described in and Safety Plan, which will be developed prior Table 5-2 to manage the potential social effects to mining and processing operations. The plan is associated with in-migration on infrastructure expected to protect the health, safety and well- and services, new work patterns and income being of all workers and will include inspections levels, and road accidents due to increased traffic. and measures to address unsafe work places, Effects will be addressed and monitored through accidents and worker health. a suite of activities, including: Agency Findings ••monitoring of social and cultural indicators in Nisga’a Villages and the mine site; The social effects of the Project will depend ••implementation of a cultural and social needs on the number of Nisga’a citizens who gain assessment survey to solicit input from Nisga’a employment at the Project, where they decide employees about their employment and work to live and how they decide to spend their conditions at the mine site; disposable income. As more people move to ••implementation of human resources policies that or return to Nisga’a communities to obtain are culturally-sensitive to the needs of Nisga’a employment, the greater the effects, both employees and fair to other employees at the positive and negative, on social-well-being, mine site; and, local infrastructure and services, and personal ••implementation of a communications plan and community well-being. Migration of Nisga’a to facilitate regular communication with the citizens into or out of Nisga’a communities is NLG and Nisga’a Villages during all phases predicted to result in a net increase in village of the Project. populations. The influx would increase demand

82 CEAA—Comprehensive Study Report: Kitsault Mine Project on housing, which is currently at or close to (VAP) for engaging communities about issues capacity, and on recreational facilities and as they arise, conduct a social and cultural needs policing services. The adverse effects on housing assessment to ensure camp life is “Nisga’a are expected to persist over the short term and friendly” and implement human resource policies could be alleviated by augmenting the housing which include drug and alcohol programs, equal inventory as higher incomes and revenues are opportunity and anti-discrimination programs, brought to the communities. The provision flexible work schedule options and policies around of transportation options that allow Nisga’a bereavement leave. Full and cooperative support of employees to commute back to Nisga’a Villages the NLG will be required for plans to be developed and the development of flexible schedules to and successfully implemented to address project- accommodate this arrangement are expected to related effects on social well-being. reduce the effects of in- and out- migration. 5.2.3 Cultural Well-being The effects of increased income on well-being can be beneficial or adverse. Increased income Description of Baseline Information can lead to the purchase of amenities that enable more comfortable living and more efficient Culture practices and activities resource harvesting. Under these conditions, the Chapter 2 of the NFA states that “Nisga’a citizens quality of life and effective resource harvesting have the right to practice the Nisga’a culture and to might both improve, and demands on family use the Nisga’a language, in a manner consistent and community services might lessen. These with this Agreement.” positive influences tend to increase as work and income stabilizes, and families learn to The ESCIA identified that knowledge of the treaty manage their increased income. Conversely, right and ability to use the land is just as important, greater income can increase the potential for if not more important than the actual pursuit of gambling or spending on alcohol that jeopardizes cultural practices and activities, based on results the purchase of necessities. Substance abuse from surveys with Nisga’a citizens. Nisga’a Nation can have serious adverse effects on family cultural practices and activities are connected and community relationships and well-being. to the land and aquatic resources. These include Incompatible expectations between workers, who hunting, trapping, fishing, mushroom picking, and have endured lengthy work-related separations, the harvest of country foods and medicinal plants. and their spouses, who want to share family responsibilities at home, can lead to serious The ESCIA reported that cultural practices family conflicts. and activities go beyond the boundaries of traditional resource harvesting practices whereby Predicting the effects to social well-being as a the integrity of the environment is not only result of increased income is therefore complex essential to the Nisga’a Nation culture, but also and contingent on many factors. The proposed the Nisga’a economy. Examples of Nisga’a management plans are expected to address, businesses offering eco-tourism and wilderness manage and monitor the adverse social effects activities show the close relationship between the associated with increased family incomes while NA environment and Nisga’a cultural values. enhancing the benefits to families. As part of the Social and Cultural Management Plan, the In terms of cultural activities, the ESCIA revealed proponent will develop social and cultural well- that most Nisga’a citizens, both on and off being monitoring programs in collaboration with the NLG, establish a Village Advisory Process

CEAA—Comprehensive Study Report: Kitsault Mine Project 83 Nisga’a Land, consume wild fish on a weekly youth are not interested in learning and because basis, while some Nisga’a citizens consume wild of limited opportunities for citizens to learn the meat, berries and plants on a weekly basis. It was Nisga’a language in urban centres. noted that wild food consumption among Nisga’a citizens who live on Nisga’a Lands is consistently Currently, efforts are being made to revitalize higher for all types of foods compared to those the Nisga’a language through immersion classes citizens who live off Nisga’a Lands. in schools and through increased awareness of the significance of the language to the Nisga’a Work Patterns and Incomes Nation’s culture. Part of the revitalization includes The ESCIA noted that Nisga’a citizens have had using new ways to connect with youth (e.g., some previous experience with shift work and the mobile application) about the Nisga’a language. potential interruptions to their land use activities. While they understand that mine employment Potential Effects of the Project can affect resource harvesting and community activities, Nisga’a citizens also recognize that Direct Project-related Environmental people are already moving away from Nisga’a Impacts on Culture Villages for seasonal work or other employment, The Project has the potential to result in residual which is not any different from the work patterns effects on harvesting activities such as fishing, for mine employment. hunting, trapping and gathering that are at the core of Nisga’a Nation culture and cultural The potential implications of increased income practices. More information is provided in on Nisga’a Nation culture will depend on the Section 5.1 of this report. individual, the family, the community and any measures implemented by the proponent. Impacts of Changing Work Patterns and Income Nisga’a Language Mine employment schedules can affect the Census data from 2006 shows that Nisga’a cultural pursuits of Nisga’a citizens by making citizens use and are more fluent in the Nisga’a it difficult for them to maintain their cultural language compared to the provincial average for lifestyle, altering family dynamics and changing language fluency among other Aboriginal groups. the traditional diet at the mine site. More recent information in the ESCIA, however, showed that the comprehension of and the ability The ESCIA described concerns with respect to read and write the Nisga’a language are limited to the limited time that those employed at to a small portion of Nisga’a citizens. In a survey the mine will have to participate in cultural of 405 Nisga’a citizens living in Nisga’a Villages, activities, including resource harvesting. For Terrace, Prince Rupert and Vancouver, 72 young, working-aged men, less time on the (17.8 percent) understood the Nisga’a language land practicing culturally-related activities may while 42 (10.4 percent) could speak the diminish their opportunities to learn traditional language, and 28 (6.9 percent) could read skills and knowledge from their family and and write the language. Elders. This situation is considered essential to facilitating the transfer of cultural knowledge The survey results coincide with the general between generations. Missing the opportunity recognition among Nisga’a citizens that most to process fish was identified as another people in Nisga’a communities no longer speak consequence of shift work associated with the Nisga’a language regularly. Teaching the the Project. Nisga’a language is often challenging because

84 CEAA—Comprehensive Study Report: Kitsault Mine Project Mine-related work schedules may also hinder substances for themselves and others. However, Nisga’a workers from attending cultural family it is also recognized that generating more wealth and community events such as weddings, can have positive results, such as improving ceremonies, funerals and feasts. Being able self-worth through increased responsibility, to participate in these events is important for creating more opportunities to participate in the Nisga’a Nation because of the value and resource harvesting activities and contributing to significance of certain ceremonies and the community well-being. The prospect of having specific roles of key community members. Nisga’a women work at the mine and earn a The ESCIA noted that Nisga’a citizens expressed good income would also have an overall positive the need to allow employees to return to the impact at the family and community levels. community for cultural and family events, especially for Nisga’a funeral ceremonies. Effects on Nisga’a Language The Project is expected to affect the use of Shift work can strain family dynamics if one Nisga’a language because: or both parents work at the mine. The potential adverse effects of the Project’s work patterns on ••The working environment is these dynamics are discussed in Section 5.2.2. predominantly English. It is noted that family and community cohesion ••Nisga’a workers do not use Nisga’a language can be strengthened when workers have extended during their shift at the site (i.e. for weeks. time to bond with family and friends, and to ••English-only policies will be enforced to ensure participate in cultural and community events that clarity and consistency among employees. foster community cultural well-being. ••An influx of non-Nisga’a workers to the Nass Valley necessitates the use of English at the mine While working at the mine site, Nisga’a workers site and in communities. will have less opportunity to consume traditional ••English will continue to be used at home and foods such as wild meat, fish, plants and berries in the community. because of the Western diet accommodated in camp. The difference between the diet in camp It is recognized that the use of English at the and Nisga’a consumption of culturally-relevant mine could hamper the Nisga’a Nation’s ongoing food is likely to affect the cultural values and efforts to revive the traditional language. lifestyle of Nisga’a workers at the mine site. However, providing Nisga’a workers with the ability to spend more time participating in Higher disposable incomes that benefit certain cultural activities with family members during individuals over others have the potential to off shifts may help reverse language loss and the weaken cultural cohesion and resilience in effects to Nisga’a culture. Teaching non-Nisga’a communities. The disparity in income can lead people the Nisga’a language has been identified to an increase in individual spending, a greater as another measure to strengthen the culture and interest in generating wealth and a diminished increase language use. interest in partaking in cultural activities together with family and friends. These effects tend to Management Plans be more prominent for certain groups in the community, based on experiences from other Measures to address the potential effects of the northern mines. For example, young single Project on the terrestrial and aquatic resources males lacking money management skills and that Nisga’a citizens have the right to harvest as responsibilities for supporting a family are defined in the NFA are provided in Chapter 4 and more likely to spend their income on alcohol or in Section 5.1.

CEAA—Comprehensive Study Report: Kitsault Mine Project 85 The five ESCIA-related management plans community events. Such absences can affect comprise actions that will minimize adverse the intergenerational transmission of cultural project-related effects on social and cultural knowledge and practices and their relationships well-being. In particular, the Social and Cultural with the community, particularly if individuals Management Plan specifies a set of strategies play an important role in the community or to identify, monitor and manage cultural effects have unique obligations at cultural events. on Nisga’a citizens working at the mine site and The extent of these effects will depend on the living in Nisga’a communities. For example, balance between work and cultural obligations, the establishment and monitoring of cultural the adaptability of families to shift work and the indicators are expected to help the proponent availability of family and community support. and the NLG characterize the extent of effects on Nisga’a citizens, determine the thresholds for As for Nisga’a language, the increase in initiating action and evaluate the effectiveness of employment of Nisga’a citizens will lead to an mitigation strategies. increase in their communication and interaction with non-Nisga’a workers. These influences Human resource policies and programs would could reduce the time that workers speak the provide options for Nisga’a workers that Nisga’a language and spend in the Nisga’a align best with their cultural pursuits and communities with their families, and in turn, commitments, including Nisga’a language alter the influence of families and communities courses, food services, bereavement leave and on workers. Collectively, these influences, plus work schedules. The proponent’s refinement of the effects on harvesting and cultural practices, all of these strategies will be achieved through could affect Nisga’a language use and cultural ongoing collaboration with the NLG. retention.

Cultural effects associated with higher incomes The proposed management plans are expected in Nisga’a communities are difficult to manage, to effectively address the adverse cultural as spending decisions are based on individual effects associated with shift work and language preferences. A VAP will be established to retention. Implementation of the social and identify, discuss and develop strategies to address cultural well-being monitoring program and the community-based effects when they arise. VAP will provide the means to identify ongoing community effects as they arise, discuss these Agency Findings effects collectively with NLG and Nisga’a representatives and develop appropriate The Project has the potential to positively solutions to manage the effects. or adversely affect the cultural well-being of Nisga’a citizens, either strengthening or weakening culture preservation and language. Cultural effects could arise from the nature of shift work and changes to resource harvesting activities, and could include loss of language.

Shift work patterns could cause Nisga’a workers to potentially miss traditional harvesting opportunities and important family and

86 CEAA—Comprehensive Study Report: Kitsault Mine Project Table 5-2: Frameworks for the Nisga’a Nation Economic, Social and Cultural Management Plans* Strategies of the Management Proponent Action Outcomes and Measures of Success Plan Social and Cultural Management Plan • Develop social and cultural indicators and triggers for • Incorporate local input into the review and comment by the NLG development of social and cultural • Report annually on results of monitoring for social and indicators and thresholds cultural indicators during construction and operation • Finalize social and cultural indicators phases including Nass community infrastructure and • Develop locally relevant and culturally services, family and community wellbeing (including appropriate thresholds Nisga’a culture) and highway safety • Develop social and cultural monitoring • Provide annual reports to the NLG for review and comment program (including a tracking database) • Invite NLG to track and report on relevant indicators related within the first year of construction to Nisga’a infrastructure, services, community well-being • Provide annual updates to tracking (including Nisga’a culture) and household level/domestic database and completion of annual Social and information report on social and cultural indicators Cultural • Track and report on relevant indicators associated with the starting at the end of the first year Monitoring mine site, including project-related transportation of construction Program • For each indicator (where practical and possible), establish • Initiate timely responses and establish potential thresholds that will trigger specific responses by an action plan to respond to trigger(s) the proponent and where appropriate the NLG • Provide the thresholds to the NLG for review and comment • If any indicators approach or surpass agreed upon threshold, investigate causes, seek to formulate action plans to address specific issues, and make best efforts to implement the action plans in consultation with the NLG and other local representatives (as directed by the NLG) • Provide results of investigations and action plans to the NLG and local representatives within 3 to 6 months from when the threshold is surpassed • Implement a process by which to collect and compile • Percentage of recommendations and ongoing local-level input from Nisga’a Villages using feedback from the VAP accepted by the existing governance and administrative bodies (VAP), as proponent directed by NLG • Collaboratively identify and agree to realistic and relevant indicators and thresholds for action Village Advisory • Identify, discuss and seek to resolve specific issues raised Process by Nisga’a local representatives and concerns that may arise through monitoring and other actions in the Social and Cultural Effects Management Plan • Consider comments, suggestions, ideas, and recommendations from local Nisga’a representatives • Implement input and recommendations from the VAP and provide a response within 60 days

* The management plans were developed in consultation with B.C. and the Nisga'a Nation.

CEAA—Comprehensive Study Report: Kitsault Mine Project 87 Table 5-2: Frameworks for the Nisga’a Nation Economic, Social and Cultural Management Plans continued Strategies of the Management Proponent Action Outcomes and Measures of Success Plan • Carry out a Cultural and Social Needs Assessment Survey • Complete a Cultural and Social Needs with the Nisga’a workforce at the mine site Assessment among Nisga’a employees • Provide the NLG the opportunity to review and comment at the mine site within the first year of prior to finalizing the survey operations • Solicit input from Nisga’a employees at the mine site about work schedule options, camp food services, Nisga’a Measure of Success: language options, counselling, family communication ••Achieve a participation rate of at least options, the bereavement policy, mentorship and shift 50 percent of Nisga’a employees in the scheduling for participation in traditional harvesting Cultural and Social Needs Assessment activities and cultural events Survey • Develop and make reasonable efforts to implement ••Submit results of the Cultural and Cultural and programs and policies that are based on the results of the Social Needs Assessment to the NLG Social Needs Cultural and Social Needs Assessment ••Implement human resources policies Assessment and procedures that are based on the results of the Cultural and Social Needs Assessment within two years of operations

Measure of Success: ••Ratio of policies, initiatives, and programs recommended compared to those implemented based on the results of the Cultural and Social Needs Assessment • Define and develop culturally-sensitive and locally-relevant • Develop and implement human Human Resource Policies (e.g., bereavement, drug and resource policies and procedures within alcohol, equal opportunity and anti-discrimination, work two years of operations. schedule options, Social and Cultural Programs and employment packages) informed by the Cultural and Social Measures of Success: Human Needs Assessment Survey ••Nisga’a worker absenteeism at or Resources • Provide the NLG the opportunity to review and comment below industry norms Policies on the policies ••Nisga’a worker absenteeism declining • Work to establish and implement such policies and over time programs ••Nisga’a worker retention rates at or above industry norms ••Nisga’a worker retention rates increasing over time Recruitment, Training, and Employment Plan • Develop and make reasonable efforts to implement a • Complete scoping of potential pre- career awareness program, including annual mine site training courses in local schools and visits with the Nisga’a graduating class, financially support vocational or technical training before pre-training courses at local educational institutions, hold the start of construction career fairs and workshops • Host an annual mine site visit with Nisga’a graduates starting in the first year of construction Career • Host or participate in career fairs and Awareness workshops starting prior to construction

Measures of Success: ••Percentage of Nisga’a citizens attending career fairs and workshops ••Percentage of Nisga’a graduates attending the mine site visits

88 CEAA—Comprehensive Study Report: Kitsault Mine Project Table 5-2: Frameworks for the Nisga’a Nation Economic, Social and Cultural Management Plans continued Strategies of the Management Proponent Action Outcomes and Measures of Success Plan • Consider, integrate and coordinate with existing Nisga’a • Identify Nisga’a worker skills, capacities training policies, strategies, objectives and processes (e.g., and barriers prior to the start of Laxgalts’ap Human Resource Development Strategy) construction • Tailor training to the areas identified in the Economic, • Deliver skills training and job-readiness Social and Cultural Impact Assessment and base it on programs starting in the first year of discussions with the NLG and local representatives (with construction such representatives to be identified by the NLG) regarding • Implement an internship program and the barriers and challenges to employment among Nisga’a job-shadowing program starting in the citizens (e.g., literacy, numeracy and life skills) first year of construction • Consider and incorporate feedback, input and lessons • Complete and submit proposal(s) to learned from the Nisga’a labour force and business leverage existing education funding experience with the Northwest Transmission Line Project sources • Provide resources (e.g., financial, personnel, information and technology) to high school upgrading and college Measures of Success: preparation programs, such as the Wilp Wilxo’oskwhl ••Increased certification in the Nisga’a Nisga’a Career and College Prep program labour force • Develop and submit proposals to leverage existing funding Educational ••Increased rate of high school sources (e.g., HRSDC’s ASETS program) in support Support and graduation of Nisga’a educational goals. The NLG must have the Skills Training ••Improved rate of academic upgrading opportunity to review and comment compared to the existing rate • Develop and make reasonable efforts to implement a skills ••At or above industry norm of Nisga’a training program, based on a review of the Nisga’a Skills workers completion of skills, job Inventory in partnership with local and regional educational preparation and internship programs organizations to address needs and barriers to Nisga’a ••Target of one proposal for funding skills development and capacities and to meet Project written and submitted per year labour requirements ••Number of Nisga’a applying for and • Develop and make reasonable efforts to deliver a job- successfully securing employment readiness training program, linking training to concrete ••Increased average income among employment opportunities Nisga’a citizens • Develop and make reasonable efforts to implement a ••Percentage of workforce being Nisga’a Nisga’a internship program and job-shadowing program. ••Levels of Nisga’a worker absenteeism The NLG must have the opportunity to review and ••Retention/turnover rate of Nisga’a comment employees • Give priority to developing short-term, construction-specific training plans and initiatives. Plans must be provided to the NLG for review and comment

CEAA—Comprehensive Study Report: Kitsault Mine Project 89 Table 5-2: Frameworks for the Nisga’a Nation Economic, Social and Cultural Management Plans continued Strategies of the Management Proponent Action Outcomes and Measures of Success Plan Business Capacity Plan • Support courses on starting and growing a business, • Reasonable efforts for the completion business financing, formal proposal writing and bidding, of two business courses or workshops joint ventures and the proponent’s procurement policy prior to construction (includes providing financial, personnel, information and IT • Complete a minimum of one business resources to existing or potential business course offerings course or workshop per year during at local and regional educational institutions and business construction and operations organizations) • Offer a range of assistance to Nisga’a businesses before, Measures of Success: during and after the bidding process for contracts related ••At a minimum, 10 percent of Nisga’a to the Project businesses attend courses • Develop a Nisga’a Business Database to facilitate ••Favourable evaluation by Nisga’a communications with, and advertising of, contract businesses of business course opportunities among Nisga’a businesses offerings • Identify relevant and potential joint venture opportunities ••Hold meetings with interested Nisga’a and develop connections and contact between Nisga’a businesses starting prior to the start of businesses and other companies with specialized goods construction and on an ongoing basis and services relevant to the mining industry throughout construction and operations • Support the emergence of the Incubation Centre and One Stop Business Shop by attending regular meetings Measures of Success: and providing information to determine opportunities for ••Numbers and size of contract awards collaboration and support to Nisga’a businesses ••Successful completion of work by Nisga’a Business Nisga’a businesses ••Increasing satisfaction among Nisga’a Opportunities and businesses with the procurement Strategies process based on feedback in an annual survey of Nisga’a businesses

• Develop a Nisga’a Business Database prior to the start of construction • Annually update the database with details about Nisga’a businesses.

Measure of Success: ••Increased engagement and awareness of the Project among Nisga’a Businesses ••Hold meetings with relevant parties regarding business opportunities and collaboration starting prior to the start of construction and on an ongoing basis throughout construction and operations

Measure of Success: ••Increased participation of Nisga’a Businesses in proponent bids and contracts.

90 CEAA—Comprehensive Study Report: Kitsault Mine Project Table 5-2: Frameworks for the Nisga’a Nation Economic, Social and Cultural Management Plans continued Strategies of the Management Proponent Action Outcomes and Measures of Success Plan Economic Closure Plan • Provide résumé preparation, job search skill assistance • Implement the Human Resource and business management and career coaching services Closure Plan one year in advance of to Nisga’a employees at the mine site closure • Develop a workforce skills and experience inventory and • Distribute the Kitsault skills and distribute it among potential external employers experience inventory to potential • Communicate with human resource personnel of other external employers one year in advance major projects in the region and elsewhere to ensure there of closure is knowledge of the available workforce • Hold meetings with human resource • Work with NLG and Nisga’a Villages and regional personnel of other major projects in the employment assistance agencies to facilitate connections region one year in advance of closure between workers and other potential employers • Hold meetings and establish relationships with regional employment assistance agencies one year in advance of closure Closure Transition Measures of Success: Support ••Percentage of Nisga’a workers that utilize internal transition assistance services ••Percentage of Nisga’a workers that utilize external transition assistance services ••Frequency of access by external parties to workforce skill and experience inventory ••Number and percentage of Nisga’a workers that secure alternative employment ••Number and percentage of Nisga’a workers that move from their home community

CEAA—Comprehensive Study Report: Kitsault Mine Project 91 Table 5-2: Frameworks for the Nisga’a Nation Economic, Social and Cultural Management Plans continued Strategies of the Management Proponent Action Outcomes and Measures of Success Plan Communications Plan • Develop and make reasonable efforts to implement the • Complete and implement Communications Plan, which will establish protocols and Communications Plan before the start of procedures for internal and external communications construction targeting different parts of the Nisga’a Nation, including • Hire and retain a Manager of the NLG, Nisga’a businesses, Nisga’a labour force and Community Affairs before the start of Nisga’a Villages during the various phases of the Kitsault construction Mine Project (including construction, operations and • Complete and communicate the Human closure) Resources Closure Plan a minimum of • Hire a Manager of Community Affairs (preferably a Nisga’a one year before the anticipated closure citizen) to implement the Communications Plan date

External Communications: Measures of Success: • Nisga’a Citizens: Four annual newsletters, regular updates ••Communications plan adhered to by to the corporate website, monthly updates and event relevant parties postings on www.nnkn.ca and one annual community ••Consistent communications records meeting in each Nisga’a Village ••Level of awareness among Nisga’a • Nisga’a Lisims Government: Hold two meetings a year citizens about the Project with the NLG and local representatives (as directed by the ••Level of coordination and collaboration NLG) to support the ongoing transfer of information to local between the proponent and the NLG health, social, cultural and educational service providers to identify, discuss, and address regarding details of mine planning schedules and activities economic, social, and cultural effects • Nisga’a businesses: Give advance notice of potential of the Project Communications Project business opportunities and work packages to ••Level of awareness among Nisga’a Plan Nisga’a businesses. Notices will be sent via email, regular businesses about the procurement mail, and fax to Nisga’a businesses and advertised on opportunities related to the Project www.nnkn.ca and in local newspapers ••Number of advanced notices provided • Nisga’a labour force: Quarterly advertisements of to Nisga’a businesses employment opportunities among Nisga’a citizens via ••Level of awareness among the local newspapers, websites, social media and local Nisga’a work force members about organizations employment opportunities at the mine site Internal Communications: ••Level of awareness among Nisga’a • Raise awareness and recruit Nisga’a employees employees about training opportunities to training, educational, and career advancement ••Level of awareness among Nisga’a opportunities employees about Human Resources • Communicate and implement human resources policies at Policies and grievance mechanisms the mine site ••Level of awareness among Nisga’a • Identify and seek to address Nisga’a employee issues, employees about closure schedules, concerns, and grievances using several mechanisms (e.g., activities and changes (as measured 360 Feedback and the Nisga’a employee advisory group) by surveys conducted at the end of • Develop and implement a Human Resources Closure Plan shifts) to communicate the schedule of activities widely, changes in work requirements (including positions required during closure), hours, and termination dates to mine workers and suppliers via letters and workshops at the mine site and in the communities

92 CEAA—Comprehensive Study Report: Kitsault Mine Project 5.2.4 Nisga’a Nation Comments the need for the proponent to develop specific commitments for monitoring family and The Nisga’a Nation expressed concerns about the community well-being that include triggers for lack of specificity of the proposed management remedial action if unanticipated effects emerge. plans and the resulting underestimation of the Project’s adverse economic, social and cultural The Nisga’a Nation submitted that, in the effects on Nisga’a citizens. Concerns focused on absence of specific commitments to monitoring the omission of a process for: 1) defining specific and management actions by the proponent, targets, indicators or commitments; 2) determining predictions regarding the economic, social and thresholds beyond which remedial action is cultural impacts of the Project on Nisga’a citizens required; and, 3) monitoring progress. The are unsupported. Nisga’a Nation also noted its limited capacity to participate in the development and implementation 5.2.5 Agency Conclusions on of management plans and emphasized that the 8f Assessment responsibility for any residual project-related costs rests with the proponent. Chapter 10, paragraph 8(f) of the NFA sets out that for all EAs covered by the NFA, B.C. and To address economic effects, the Nisga’a Nation Canada are required to “assess the effects of suggested that specific training initiatives and the project on the existing and future economic, employment and business contract targets be social and cultural well-being of Nisga’a citizens established in order to evaluate, on an ongoing who may be affected by the project.” basis, the extent to which Nisga’a citizens and businesses realize the economic benefits The potential economic, social and cultural associated with the Project. Other comments effects of the Project on the well-being of Nisga’a included the need for more details on the range citizens were evaluated during the EA. The of possible economic impacts, including details Agency took into consideration plans proposed on employment and business effects, effects on by the proponent to manage potential adverse NLG revenues and expenditures, and opportunity economic, social and cultural effects. Based on costs of predicted employment. However, in the information in this report, the Project may the absence of these details, the Nisga’a Nation result in both adverse and positive effects on the questioned the basis for predicting net economic social and cultural well-being of Nisga’a citizens benefits of the Project to Nisga’a citizens. and contribute to modest improvements in their economic well-being. With respect to social and cultural effects, the Nisga’a Nation noted the uncertainty regarding project-related effects on Nisga’a migration and community population levels and the associated demands on Nisga’a families, communities and community infrastructure and services. The comments indicated that the extent of effects on family and community well-being and on cultural activities will largely depend on the implementation and effectiveness of proposed policies and programs, and the identification of and response to social and cultural issues as they arise. The Nisga’a Nation emphasized

CEAA—Comprehensive Study Report: Kitsault Mine Project 93 6. Treaty and Aboriginal Consultation

The federal government has a duty to consult and, where appropriate, to accommodate, when it has knowledge that its proposed conduct might adversely impact an established or potential The federal government Aboriginal or Treaty right. Consultation is also undertaken more broadly as an important part of has a duty to consult good governance, meaningful policy development and informed decision-making. and, where appropriate,

In addition to the federal government’s to accommodate, when broader obligations, the former Act requires that all federal EAs consider the effect of any it has knowledge that its environmental change caused by the Project and also the effect of that change on current use of proposed conduct might lands and resources for traditional purposes by Aboriginal peoples. The former Act also requires adversely impact an consideration of the effect of any project-related environmental change on physical and cultural established or potential heritage, and “any structure, site, or thing that is of historical or archaeological significance.” Aboriginal or Treaty right.

The Agency served as the Crown consultation coordinator and, together with the relevant federal departments, integrated consultation with 6.1 Nisga’a Nation the EA process to the extent possible. In this Consultation Activities role, the Agency ensured that Aboriginal groups were provided with opportunities to (a) learn Provisions under Chapter 10 of the Nisga’a about the project, (b) evaluate the project, and (c) Final Agreement specify the requirements for communicate their concerns to the Crown. consultation with the Nisga’a Nation in relation to an EA of a project. The Government of Through the federal government’s Participant Canada worked collaboratively with the NLG Funding Program, funding was made available and the Government of B.C. as part of a tripartite to reimburse eligible expenses incurred by government approach to: 1) ensure that the Aboriginal groups during their participation in Nisga’a Nation was informed about the Project; the EA. The Nisga’a Nation, GHCO (on behalf 2) understand the potential impacts of the Project of Gitanyow Huwilp Wiitaxhayetwx-Sidok, on Nisga’a Nation treaty rights under the NFA; Huwilp Gwass Hlaam, Huwilp Gwinuu, and and, 3) elicit Nisga’a Nation feedback on how Huwilp Gamlaxyeltxw), Gitanyow Huwilp the NFA applies to different phases of the EA Luuxhon, Gitxsan Nation, Kitselas First Nation, process. Kitsumkalum First Nation and the Métis Nation of B.C. (MNBC) were provided with funding under the Participant Funding Program.

94 CEAA—Comprehensive Study Report: Kitsault Mine Project The Agency invited the NLG to review boundaries of its asserted traditional territory, has and provide comments on key documents the potential to infringe Metlakatla First Nation’s relating to the EA, including the federal EIS potential rights and affect Metlakatla First guidelines, the EIS and corresponding reports, Nation’s interests. this comprehensive study report and all of the products associated with the proponent’s Representatives of the Metlakatla First Nation ESCIA. Additional information was received were invited to participate in the TWG to discuss from the NLG through working groups (EA and different aspects of the proponent’s EIS and the transportation), technical subgroup meetings, draft of this report. The Agency also received bilateral and trilateral government meetings, feedback and information from the Metlakatla correspondence, open houses in Nisga’a villages First Nation through face-to-face meetings and and supplementary information documents. The correspondence. NLG also provided its draft ESCIA Guidelines to the Agency and the BC EAO to guide the scope 6.2.2 Gitanyow First Nation and contents of the proponent’s ESCIA. Meetings held between the NLG, Agency and BC EAO Although the project footprint is situated outside provided opportunities to collectively discuss of the asserted territory of the Gitanyow First issues related to the ESCIA and to inform the Nation, the proposed transportation corridors proponent of information gaps that needed to be intersect portions of the asserted territories of five addressed. Funding was allocated to assist the Gitanyow Huwilp, including the Gitanyow Huwilp NLG to participate in the activities related to the Luuxhon. The GHCO represented the interests federal EA. of the Gitanyow Huwilp Watakheyetsxw, Huwilp Gamlaxyeltxw, Huwilp Gwass Hlaam and Huwilp 6.2 Consultation Activities related Gwinuu while the Gitanyow Huwilp Luuxhon to Potential Aboriginal Rights participated in the EA as a separate entity.

Aboriginal groups that were contacted and invited The GHCO and the Gitanyow Huwilp Luuxhon to participate in the consultation activities had were invited to participate to the TRWG to been identified as potentially having asserted exchange information on the potential effects of Aboriginal rights that could be adversely impacted road use, and provide input into the proponent’s by the Project. These groups included Metlakatla measures for spill response. Important information First Nation, GHCO, Gitanyow Huwilp Luuxhon, was also received through one-on-one meetings, Gitxsan Nation, Kitselas First Nation, Kitsumkalum direct correspondence, public open houses and First Nation, and MNBC. comment periods on the EIS and other documents, including the draft of this report. Both the GHCO 6.2.1 Metlakatla First Nation and Gitanyow Huwilp Luuxhon were provided with funding to participate in these activities Based on the available information gathered related to the transportation aspects of the Project. during the EA, the Agency identified that the mine footprint and six kilometres along one of 6.2.3 Gitxsan Nation the proposed transportation corridors (i.e., mine site along the Nass FSR to Highway 113 south to The project footprint is situated outside the Highway 16) overlap with the asserted territory asserted territory of the Gitxsan Nation; of the Metlakatla First Nation. Correspondence however, the proposed transportation corridor received from the Metlakatla First Nation from Highway 16 along Highway 37 to the confirmed that the Project, situated within the mine site intersects the territories of three

CEAA—Comprehensive Study Report: Kitsault Mine Project 95 Gitxsan wilp, including Tenim Gyet (for to participate in the consultation process for the 13.8 km), Gaxsbgabaxs (for 3.7 km), and EA. Preliminary information provided to the Sakxam Higookxw (for 9.0 km). The Agency’s Agency in 2010 suggested that MNBC citizens consultation activities with the Gitxsan Nation from adjacent chartered communities could be were related to the proponent’s intended use of exercising their potential Aboriginal rights to Highway 37 and the potential for transportation- harvest near the Project. MNBC was provided related effects such as wildlife mortality and funding to participate in the EA, kept informed spills. Funding was provided for Gitxsan Nation of EA milestones and was invited to comment on participation in the EA, including involvement in key documents. the TRWG. 6.3 Proponent Engagement 6.2.4 Kitsumkalum First Nation The legal responsibility to consult and The asserted territory of the Kitsumkalum First accommodate rests with the Crown. However, Nation covers the extent of the Kitsumkalum the efforts of the proponent can assist in the valley from Terrace to Sand Lake and therefore overall consultation process and inform not only overlaps with the proposed transportation the assessment of potential adverse impacts of corridor that travels from the mine site to Terrace the Project on asserted Aboriginal rights but via Highway 113. Funding was provided to also appropriate mitigation or accommodation the Kitsumkalum First Nation to participate in measures that may be required to address the the TRWG and to provide input during public potential impacts. comment periods and open houses. The following are examples of consultation 6.2.5 Kitselas First Nation activities the proponent led during the EA process: Neither the mine footprint nor the proposed transportation corridors intersect the asserted ••sharing of project information territory of the Kitselas First Nation; however, ••participation in working group meetings it was determined that the close proximity of ••organization of site visits, community meetings project-related traffic along Highway 113 through and open houses Terrace could affect the Kitselas First Nation’s ••provision of capacity funding to participate in the current use of lands and resources in the area. In review process and for community engagement consideration of these potential effects, funding ••financial support and coordination of field was made available to the Kitselas First Nation to activities, including a survey of areas along the participate in the federal EA. The Kitselas First transportation corridors where barrier protection Nation was also invited to the TRWG to provide could be warranted to protect ecologically input into project-related road use issues and sensitive areas from future spills or accidents proposed mitigation measures. Information collected by the proponent during its 6.2.6 Métis Nation of British Columbia Aboriginal consultation program was considered in the Agency’s determination of any potential The Métis Nation of British Columbia (MNBC), adverse impacts of the Project on potential or a consultative body representing chartered Métis established Aboriginal and treaty rights. communities in B.C., notified the Agency of its interest in the Project and was therefore invited

96 CEAA—Comprehensive Study Report: Kitsault Mine Project 6.4 Summary of Key Issues the NLG stated the need for a better understanding of the cumulative effects of the Project and Project effects that could potentially affect historical tailings disposal in Alice Arm from Aboriginal rights were considered during the previous Kitsault Mine operations. review of the proponent’s EIS through the participation of Aboriginal groups on the TWG The NLG advocated for water treatment during and TRWG, and through direct consultation all mine phases to address predicted exceedances meetings with the Metlakatla First Nation, of BC WQGs and recommended changes to the Gitanyow First Nation, Gitxsan Nation and AEMP and MEMP, including the evaluation MNBC. The potential effects of the Project on of ecosystem health effects and the monitoring the treaty rights of the Nisga’a Nation, as defined of clams. Questions were raised regarding by the NFA, are discussed in Chapter 5 of this the proponent’s water quality predictions. comprehensive study report. The NLG requested the opportunity to review the proponent’s baseline water quality data, The Agency maintained an issues tracking table water quality model predictions and associated to follow and respond to all information related modeling assumptions. Specific comments on the to potential or established Aboriginal rights, derivation and output of the proponent’s water potential adverse impacts on those rights and quality predictions were provided. proposed mitigation or accommodation measures. This table was shared with Aboriginal groups The NLG sought assurances that BC WQGs contacted during the EA process, for review and or Site Specific Water Quality Objectives be comment. A summary of the substantive issues used to evaluate the protection of aquatic life raised by Aboriginal groups follows. in Lime Creek. The proponent’s use of water quality management targets was not considered 6.4.1 Nisga’a Nation appropriate to replace the guidelines and protocols developed by the BC MOE to manage water During the EA, the NLG raised a range of quality in the province. The NLG asserted that issues regarding the Project through written any approach other than following the approved correspondence to the Agency, comments on provincial process for protecting aquatic life was proponent documents and concerns expressed at not acceptable to the Nisga’a Nation. the TWG and other working groups. The NLG requested more information on the Comments were provided about the predicted proposed closure plan for water management, effects of the Project on water quality in the Lime in particular a conceptual model of the water Creek and Clary Creek freshwater environments flows and contaminant loads for closure and post and the mitigation measures proposed to closure, the approach for sludge management address these effects, including mine site water post closure, and the basis for long-term management and water treatment. The NLG raised mitigation strategies such as cover design. With concerns regarding mine site discharge into Lime respect to ML/ARD, concerns were raised about Creek and the ecological implications of such the management of waste rock and PAG rock, discharge on downstream water quality, sediment the feasibility of segregating PAG from non- quality and marine biota in Alice Arm. Comments PAG, the location of the LGS and long-term were focused on both ecosystem and human health water treatment during post closure. Further risks associated with increased metal loading in clarification was sought regarding the proponent’s marine sediment and shell fish that are important PAG waste rock management strategy, including to Nisga’a Nation harvest food diet. Furthermore, the consideration of submerging PAG waste

CEAA—Comprehensive Study Report: Kitsault Mine Project 97 rock and the possibility of moving the LGS NLG comments regarding the Nisga’a effects closer to the Kitsault Pit to manage long-term assessment in the EIS focused on clarifications water quality effects. The NLG questioned the of intent, content, terminology or interpretation accountability, enforcement and net present value of the NFA and the applicability of the socio- for water treatment with the onset of ARD after economic data sources and information. As for closure, indicating that the responsibility for the the ESCIA, the NLG raised concerns about legacy of the mine should fall to the proponent. the lack of detail with regard to the mitigation measures to address economic, social and cultural Concerns were raised about moose mortality, effects. The NLG requested that the proponent specifically from the increase in winter access conduct additional site-specific land use analyses along the Nass FSR, the corresponding increase to assess effects to marine harvesting in Alice in illegal and unregulated hunting pressure, Arm and wildlife and vegetation harvesting in and the cumulative increase in regional traffic. the Kitsault mine site area. The NLG stated that the proposed Wildlife Management Plan must include requirements to 6.4.2 Metlakatla First Nation support Nisga’a Nation participation in additional enforcement when access along the Nass FSR The Metlakatla First Nation asserts an Aboriginal increases during the winter. Monitoring wildlife right to access and harvest marine resources from mortality along the proposed transportation their traditional territory. Potential project-related corridors was also discussed as an important effects on these rights relate to changes to surface element in identifying and mapping sensitive water quality in Lime Creek and Clary Creek and areas where moose are most vulnerable. the resulting downstream implications on marine water quality and organisms in Alice Arm. The NLG strongly opposed the notion to close the Nass FSR by stating that the closure of Concerns were noted regarding the extent this road during the winter months is “not an of existing water quality and sediment effective strategy for mitigating potential impacts contamination in Alice Arm from historical to moose and moose habitat.” Through written mining activity and the need to characterize correspondence to the BC MFLNRO, the NLG the extent and severity of this contamination outlined various reasons behind its position through monitoring that would, in turn, determine and requested that the proponent open the Nass outcomes for local harvesters. Cumulative effects FSR during the winter months and participate arising from the combination of elevated metal in any coordinated regional strategy on access concentrations in the freshwater environment and management and moose conservation. the residual marine concentrations from historical mining were also identified as important to the Concerns were raised about the effects of the Metlakatla First Nation. It was recommended TMF on wetlands and fish and fish habitat that the MEMP include sampling of marine and the need to capture these impacts in species that are harvested and consumed by First appropriate management plans (i.e., Wetlands Nations and specify the actions to be taken when Habitat Compensation Plan and FHCP). elevated levels of contaminants are detected The NLG provided feedback on the contents in the freshwater or marine environments. The of these conceptual management plans and Metlakatla First Nation advocated that the requested ongoing meaningful engagement and proponent develop a communications plan with consultation to incorporate Nisga’a interests them to establish Metlakatla involvement in as the management plans are finalized after the the development, implementation and reporting conclusion of the EA.

98 CEAA—Comprehensive Study Report: Kitsault Mine Project activities of environmental management plans, moose available for the Gitanyow First Nation to wetland and fish habitat compensation plans and exercise their right to hunt or harvest moose. monitoring programs. The GHCO provided the Agency with The Metlakatla First Nation also raised issues information related to the moose population in related to the project-related effects on socio- the Nass Valley and mitigation measures used economic interests and other issues that were in other jurisdictions to reduce vehicular moose not directly related to Metlakatla First Nation’s mortality. This information indicated that the potential Aboriginal rights. These issues were moose population in the Nass Valley had declined instructive in guiding the federal EA process from 638 in 2007 to 517 in 2011 and that the and related consultation activities. majority of moose migrated along the Nass FSR to the Cranberry River during the winter. 6.4.3 Gitanyow First Nation and Concerns were raised about the effects on moose Gitanyow Huwilp Luuxhon in their critical winter habitat of year-round vehicular access to the Nass FSR. The issues raised by the GHCO focused on the potential effects of increased road use The documentation provided by GHCO along the proposed transportation corridors on throughout the EA contributed to the Crown’s wildlife, notably moose. The GHCO stated in understanding of the cultural importance of moose correspondence to the Crown that the proposed to the way of life of the Gitanyow First Nation and transportation corridors overlap with the asserted the importance of moose as a fundamental food territories of the Gitanyow Wilp Watakheyetsxw source. Meetings with GHCO have also helped (44.8 km), Wilp Gamlaxyeltxw (16.9 km), Wilp the Crown understand the GHCO’s position on Gwaas Hlaam (49.1 km), and Wilp Gwinuu mitigation measures to slow the decline of the (7.8 km) and that the Nass FSR provides current moose population, including the prospect important wintering habitat for moose, a species of temporarily closing the Nass FSR during certain which Gitanyow communities depend on for food months of the winter. Comments focused on and for cultural and ceremonial purposes. The identifying and protecting habitat areas for moose, GHCO expressed that they have constitutionally using historical vehicle-moose collision data, protected Aboriginal rights to harvest moose and enforcing unregulated harvesting of moose, and other traditional foods from their territory. funding for additional monitoring of and education about moose conservation. The GHCO, as members of the TRWG, provided detailed and insightful information In addition to concerns about moose, the and feedback related to the potential effects of Agency also received comments regarding the transportation corridors on Gitanyow First the vulnerability of local water bodies (e.g., Nation’s Aboriginal rights. The majority of the Cranberry River) to potential spills and accidents concerns were focused on the potential direct and along the Nass FSR and the downstream cumulative effects of increased road use along the effects of such events. The GHCO advocated Nass FSR on the regional moose population. The that the proponent and government agencies GHCO clarified, through written correspondence involve Gitanyow First Nation members in any to the Agency, that any further decrease to the emergency response measures or initiatives declining moose population, either because of developed for the transportation corridors. the Project or because of the cumulative increase Comments were also made regarding the effects in traffic along Highway 37, would reduce the of increased traffic on human safety

CEAA—Comprehensive Study Report: Kitsault Mine Project 99 in communities along the transportation of any spill would be difficult to clean up during corridors, access to fishing sites, and other winter when the lake is frozen and when recovery wildlife including grizzly bears and furbearers. of materials and equipment would be challenging. The Kitsumkalum First Nation requested to be Participation of the Gitanyow Huwilp Luuxhon involved in the development of the proponent’s was limited during the EA. Comments received Mine Emergency and Spill Response Plan that by the Agency were in opposition to the notion includes establishing a response team located in of closing the Nass FSR during the winter, in the Kitsumkalum community. view of the economic opportunities for the Huwilp associated with the use of the proposed Comments were also noted regarding the transportation corridor along Highway 37. potential effects of project-related traffic on the moose population, the need for roadside barrier 6.4.4 Gitxsan Nation protection, and the increase in traffic along the Nisga’a Highway (Highway 113) and through The Gitxsan Nation raised concerns regarding the Kitsumkalum asserted traditional territory the potential effects of the Project on the Nass should the use of the Nass FSR be restricted. River and the watersheds in Gitxsan territory, The Kitsumkalum First Nation requested to including the Nass, Lower Skeena, Kitseguecla be involved in reporting moose kills and in and Saskwa. These watersheds are important timely consultation on the development of a to the Gitxsan Nation as they provide fish and communications protocol with the proponent. wildlife for sustenance and resources for cultural practices. As a member of the TRWG, concerns 6.4.6 Kitselas First Nation were expressed about the increase in vehicle traffic moving through Gitxsan territories and The Kitselas First Nation did not raise any the cumulative effect of more traffic interacting concerns or provide any written feedback with wildlife (e.g., deer, grizzly bears, moose regarding the Project during the EA process. and other wildlife). The Gitxsan Nation also commented on the implications of ploughed snow 6.4.7 Métis Nation of British Columbia affecting steelhead in the Cranberry River and the effects of invasive species on medicinal plants Issues raised by MNBC during the review of the along the transportation corridors. Project include the assertion of Aboriginal rights in the project area and a desire to be included 6.4.5 Kitsumkalum First Nation in the scope of Crown consultation related to the EA process. MNBC identified that the As a participant on the TRWG, the Kitsumkalum construction and operation of the Project could First Nation expressed the importance of put local Métis Aboriginal rights and traditional Kitsumkalum River and Lake as traditional areas land uses at risk by adversely affecting harvesters for hunting and fishing. Concerns were raised who rely on the area for sustenance, social and about the potential for vehicular accidents with ceremonial purposes. Concerns centred on the moose, bears, and furbearers, and for spills contingency measures that will be undertaken by and downstream effects on Kitsumkalum Lake, the proponent should the Project affect surface which provides habitat for Chinook salmon and and groundwater quality and on the monitoring of spawning channels for sockeye salmon along the such effects on fish in the lake environment. roadside. It was noted that the downstream effects

100 CEAA—Comprehensive Study Report: Kitsault Mine Project 6.5 Mitigation and Accommodation will be appropriately avoided, mitigated or accommodated. The potential impacts on potential Aboriginal rights and related interests, and the appropriate The Agency is satisfied that the consultation mitigation and accommodation measures, and accommodation obligations, including the were considered throughout the EA process, implementation of mitigation measures, are particularly through consultation during the commensurate with the Crown’s assessment of review of the EIS. Mitigation measures developed the potential Aboriginal rights in the project area in response to issues raised by Aboriginal and the potential adverse effects of the Project groups that participated in the EA process are on these potential rights. Additional consultation described in Appendix I. The proponent will and accommodation measures may be considered also make reasonable efforts to ensure that the as part of the post-EA permitting phase should Metlakatla First Nation, Gitanyow First Nation, new information arise (post-consultation on this Gitxsan Nation and Kitsumkalum First Nation document) that require changes to the Crown’s continue to be involved in environmental studies assessment. or monitoring programs during the regulatory phase of this project. Appendix I describes key After the EA concludes, the RAs will continue mitigation and monitoring measures that address Crown consultation with Aboriginal groups potential impacts on potential Aboriginal rights as appropriate on matters associated with any to hunting, fishing, trapping, harvesting and other federal regulatory approvals required for the land uses. Project to proceed. 6.6 Agency Conclusions Regarding Impacts to Aboriginal Rights

As a result of Crown consultation with the Metlakatla First Nation, Gitanyow First Nation, Gitanyow Huwilp Luuxhon, Gitxsan Nation and the MNBC, throughout the EA process, the Crown better understands the importance of certain areas near the mine site and along the transportation corridors to these groups’ potential Aboriginal rights related to food, cultural practices and other traditional uses.

The Agency has considered the mitigation measures to address the potential effects to water quality, fish and fish habitat (including the removal of non-fish bearing habitat), wildlife and wildlife habitat, wetlands and other VCs. As a result, the Agency is satisfied that adverse impacts of the mine on the continued exercise of potential Aboriginal rights in the area of the Lime Creek and Clary Creek watersheds and along the proposed transportation corridors

CEAA—Comprehensive Study Report: Kitsault Mine Project 101 7. Public Consultation

The former Act requires that the public be 7.1 Public Comment Summary provided with a minimum of three formal participation opportunities: one at the outset of All comments received were shared with federal the EA process, one during the comprehensive and provincial members of the TWG. The study process, and a final opportunity to review key environmental issues raised related to the and comment on this report. potential impacts on existing freshwater and marine water quality, fish and fish habitat, and The federal and provincial government agencies groundwater-surface water interactions. Other worked cooperatively throughout the EA process issues included opportunities for local training and collaborated wherever possible on public and employment and the ability of the TMF to consultation activities, including participation withstand natural seismic events. Appendix H in open houses and proponent-led public provides a summary of the key issues raised consultation activities. during the public comment periods conducted prior to this report. For this project, formal public consultation periods were held to receive comments on

a) the Project and the conduct of the comprehensive study (November– December 2010), and

b) the proponent’s EIS (May–June 2012; held jointly with BC EAO)

During the final public consultation opportunity, the Agency invites the public to comment on the content, conclusions and recommendations of this comprehensive study report.

Notices of these opportunities for public participation were posted on the Canadian Environmental Assessment Registry (CEAR) website. Notices were also provided in local media sources, and individuals and groups who had indicated an interest in the Project were notified directly. The Agency provided funding to support the public’s participation in the comprehensive study process through its Participant Funding Program.

102 CEAA—Comprehensive Study Report: Kitsault Mine Project 8. Follow-up under the Canadian Environmental Assessment Act

The purpose of a follow-up program required under the former Act is to verify the accuracy of the EA of a project and determine the effectiveness of measures taken to mitigate the The purpose of a follow-up adverse environmental effects of the Project. The results of a follow-up program may also program required under the support, where appropriate, the implementation of adaptive management measures to address former Act is to verify the unanticipated adverse environmental effects and environmental management systems to manage accuracy of the EA of a the environmental effects of projects. project and determine the The proponent has proposed a follow-up program to verify the accuracy of effects predictions effectiveness of measures or the effectiveness of mitigation for certain VCs. The detailed design and implementation taken to mitigate the of these programs will be completed following the Minister’s EA decision statement and NFA adverse environmental Project Recommendation. effects of the Project. 8.1 Water Management

A follow-up program is required to monitor and verify water quality predictions in Lime Creek The proponent will also develop a Mine and the effectiveness of mitigation measures in Site Water Monitoring Plan to quantify and protecting aquatic life. characterize mine site water and inform the development of additional management measures The proponent will develop the AEMP prior based data trends in water quality and quantity to construction of the Project to detect adverse over time. This plan will be provided to the NLG changes (e.g., cadmium, aluminum) that and Metlakatla First Nation and will complement may affect freshwater receptors (e.g., fish, the objectives and measures in the proponent’s aquatic plants) in Lime Creek and examine the Environmental Management System and AEMP. effectiveness of water management measures. The proponent will develop and implement Monitoring of ML/ARD will be undertaken additional management actions where monitoring in accordance with the proponent’s ML/ARD results exceed water quality guidelines. Potential Monitoring and Management Plan that will be effects will be monitored in surface and developed prior to the start of construction. The groundwater chemistry, hydrology, sediment plan will confirm geochemical characterisations and chemistry, primary and secondary producers, and adapt management approaches for different ML/ fish. The AEMP will include protocols for field ARD sources, if necessary. Components include: sampling and analysis, triggers for management actions and reporting. The proponent will provide • Data collection and ongoing characterization copies of monitoring reports to EC upon request of waste rock, low-grade ore, tailings and for review and follow up. construction material;

CEAA—Comprehensive Study Report: Kitsault Mine Project 103 ••An inventory of waste and low grade ore The proponent will develop the AEMP in production and placement for future assessments accordance with the requirements of the B.C. of facility performance; Environmental Management Act permit that ••Monitoring of water chemistry (i.e., seeps, pit includes provisions for additional management wall runoff, supernatant); and measures should effects to fish and fish habitat arise. ••Updates to water and metal loading to verify and refine water quality predictions for the Project. 8.3 Wildlife and Wildlife Habitat

The MEMP will be developed to detect potential The proponent will submit a Wildlife Management effects of the Project on defined water users Plan to EC prior to construction that includes (e.g. marine life, human health, wildlife) prior specific requirements for the protection of to effects occurring. Two years of marine migratory birds and active bird nests as defined environment monitoring data will be collected by the Migratory Birds Convention Act. and analysed to establish a baseline for the identification of potential effects before the 8.4 Wetlands and Species at Risk start of operations. The MEMP will involve monitoring of water quality, sediment chemistry The proponent will, prior to construction, submit and toxicity, and tissue chemistry of important a detailed Wetland Habitat Compensation Plan to marine resources including shellfish, intertidal EC that will identify options to offset effects of fish and BMI. Any effects identified through loss of wetland communities for migratory birds monitoring over time will inform and adapt and species at risk within the mine footprint. The the proponent’s management measures. The plan will take into account wetland functions to proponent will consult EC, the NLG, the migratory birds and species at risk and EC’s no- Metlakatla First Nation on the design and net-loss policy for wetland habitat compensation. development of the MEMP and, where required, will request HC’s expert advice on human health The proponent will also conduct a site assessment issues related to the harvesting and consumption survey for Cryptic Paw Lichen within and of marine resources by local communities. near the immediate mine footprint prior to the commencement of construction. Reporting of 8.2 Fish and Fish Habitat survey results and ongoing management measures will be completed in consultation with EC. The proponent will submit a FHCP to DFO before an authorization under subsection 35(2) 8.5 Other Valued Ecosystem of the Fisheries Act may be issued. DFO will Components continue to consult with the NLG on the design and implementation of the FHCP following The Agency identified minor residual effects conclusion of the EA if the EA decision enables to vegetation, cultural foods and current use of the Project to proceed. The primary objective of lands and resources for traditional purposes by this plan is to offset unavoidable impacts to fish Aboriginal people. The assessment of effects habitat through the creation of new habitat or relies on measures that will be further defined and improvement of existing habitat. Since the FHCP implemented through environmental management is part of the regulatory process following the plans for air quality, vegetation and soils. These conclusion of the EA, it is not considered part of plans and their adaptive management measures the follow-up program under the former Act. may be amended or updated during the life of the Project to address changes in environmental conditions or observed environmental effects.

104 CEAA—Comprehensive Study Report: Kitsault Mine Project 9. Benefits to Canadians

The EA as a planning process can substantially influence a project’s design or alternatives. The Through this process, Agency, assisted by RAs, federal authorities, provincial agencies, the NLG and Aboriginal changes were made to the groups, evaluated the Project. Through this process, changes were made to the Project, and Project, and associated associated activities – mitigation, monitoring and follow-up program – to avoid or minimize activities – mitigation, potentially adverse effects as much as possible. For example, the proponent’s water management monitoring and follow- approach was revised to incorporate in-mill, lime addition and active water treatment that up program – to avoid or is expected to reduce metal concentrations in water discharged into the natural receiving minimize potentially environment. The Project design has also been changed to allow continuous discharge of water adverse effects as much from the TMF that reflects the natural hydrograph of Lime Creek and to collect and direct seepage as possible. and runoff from the LGS and the existing Clary and Patsy waste dumps to the TMF during all project phases.

The NLG and Aboriginal groups identified that the current decline of the moose population in the Nass Area could potentially be affected by the Project. Because moose are of high value ecologically, culturally and economically, the proponent, with input from the NLG and Aboriginal groups, developed mitigation measures to address the potential effects on moose along the Nass FSR. These measures include: implementing a speed limit for mine- related vehicles along a stretch of the Nass FSR, making improvements to the intersection of the Nass FSR and Highway 37, providing accommodation at the mine site for Conservation Officers or other enforcement personnel during enforcement activities, supporting recovery of the Nass moose population and participating in any cross industry or government initiatives related to road use, including a coordinated approach to manage cumulative effects to aquatic and wildlife populations along Highway 37.

CEAA—Comprehensive Study Report: Kitsault Mine Project 105 10. Conclusions of the Agency

10.1 Canadian Environmental DFO and NRCan for appropriate course of action Assessment Act in accordance with Section 37 of the former Act.

The Agency has taken into account the following 10.2 Nisga’a Final Agreement elements in reaching a conclusion on whether the Project is likely to cause significant adverse In addition to the requirements of the former Act, environmental effects: the Agency assessed the effects of the Project on the Nisga’a Nation in accordance with Chapter 10, • documentation submitted by the proponent, paragraphs 8(e) and 8(f) of the NFA, as part of including the EIS, technical memoranda and the environmental assessment process. responses to information requests • analysis and findings in this comprehensive In assessing the adverse environmental effects study report on residents of Nisga’a Lands, Nisga’a Lands, • opinions and comments of the public, government or Nisga’a interests as required under paragraph agencies, the NLG and Aboriginal groups 8(e), the Agency considered the analysis of • the proponent’s obligations as documented in this environmental effects under the former Act as report and summarized in Appendix C applicable. The Agency concludes that the Project • the regulatory authorizations and permits the is likely to result in adverse, but not significant, proponent will be required to obtain, namely: environmental effects on Nisga’a Nation treaty • a Fisheries Act authorization and the interests related to fisheries, wildlife and associated FHCP migratory birds, and forest resources. No adverse • a licence under subsection 7(1)(a) of the effects are predicted to water and to cultural Explosives Act for the manufacture and artefacts and heritage as described in the NFA. storage of explosives The Agency considers the mitigation measures as described in this report and summarized in The environmental effects of the Project have Appendix C appropriate to prevent or minimize been determined using assessment methods the adverse environmental effects identified that reflect the current best practices of impact under paragraph 8(e). assessment practitioners. The Agency concludes that with the implementation of mitigation The 8(f) assessment of economic, social and measures, the Project is not likely to cause cultural effects was considered as a matter relevant significant adverse environmental effects. to the assessment under section 16(1)(e) of the former Act. Although not specified in paragraph Following a public consultation on this report, 8(f), the Agency took into consideration plans the Minister of the Environment will decide proposed by the proponent to manage potential whether, taking into account the implementation adverse economic, social and cultural effects. of mitigation measures, the Project is likely to The Agency concludes that the Project may cause significant adverse environmental effects. have both adverse and positive effects on the Should the EA decision allow the Project to social and cultural well-being of Nisga’a citizens proceed, the Project will then be referred back to and contribute modest improvements in their economic well-being.

106 CEAA—Comprehensive Study Report: Kitsault Mine Project In accordance with Chapter 10, paragraph 8(h), the Minister of the Environment will issue an NFA Project Recommendation in respect of whether the Project should proceed, alongside the EA decision statement. Any regulatory decisions that may be taken by the responsible authorities – DFO and NRCan – will take into account the NFA Project Recommendation issued by the Minister.

The Agency concludes that

with the implementation

of mitigation measures,

the Project is not likely to

cause significant adverse

environmental effects.

CEAA—Comprehensive Study Report: Kitsault Mine Project 107 11. Appendix for processing. A long-term stockpile will store up to 36 Mt of low grade ore mined early in the Appendix A life of the Project and mined during operations. A Project Components and Activities coarse ore stockpile will store crushed ore during processing, with a live load of up to 60 000 tonnes. This appendix provides further details on major project components and activities. Tailings Management Facility The TMF will manage tailings, which include Project Components bulk rougher tailings and pyritic or cleaner/ scavenger tailings. The TMF has been Waste Rock Management Facility designed for secure and permanent storage of The WRMF is the area where waste rock mined approximately 270 Mt of tailings. from the Kitsault Pit will be deposited and includes a channel to divert non-contact water The tailings impoundment and supernatant pond around the WRMF. Snow will be deposited at the will be created by two embankments constructed western edge of the WRMF each winter, which is with a combination of local borrow materials, the adjacent rather than on top of the waste rock. cyclone sand fraction of the tailings, and waste rock from the mining operation. The TMF includes Explosives Manufacturing Facility and a south (rockfill) embankment, a northeast Storage Magazines (cyclone sand) embankment, cyclone sand towers, Explosives manufacturing and storage facilities bulk and cleaner tailings delivery and distribution include a factory, magazine facilities, silos, pipeworks, freshwater channel diversions, a garage, fuel storage, and power supply. As seepage collection system, a reclaim system to required, explosives components will be mixed recycle water to the process plant and a surplus on site in a purpose-built explosives mixing water system to release water to Lime Creek. facility and transported to the mine site in purpose-built mixing trucks. The explosives Tailings Distribution System manufacturing facility and magazine areas are The tailings distribution system will deliver and located up a side road from the mine site road, distribute tailings from the processing facilities about 500 m to the northeast of the TMF. The to the tailings impoundment and supernatant following components will be stored on site: pond. Both the final cleaner tailings and the final bulk tailings leave the plant by pipelines for • Ammonium nitrate transport to the TMF. Bulk tailings will be split • Emulsifier in a distribution box in the process plant and then • Fuel Oil directed either to the cyclones or to the TMF • Primers embankments. They will be discharged away • Detonators from the embankment faces to provide addition seepage control and keep the surface pond remote The manufacturing of explosives and storage from the embankments. The coarse fraction of ammonium nitrate and explosives will be in from the cyclones will be used for embankment conformance with the Explosives Act which is construction, while the fine fraction must be administered by NRCan. placed within the TMF. The cleaner and pyritic tailings stream will be deposited into a separate, Ore Stockpiles permanently submerged area of the TMF, away A short-term stockpile will be used to store small from the tailings beaches and embankments to quantities of ore (up to 340 000 t) before it is sent prevent oxidation that may lead to ML/ARD.

108 CEAA—Comprehensive Study Report: Kitsault Mine Project Water Management Facilities Mine Site Roads Contact water (i.e., water, seepage or runoff The mine site will have a network of general that has been in contact with historical mining vehicle roads around the facilities, service roads features and new mine facilities) will be collected to remote structures, and haul roads. and directed to the TMF. This process will be maintained until closure. Road Access Road access to the mine site will be either: Processing Facilities Processing facilities will process ore mined from 1. From the Highway 16 turn-off west the Kitsault Pit into a concentrate. The crushed ore of Terrace: must be conveyed over a horizontal distance of up ••North along Highway 113 (Nisga’a to 1500 m to the course ore stockpile. The process Highway) to Nass Camp, east along the plant will include the mills, flotation cells, capacity Nass FSR (i.e., Cranberry Connector) to for water treatment, and process systems. the junction of the Nass-Kinskuch FSR. From this junction, southwest along the Infrastructure and Ancillary Facilities Nass-Kwinatahl FSR, then northwest Infrastructure facilities will include all buildings, along the Kitsault FSR to the existing shops, utilities, and services necessary to mine site road. support mining and ore processing activities. A 2. From the Highway 16 turn-off at Kitwanga: truckshop is required for equipment and vehicle ••North along Highway 37 to the Nass maintenance. Fuel will be stored in a manner FSR and west along the Nass FSR to consistent with regulations at other locations the junction of the Nass-Kinskuch FSR. within the mill site. Liquid propane will be From this junction, southwest along the stored in mobile tanks. Accommodations will Nass-Kwinatahl FSR, then northwest be constructed for a peak of 700 workers. An along the Kitsault FSR to the existing administration and change room facility will be mine site road. constructed. Human waste from the campsite will be treated with a sewage treatment plant. Non- The proponent will undertake any necessary road hazardous waste will be segregated into two streams and bridge modifications, vegetation brushing, that will either be burned in on-site incinerators or dust suppression and snow removal along the collected and disposed of within an on-site landfill. Nass, Nass-Kwinatahl, Nass-Kinskuch, Kitsault An explosive manufacturing facility and related FSRs and the Alice Arm Road to the mine site explosives magazines will be constructed for as per provincial permit requirements. blasting purposes at the Kitsault Pit. Project Activities Power Supply and Distribution Power will be provided by diesel generators Construction during construction until power from the grid The construction period includes pre-production becomes available on site. Power for operations mining (i.e., mining of waste rock and stockpiling of will come from an existing B.C. Hydro 138-kV ore) that will supply materials for the construction transmission line from the New Aiyansh substation, of mine infrastructure. Pre-production mining will approximately 70 km away. The incoming also include developing mine access roads suitable transmission line will terminate at a new main for large mining equipment. Construction will occur substation at the project site. between year zero and year two and may overlap with some components of operations.

CEAA—Comprehensive Study Report: Kitsault Mine Project 109 Sourcing Construction Materials Open Pit Preparation Construction materials and large-scale mining The initial open pit access and pre-stripping and construction equipment will be delivered via was largely completed during the historical Highway 113 or Highway 37, while aggregates development of the open pit. Waste rock from will be sourced at the mine site. pre-stripping will be used as fill in areas except the starter South Embankment, if non-PAG. Interim Facilities More than 2 Mm3 of PAG waste rock will be Water management structures (e.g., diversion placed in un-flooded downstream side of south ditches, sediment control ponds, and temporary embankment of TMF prior to the second year of coffer dams for construction, seepage collection operations. The initially stripped materials will ponds) will be constructed prior to the start of be stockpiled for construction and reclamation earthworks (including removal and stockpiling purposes. Ore that has been mined during the of topsoil and organics). Temporary erosion and construction period will be stockpiled and re- control features will be implemented to control handled to the mill during operations. sediment and erosion during construction. These features will be reclaimed after achieving soil and Operations sediment stability. Explosives will be brought to the mine site as-needed by a certified supplier Open Pit Mining until the explosives manufacturing facility is Mining will deepen the existing historical open constructed and operational. pit. Once commercial-scale mining commences, production drilling will be performed. Blasting is Road Access expected to occur daily. Shovels will be used to The existing roads along the proposed transportation load the ore and waste trucks. High-grade ore will corridors will be used for mine site access during all be sent to the process plant while low grade ore phases of the Project. During construction, there will will be stockpiled for processing or submerged in be short-term, intensive use of FSRs, Highway 37, and the Kitsault Pit at closure. Highway 113 to transport construction materials and supplies, large-scale mining and construction Ore Processing equipment, and construction personnel. Bridges Ore will be crushed and transported by a and culverts along the FSRs that access the mine conveyor system to a concentrator in preparation site will require minor maintenance and repair. for flotation. Flotation processes will separate the The maximum daily number of trips is estimated ore into a purified molybdenum concentrate and at 108 total trips (54 round trips). waste streams (tailings). The concentrate will be stored and bagged in an enclosed building onsite Facility Construction and transported by truck-trailer combination. Construction of the ore processing facilities Two main waste streams will exit the mill. The will commence early in the construction phase, first will consist of tailings that are expected to following initial on-site road construction and be non PAG and suitable for TMF construction. land clearing. Topsoil from the area of the The second waste stream will comprise a blend processing facilities and from under the truckshop of tailings and sulphide concentrates predicted to will be excavated and stockpiled. The two TMF be PAG, and will be deposited in a permanently embankments will be constructed before start-up submerged area of the TMF. with the use of quarry material near the TMF for construction of the northeast embankment. A ML/ Road Use ARD monitoring program will be implemented to During operations, there will be continuous, long- ensure the appropriate use of construction material. term flow of mine-related traffic between the mine

110 CEAA—Comprehensive Study Report: Kitsault Mine Project site and regional hubs for transporting materials, Collection Pond, groundwater inflows and natural equipment and supplies (including personnel bus precipitation in the pit area. Discharge from the transportation and concentrate transport). Project TMF will be diverted around the pit until the post personnel on rotation will be transported to and closure phase. Pit walls above the final water from the mine site by bus from Terrace, with level will remain as exposed bedrock. provisions made for intermediate pickups for those who live locally in New Aiyansh. Private Tailings Management Facility vehicle access to the mine site must be limited to At closure, the TMF will have a lake to maintain personnel with issued visitor passes or personnel permanent water cover over sulphidic tailings. vehicle passes. Hazardous materials (e.g. Sand beaches will keep water away from the petroleum products, explosives, mill reagents) northeast and south embankments and will be will be transported along the existing provincial reclaimed to allow for seasonal fluctuations in highways and FSRs in accordance with provincial lake levels. At closure, reclamation material will guidelines and regulations. be placed over the non-inundated tailings beaches (north and south) and the downstream slope of Premature Closure the Northeast Embankment. Revegetation will Premature closure involves permanent closure encourage development of wetland habitat around of the mine before completion of mining. The the edges of the TMF lake and upland habitat closure and reclamation activities, as outlined in the drier areas away from the lake. TMF in the following section will be implemented reclamation will be consistent with the Wetland should any temporary shutdown extend beyond Habitat Compensation Plan. two years with the exception that the LGS being hauled to the Kitsault Pit and submerged. WRMF and Low Grade Ore Stockpile The downstream slope of the WRMF will be Decommissioning and Closure resloped to approximately 2:1. Soils salvaged for The closure phase commences with the cessation reclamation will be placed prior to revegetation, of molybdenum production (i.e. milling of which will be completed using native species and ore) and lasts until the Kitsault Pit floods to its seed mixes according to the final Reclamation discharge elevation. Closure and reclamation and Closure Plan. At the commencement of the activities will be undertaken consistent with closure phase, the LGS will have been milled provincial permit requirements. The post closure or must be in the process of being moved to the phase begins when the open pit begins passively Kitsault Pit. The LGS area will be reclaimed discharging into Lime Creek. using salvaged soil to provide a growth medium and planted or seeded with native species. During the closure phase, all equipment and infrastructure not required for closure and Infrastructure, Processing and post-closure activities will be removed and/or Ancillary Facilities reclaimed. Soil stockpiles generated during the Infrastructure, processing and ancillary facilities construction will be used to provide reclamation will be dismantled and removed, demolished, media across the site. Revegetation activities must and/or reclaimed at closure. Decommissioning of include fertilization, seeding using certified weed- the explosives manufacturing facility and storage free mixes approved by permitting agencies, and magazines will be undertaken in accordance must reflect native species (without legumes). NRCan requirements. Salvageable items and materials will be removed from the site and sold. Kitsault Pit Non-hazardous materials with no salvage value At the end of the mine’s life, the Kitsault Pit will be disposed of on-site while hazardous will be filled with water from the South Seepage wastes will be removed from the site and

CEAA—Comprehensive Study Report: Kitsault Mine Project 111 delivered to an approved facility. All salvaging, TMF diversion channel that is immediately dismantling and demolition will be completed upstream of the WRMF will be maintained in within three years of cessation of commercial the long term to divert flows around the waste production. These areas of the mine site will rock and into the pit. The south diversion ditch be reclaimed according to the Reclamation (above the pit) and the in-pit diversion channel and Closure Plan, which includes placement of will be decommissioned, allowing flows to enter reclamation medium and revegetation or seeding the pit. A closure spillway for the TMF will be using native species. constructed during the final year of operations to meet the latest closure criteria and specifications Access and Haul Roads as defined by the Canadian Dam Association. On-site roads that provide access to key closure and post-closure infrastructure (i.e., water quality monitoring stations, the TMF, treatment facilities, etc.) will be maintained for ongoing site maintenance and monitoring. Roads that are no longer required will be re-graded and scarified to encourage vegetation growth.

Borrow Areas Borrow sites will be reclaimed through progressive reclamation and during the closure phase where progressive reclamation is not possible. Borrow reclamation will involve re- contouring the site to establish drainage patterns and topography consistent with the surrounding landscape. Reclamation material, salvaged prior to site development, will be replaced directly on the re-contoured area.

Water Management During the closure phase, the south TMF diversion channel, the south diversion ditch (above the south side of the Kitsault Pit) and the in-pit diversion channel will be maintained until the pit has flooded to the closure elevation. During this phase, excess water from the TMF will be released into Lime Creek via a single point of discharge.

Once the Pit is full and begins to spill to Lime Creek (at post closure), the south TMF diversion channel upstream of the TMF will be decommissioned, allowing the diverted catchment to flow into the TMF. The portion of the south

112 CEAA—Comprehensive Study Report: Kitsault Mine Project Appendix B Alternatives for Carrying out the Project Table B-1: Project Alternatives Assessment Factors Considered Preferred Alternatives Environmental Socio-economic Reclamation Cost-effectiveness Option considerations considerations feasibility Processing Plant Operations cost Effects on the natural N/A Construction on greater due to environment are pre-disturbed area Site A southwest separation from minimised through requiring mitigation of the LGS other facilities mitigation during operation and at closure

Large enough to More compact N/A Construction on accommodate and footprint reduces pre-disturbed area centralize most of disturbance; site will requiring mitigation the site facilities drain to the TMF during operation and Site B southeast thereby reducing and simplify water at closure √ of the LGS the need for management ongoing operational coordination and costs Waste Rock Management Facility – All options are predicted to result in acidic drainage resulting in long-term risks and costs associated with collection and treatment WRMF located Highest haul Seepage will be N/A Seepage would east of Kitsault costs but does not captured in the report to and mix Pit make operations Kitsault Pit not in with water in the final uneconomical Lime Creek; allows pit lake for batch treatment √ and full capture, if seepage, as predicted, needs to be treated WRMF located High haul costs Risk of seepage N/A Seepage collection north of the entering Lime Creek and treatment on Kitsault Pit on closure will be the existing Clary required Dump WRMF west of Ideal location for Difficult to fully N/A Seepage collection the Kitsault Pit waste rock is at the prevent seepage and treatment on lip of the Kitsault Pit from entering Lime closure will be because haul costs Creek; failure would required are the lowest affect Lime Creek and Alice Arm Truckshop and Fuel Storage Compound Site near the Less cost-effective Ground conditions Increased noise and Chosen site Clary Dump due to use of more (existing waste rock disturbance in other is located in a north of LGS fuel and time overlying topsoil areas of the mine site previously disturbed and organics) and area topography not suitable for salvage for reclamation

CEAA—Comprehensive Study Report: Kitsault Mine Project 113 Table B-1: Project Alternatives Assessment continued Factors Considered Preferred Alternatives Environmental Socio-economic Reclamation Cost-effectiveness Option considerations considerations feasibility Site south of the Less distance to Truckshop site Closer to other Chosen site LGS travel for mine trucks will allow salvage facilities and is located in a and therefore less of topsoil for infrastructure and previously disturbed √ fuel and time lost reclamation keeps most of the area noise away from the camps and mill site Primary Crusher North of the Most cost-effective Orientation will Reduction in dust Chosen site Kitsault Pit due to proximity minimise dust from will mitigate health is located in a to Kitsault Pit and prevailing winds effects on workers previously disturbed √ crusher configuration area

Other locations Less cost-effective Increase in dust Potential health Chosen site near the Kitsault the further away it is because of the risk to employees is located in a Pit from the Kitsault Pit prevailing winds working near the previously disturbed area of the crusher area Explosives Manufacturing Facility and Storage Magazines 500 m northeast Location not driven Away from water Main issues Results in new of the TMF by cost effectiveness bodies that could be are safety and disturbance but √ affected by leachate compliance with legally required for regulations safety reasons Other locations Locations not driven Leachate may reach Not compliant with May or may not around the mine by cost effectiveness nearby water bodies regulations result in new site disturbance

Tailings Management Facility High capital and Catastrophic failure Embankment failure Post-closure Site 1 – Upper operating costs of embankment could affect use of treatment could be Lime Creek could destroy fish the fish resource and required habitat nearby property Lowest construction Overlying a fish Potentially high Post-closure lake Site 2 – Clary and operations cost bearing lake social and economic and wetland could Lake effects due to loss of replace fish habitat fish resource lost Overlying another Environmental Loss of the Bell Moly Seepage control potential deposit - control at the site deposit, potential and treatment could Site 3 – Bell Moly Bell Moly manageable and fish revenues and be required post deposit bearing waters not employment closure to prevent directly affected contamination of adjacent lakes Relatively high Need to capture Seepage into Seepage control and construction and seepage from the Killam Lake, if not treatment could be Site 4 – Patsy operating costs embankment to controlled, could required post closure Lake East prevent effects to affect fish Killam Lake

114 CEAA—Comprehensive Study Report: Kitsault Mine Project Table B-1: Project Alternatives Assessment continued Factors Considered Preferred Alternatives Environmental Socio-economic Reclamation Cost-effectiveness Option considerations considerations feasibility Higher cost than Covers a non-fish Safety risks less than Seepage treatment some of the other bearing lake but Sites 1, 6, 7; loss of not required because Site 5 – Patsy alternatives potential to establish fish use relatively low small-volume √ Lake wetland at closure seepage would drain to pit lake Short haul distance Catastrophic failure Embankment failure Post-closure for embankment of embankment could affect use of treatment could be Site 6 – Lower and piping with no could destroy fish the fish resource and required Lime Creek pumping of tailings habitat nearby property required (i.e., gravity feed) Haul distance for Situated in separate Catastrophic failure Seepage treatment embankment and watershed from of the embankment could be required Site 7 – Roundy piping distance deposit, leading to would affect Roundy post closure Creek relatively large greater potential Creek and possibly for environmental Alice Arm effects Haul distance for Longer haul N/A Seepage treatment Site 8 – Ksi embankment and distances would could be required Gwinhat’al piping distance increase exhaust post closure relatively large emissions Overlying another Overlying a fish Loss of the Bell Post-closure lake Site 9 – East Bell potential deposit - bearing lake Moly East deposit, and wetland could Moly Bell Moly East revenues, and replace fish habitat employment lost Low construction Overlying a fish Potential loss of Post-closure lake Site 10a – Clary cost, but higher haul bearing lake subsistence and and wetland could Lake North costs recreational fishing replace fish habitat opportunities lost Overlying another Fish habitat N/A Seepage treatment Site 10b – Belly potential deposit - unknown; could could be required Moly deposit Bell Moly overlie fish bearing post closure lakes Insufficient capacity Loss of terrestrial N/A Closure activities for mine life tailings habitat that could be manageable Site 10c with high haul costs replaced by wetland compared to other habitat at closure sites Water Management

Alternatives for water management measures are closely tied to arrangement of project facilities and are limited once facility locations and configurations have been chosen. The approach to water management will be to recycle as much as possible, divert clean water around the mine site, collect all contact water for treatment and discharge at a single point.

Transport of Construction Materials

The proponent will transport construction materials using existing highways and roads. No alternatives except for the two transportation corridors between the mine site and Kitwanga were considered.

CEAA—Comprehensive Study Report: Kitsault Mine Project 115 Table B-1: Project Alternatives Assessment continued Factors Considered Preferred Alternatives Environmental Socio-economic Reclamation Cost-effectiveness Option considerations considerations feasibility Transport of Molybdenum Concentrate

The proponent will transport concentrate using existing highways and roads. No alternatives except for the two transportation corridors between the mine site and Kitwanga were considered. Highway 16 and Highway 97 would be used beyond Kitwanga.

Decommissioning, Closure and Reclamation Decommissioning, closure, and reclamation will be guided by provincial requirements for health, safety and reclamation and influenced by the social and environmental conditions of the mine.Alternatives were not considered as reclamation will be undertaken to achieve end land-use objectives. All facilities will be removed or buried while access of the Alice Arm Road will remain open to provide access to the Kitsault Townsite and Alice Arm.

116 CEAA—Comprehensive Study Report: Kitsault Mine Project Appendix C to mimic the natural hydrograph of Lime Creek Summary of Mitigation Measures throughout the year. ••Construct sediment control ponds to detain runoff The following list includes measures that the from disturbed areas and enable sediments to Canadian Environmental Assessment Agency settle out and be captured. considers necessary to mitigate the environmental ••Store cleaner scavenger tailings and pyrite effects of the Project. Mitigation measures in concentrate that are PAG below water in the TMF. relation to accidents and malfunctions are listed ••Ensure that the starter embankment and TMF separately in Appendix D. are designed and constructed such that the final TMF surface water or tailings pore water is not Additional mitigation is specified in the British hydraulically connected with the contact between Columbia EA Certificate documentation, and may the Bowser Group and Tertiary basalt. be further described in additional authorizations that may be issued by the federal and provincial Wildlife and Wildlife Habitat governments. ••Implement actions in a Bear Interaction Acid Rock Drainage Prevention and Mitigation Management Plan approved by appropriate regulatory authorities to avoid and reduce risks of ••Construct and operate a de-pyritization circuit potential bear-human conflicts. as part of the processing facilities. Combine ••Prior to the start of construction, develop a pyritic tailings with the cleaner tailings stream map of sensitive wildlife areas within the LSA. and deposit via one pipeline for immediate and Develop and implement site-specific mitigation permanent subaqueous storage within the TMF. measures, to the satisfaction of appropriate ••At mine closure, either mill the stockpiled regulatory authorities including Environment LGS or move it to the open pit for permanent Canada, to reduce the likelihood of impacting subaqueous storage. sensitive wildlife habitats or wildlife within those ••Ensure that the chosen method for deposit of habitats during all Project phases. waste rock supports the long term predicted ••If pre-construction site assessments identify a bat water quality identified in the EA process. hibernacula site or sites, develop and implement protocols for minimizing adverse effects to Water Management and Treatment bats at all Project phases, to the satisfaction of appropriate regulatory authorities including ••Ensure that, during the all phases of the Project, Environment Canada. water quality at LC1, LC2 and Lake 901 meets ••If pre-construction assessments confirm the water quality guidelines or objectives set by the presence of breeding habitat for marbled appropriate regulatory authorities. murrelet, develop and implement protocols for ••Collect and direct runoff and seepage from minimizing adverse effects to marbled murrelets all Project infrastructure, including the LGS, and their breeding habitat at all Project phases, Kitsault Pit, South and Northeast Embankments, to the satisfaction of appropriate regulatory WRMF, historic waste rock, conveyor system cut authorities including Environment Canada. and roads, to the TMF. ••Prior to clearing or construction activities, ••Divert freshwater runoff from upstream areas not examine wetlands and ponds within and affected by the mining operation to reduce the immediately adjacent to work zones during amount of water in contact with disturbed area. western toad breeding and dispersal periods. ••Ensure that mine water discharge during all If one or more western toad breeding areas phases of the Project meets the flow requirements or dispersal areas are identified through field

CEAA—Comprehensive Study Report: Kitsault Mine Project 117 work, develop and implement protocols for • Support Nass moose population recovery efforts, minimizing adverse effects to western toads, for example, education and communication, to the satisfaction of appropriate government inventory, monitoring, collection of harvest data, authorities including Environment Canada and signage and programs to reduce the risk of moose the Nisga’a Lisims Government. mortality in the Nass Valley. • Actively participate in any cross industry or Vegetation and Plant Communities government initiatives that address road use adjacent to or intersecting moose habitat along ••Prior to clearing or construction of mine the transportation corridors, including funding components that will impact wetlands, undertake to support a coordinated approach to managing a site survey and characterization of blue- and and mitigating the potential cumulative effects red-listed wetland communities within the to aquatic and wildlife populations along Kitsault Mine site, including an assessment of Highway 37. blue-and red-listed wetland function as it relates • Prior to the commencement of construction, to habitat for migratory birds and species at risk, develop a Geographic Response Plan articulating for use in the development of a Wetland Habitat training and hazardous material spill response Compensation Plan. activities for the transportation route to the ••Prior to construction, complete a detailed approval of regulatory authorities responsible Wetlands Habitat Compensation Plan that for hazardous material spill response. Spill addresses effects on red- and blue-listed response measures will include the establishment wetland communities and their functions, to of five separate equipment caches along the the satisfaction of Environment Canada and transportation corridor which will enable other appropriate regulatory authorities. Consult timely and effective response to spills in high with the Nisga’a Lisims Government and the environmental sensitivity areas, including areas Metlakatla First Nation prior to submission and downstream of water-crossings. Consult the implementation of the Plan. Nisga’a Lisims Government, Gitanyow Nation, ••Prior to construction, conduct a site assessment Gitxsan Nation and the Kitsumkalum First survey for Cryptic Paw Lichen within and near Nation on the development of the Geographic the immediate Kitsault Mine footprint, by a lichen Response Plan. specialist. If Cryptic Paw Lichen is identified • Develop and implement a plan describing at the site, develop and implement protocols to appropriate forms of barrier protection along minimize adverse effects on Cryptic Paw Lichen areas of the proposed transportation corridors to the satisfaction of appropriate regulatory with high aquatic values that could be at risk authorities including Environment Canada. from spills of hazardous materials. Prior to identifying high risk areas, consult with: the Transportation and Road Use Nisga’a Lisims Government within the Nass Area; and the Gitanyow Nation, Gitxsan Nation ••Implement a speed limit for mine-related vehicles and Kitsumkalum First Nation within their of 50 km/hr along kilometre 0 to 51 of the Nass asserted traditional territories. Forest Service Road (Cranberry Connector). ••Develop a Wildlife Corridor Management Fish and Fish Habitat Plan prior to construction that includes a Large Mammal Reporting and Monitoring Program • Complete a Fish Habitat Compensation Plan to identify high potential areas (i.e., location, to the approval of Fisheries and Oceans time of day, season) for large mammal-vehicle Canada before a Fisheries Act subsection 35(2) collisions. authorization is issued. Consult with the Nisga’a Lisims Government prior to submitting the Plan.

118 CEAA—Comprehensive Study Report: Kitsault Mine Project ••Design and install a diversion between Lake 493 and Lake 901 to mitigate potential lake level changes in Lake 901 and Clary Lake.

Marine Aquatic Resources

••Prior to construction, complete and submit a plan for review by the appropriate parties, including Health Canada, the Nisga’a Lisims Government and the Metlakatla First Nation, describing how human health risks will be analyzed and managed as part of the AEMP and MEMP. Implement the actions in the plan.

CEAA—Comprehensive Study Report: Kitsault Mine Project 119 Appendix D Environmental Effects from Accidents and Malfunctions and Summary of Prevention/Mitigation Measures Effects Prevention / Issue Facility Construction Operations Closure Mitigation Drip trays, regular Routine drips Routine drips maintenance service, Routine drips and spills, and spills, major employee training, spill and spills, major Equipment major adverse adverse effects response and clean up adverse effects to effects to land to land or water (i.e., Mine Emergency land or water body or water body body and Spill Response Petroleum spills Plan) Drip trays, containment Routine drips Routine drips ponds, follow standard Routine drips and and spills, and spills, major operating procedures Storage spills, major loss to major loss to loss to land or (SOP), employee land or water body land or water water body training, and spill body response and clean up Mill, explosives Health manufacturing Design, containment hazard, injury, facility, magazines, ponds, follow SOPs, contaminated Hazardous and explosives training, explosives N/A soil and N/A substances spills process trucks, management plan, water, impacts truckshop, and spill response and on aquatic warehouse, cold clean up organisms storage building Loss of sediment Regular inspection, Sedimentation to water bodies, N/A N/A monitoring and clean- ponds impacts on aquatic up organisms Loss of Containment pond potentially failure contaminated Engineered design and water and construction control, Seepage collection N/A sediment to N/A regular inspection, ponds water bodies, monitoring, and spill impacts response and clean-up to aquatic organisms Small Small slump: slump: loss loss of material of material to a lower bench Engineered design to a lower or surroundings and construction bench or Large failure: control, use of trained surroundings equipment operators, Stockpile failure LGS, WRMF N/A injury or loss of Large failure: life, covering monitoring, regular injury or of surrounding inspections, spill loss of life, area response and clean-up, covering of and medical response surrounding area

120 CEAA—Comprehensive Study Report: Kitsault Mine Project Environmental Effects from Accidents and Malfunctions and Summary of Prevention/Mitigation Measures continued

Effects Prevention / Issue Facility Construction Operations Closure Mitigation Small: loss of water Small: loss or tailings of water or to open tailings to open pit (South pit (South Embankment) Embankment) or to seepage or to seepage control ponds control ponds Engineered design and (Northeast (Northeast construction control, TMF Northeast monitoring, annual Embankment Embankment) Embankment) and South N/A dam safety inspection failure embankments Large: loss Large: loss and regular dam safety of water or of water or reviews, and spill tailings to tailings to the response and clean-up the open open pit (South pit (South Embankment) Embankment) or to Lake 901 or to Lake 901 tributaries, tributaries, Lake 901 or Lake 901 or downstream downstream Fresh water Fresh water Engineered design Water supply line loss, erosion, loss, erosion, N/A control, and regular sedimentation sedimentation inspections Pipeline leakage None as Engineered design tailings will control, regular Tailings line N/A N/A drain to the inspections and TMF monitoring Monitoring, regular Raw or maintenance service, Sewage treatment Raw or partly partly treated N/A follow SOPs, employee plant treated sewage sewage training, and spill response and clean-up Small: minor, one time, exceedances Off-specification of discharge treatment plant criteria effluent Treatment plant design, Discharge water Large: major plant operator training, N/A N/A treatment plant malfunction and monitoring of plant of treatment operations plant leading to general non-compliance with discharge criteria

CEAA—Comprehensive Study Report: Kitsault Mine Project 121 Environmental Effects from Accidents and Malfunctions and Summary of Prevention/Mitigation Measures continued

Effects Prevention / Issue Facility Construction Operations Closure Mitigation Shutdown of electric Shutdown equipment, of electric loss of lighting equipment, loss and heat, of lighting and stoppage heat, stoppage Shutdown of electric of water Backup generators, All facilities of water Power outages equipment, loss of management regular maintenance requiring electricity management lighting and heat structures and inspections structures (e.g., (e.g., treatment plant treatment and pumping plant and of seepage to pumping of TMF) seepage to TMF) Damage/ Damage/ destruction destruction of facilities or of facilities or surroundings, surroundings, Damage/destruction power power outages, Engineered design of facilities or outages, Slash, forest stoppage control, monitoring, surroundings, power stoppage Fire wildfire, buildings, of water suppression outages, increased of water mobile equipment management equipment, training and erosion and runoff, management structures, medical response injury or loss of life structures, increased increased erosion and erosion and runoff, injury or runoff, injury loss of life or loss of life Injury or Injury or loss Engineered design Buildings, loss of life, of life, damage control maintenance, Accidental explosives storage, damage or or destruction N/A monitoring, follow explosion propane tanks, destruction of facilities or SOPs, training and vehicles of facilities or surroundings medical response surroundings Safe placement of Injury, rock facilities, equipment Fly rock from project Open pit N/A N/A and people, signage, blasting beyond the training, blast warnings open pit and medical response Injury or loss Injury or loss of life, spills Injury or loss of life, of life, spills of Maintenance, Mobile equipment of hazardous spills of hazardous hazardous or employee training, re- Motor vehicle at mine, personnel or non- or non-hazardous non-hazardous enforcement of safety accidents and materials hazardous substances on land substances on procedures, clean-up transport vehicles substances on or water, fires land or water, and medical response land or water, fires fires

122 CEAA—Comprehensive Study Report: Kitsault Mine Project Environmental Effects from Accidents and Malfunctions and Summary of Prevention/Mitigation Measures continued

Effects Prevention / Issue Facility Construction Operations Closure Mitigation Sediment Engineered design Sediment Sedimentation Sediment export export to control, regular export to water pond or coffer dam to water bodies, water bodies, maintenance service, bodies, impacts malfunction or impacts on aquatic impacts monitoring and on aquatic failure organisms on aquatic installation of silt organisms Sediment release organisms screens to water courses Sediment Engineered design export to control, regular Diversion water bodies, maintenance service, N/A N/A channels, ditches impacts monitoring and on aquatic installation of silt organisms screens Engineered design control, monitoring of Damage runoff and seepage, Accidental release Open pit, LGS, to aquatic N/A N/A maintenance of ditches of ML/ARD WRMF, TMF habitat and and ponds and the organisms TMF, spill response and clean-up Dust Dust generation, Dust generation, Disturbed, generation, Watering roads and inhalable and inhalable and non-vegetated inhalable and other bare surfaces, Dust respirable respirable surfaces, wind respirable keep tailings beaches suspended suspended blown tailings suspended wet particulate particulate particulate Off-spec Off-spec Off-spec exhaust exhaust gases exhaust gases Regular maintenance Vehicle emissions Mobile equipment gases (PM, NOx, (PM, NOx, (PM, NOx, SOx, service SOx, CO, CO2) SOx, CO, CO, CO2) CO2) Off-spec stack Off-spec stack Off-spec stack Regular maintenance Incinerator gases (PM, gases (PM, Incinerator gases (PM, NOx, service, follow SOPs, emissions NOx, SOx, CO, NOx, SOx, CO, SOx, CO, CO2) and employee training CO2) CO2) Affect delivery of necessary Affect delivery Affect delivery of materials and of necessary necessary materials chemicals materials and and chemicals for for mine Employee training, chemicals for mine activities, activities, monitoring, re- mine activities, Road wash out Access roads including water including enforcement of safety including water management, water procedures, spill management, impacts to aquatic management, response and clean-up impacts to habitat and impacts aquatic habitat organisms to aquatic and organisms habitat and organisms

CEAA—Comprehensive Study Report: Kitsault Mine Project 123 Appendix E Summary of the Environmental Effects Assessment

Table E-1: Analysis of the Significance of Residual Environmental Effects on VCs

Predicted Degree of Effect After Mitigation

Extent Duration Ecological, socioeconomic, Magnitude Frequency Reversibility Significance of Effect (local, watershed, regional, (short-term, medium-term, or cultural importance (negligible, low, medium, high) (once, intermittent, continuous) (reversible or irreversible) After Mitigation provincial scale) long-term) (negligible, low, medium, high) (minor, moderate, major)

Negligible. There is no Local. The effect is limited to the Short-term. The effect lasts Once. The effect is confined to one Reversible. The effect can be Negligible. The effect is not Not Significant (negligible/minor). Residual effects detectable change from baseline project footprint. less than one day to two years discrete period during the life of the reversed within the short to long term. considered to be important or of no or low magnitude, site-specific or local extent, conditions. (duration of construction phase). project. valuable by people living in short to long-term, low frequency (once or intermittent) potentially affected communities in and reversible with negligible or low ecological the region. context; their effects are not distinguishable from those resulting from background physical, chemical and biological processes. Low. The magnitude of effect Watershed. The effect extends Medium-term. The effect lasts Intermittent. The effect occurs at Irreversible. The effect cannot be Low. The effect is considered to be Not Significant (moderate). Residual effects differs from the average value for beyond project footprint to within throughout mine operations, sporadic, intermittent, intervals and reversed. somewhat important or valuable by of medium magnitude, local to regional extent, baseline conditions, but is within an area a few kilometres of the decommissioning and closure. potentially beyond the life of the people living in potentially affected medium to long-term, occur at all frequencies the range of natural variation project footprint. project. communities in the region. (once to continuous), and reversible or irreversible and well below a guideline or with medium ecological context; their effects and threshold value. consequences are distinguishable at the level of populations, communities and ecosystems. Follow-up or monitoring of these effects may be required. Medium. The magnitude of Regional. The effect extends Long-term. The effect is likely Continuous. The effect occurs Medium. The effect is considered Significant (major). Residual effects of high effect differs from the average throughout the regional to persist beyond the life of the constantly during and potentially to be valuable by people living in magnitude, regional extent, long-term occur at all value for baseline conditions and assessment area. project. beyond the life of the project. potentially affected communities in frequencies (once to continuous), and irreversible with approaches the limits of natural the region. high ecological context; their effects are consequential variation, but below or equal to a in terms of structural and functional changes guideline or threshold value. in populations, communities and ecosystems. If significant effects are justified, follow-up and monitoring would be required. High. The magnitude of effect is Provincial: effect extends across High. The effect is highly valued by predicted to differ from baseline or beyond the province people living in potentially affected conditions, guideline or threshold communities or the region. value so that there will be a detectable change beyond the range of natural variation (i.e., change of state from baseline conditions).

124 CEAA—Comprehensive Study Report: Kitsault Mine Project Table E-2: Environmental Effects Analysis for Atmospheric Environment

VEC Affected Potential Effect Proposed Residual Effect Predicted Degree of Effect After Mitigation Significance Agency Follow-up Mitigation of Effect After Conclusion Requirement (yes/ Ecological, Extent Duration Mitigation no) Magnitude Frequency Reversibility socioeconomic, (local, watershed, (short-term, (minor, (negligible, low, (once, intermittent, (reversible or cultural importance regional, provincial medium-term, medium, high) continuous) irreversible) (negligible, low, moderate, major) scale) long-term) medium, high) Atmospheric Environment Air quality Decline in air • Use of mining Yes Low Local Medium-term Intermittent Reversible Low Minor The residual quality due equipment that environmental to increased meet emission effects are not emissions, standards likely to be fugitive dust, and • Vehicle and significant (minor). aggregate ore and equipment waste handling maintenance and activities management • Minimize land disturbance • Establish speed limits on unpaved surfaces • Minimise clearing / grubbing areas • Dust suppression on access and haul roads Climate change Greenhouse gas • See mitigation for No emissions due to air quality mining vehicles • Reclamation of and deforestation the mine footprint Noise and Increased noise • Use of noise No Vibration and vibration abatement from road traffic, equipment and blasting and accessories. construction • Restricted use of equipment sirens and alarms

125 CEAA—Comprehensive Study Report: Kitsault Mine Project Table E-3: Environmental Effects Analysis for Groundwater

VEC Affected Potential Effect Proposed Mitigation Residual Predicted Degree of Effect After Mitigation Significance Agency Conclusion Follow-up Effect of Effect After Requirement Extent Ecological, Duration Mitigation (yes/no) Magnitude (local, Frequency socioeconomic, (short-term, Reversibility (negligible, watershed, (once, cultural (minor, medium- (reversible or low, medium, regional, intermittent, importance moderate, major) term, long- irreversible) high) provincial continuous) (negligible, low, term) scale) medium, high) Groundwater Groundwater Effects to groundwater • Discharge of water drawn from Yes Medium Local Long-term Continuous Irreversible Low Moderate The residual The proponent will flow flow in Patsy, Lime the Patsy Creek and Lime Creek environmental effects are develop a groundwater Creek watershed due watersheds (at hydraulically up-gradient not likely to be significant. monitoring and to the Kitsault Pit, TMF locations within the headwaters) back mitigation plan that will and diversion channels into these watersheds include the installation • Monitor bedrock groundwater monitoring of groundwater wells near and hydraulically down- monitoring wells gradient from the Kitsault Pit between Lake 901 and Groundwater Effects of seepage, • Seepage collection ponds downstream Yes Medium Local Long-term Continuous Irreversible Low Moderate The residual the seepage collection quality runoff, ML/ARD, of TMF embankments (i.e., South and environmental effects are ponds at the Northeast blasting residue, Northeast Seepage Collections Ponds) not likely to be significant. Embankment. and contaminants to to collect seepage and runoff and pump groundwater quality back to TMF and nearby surface • Install monitoring and pump back wells water bodies between the NSCPs and Lake 901 to meet BC WQGs or Site Specific Water Objectives • Seep mapping in the area of the TMF to identify and mitigate potential seepage pathways • Vertical sump downstream of the LGS to collect and pump seepage and runoff back to the TMF and monitoring • Mapping and hydraulic characterization of permeable bedrock features • Install additional monitoring wells or seepage collection trenches in the event of a spill and if further effects are identified Groundwater Changes to • See mitigation for groundwater quality Yes Medium Local Long term Continuous Irreversible Low Moderate The residual Recharge and groundwater and environmental effects are Discharge surface water flow and not likely to be significant. quality Groundwater Changes in • See mitigation for groundwater quality Yes Medium Local Long term Continuous Irreversible Low Moderate The residual and Surface groundwater flow and environmental effects are Water quality on surface not likely to be significant. Interaction water

126 CEAA—Comprehensive Study Report: Kitsault Mine Project Table E-4: Environmental Effects Analysis for Hydrology

VEC Affected Potential Effect Proposed Mitigation Residual Predicted Degree of Effect After Mitigation Significance Agency Follow-up Effect of Effect After Conclusion Requirement Ecological, Extent Duration Frequency Mitigation (yes/no) Magnitude Reversibility socioeconomic, (local, watershed, (short-term, (once, intermittent, (minor, moderate, (negligible, low, (reversible or cultural importance regional, provincial medium-term, continuous) medium, high) irreversible) (negligible, low, major) scale) long-term) medium, high) Hydrology Hydrology of Decreased annual • Maximise water recycling Yes Low to medium Watershed Long-term Continuous Irreversible Low Moderate The residual Lime Creek/Patsy and low flows and • Regulating discharge from environmental Creek, Clary Creek increased high mining facilities to mimic effects are not and flows in the Lime the natural hydrograph in likely to be Illiance River and Patsy Creek Lime Creek significant. watersheds watershed • Increasing the amount of freshwater diversions • Contact water from the Decreased annual TMF embankments, Yes Low Watershed Long-term Continuous Irreversible Low Minor The residual and low flows WRMF, Kitsault Pit and environmental and lake levels in LGS will be collected and effects are not the Clary Creek pumped back to the TMF likely to be watershed • Water diversion from significant. Lake 493 to Lake 901 to compensate for loss of Lake 901 drainage overlapping the TMF • Install monitoring and pump back wells between the NSCPs and Lake 901 to meet BC WQGs or Site Specific Water Objectives • Seepage collection ponds downstream of TMF embankments (i.e., South and Northeast Seepage Collections Ponds) to collect seepage and runoff and pump back to TMF

127 CEAA—Comprehensive Study Report: Kitsault Mine Project Table E-5: Environmental Effects Analysis for Surface Water and Sediment Quality

VEC Affected Potential Effect Proposed Mitigation Residual Predicted Degree of Effect After Mitigation Significance Agency Follow-up Requirement Effect of Effect After Conclusion Extent Frequency Ecological, Mitigation (yes/no) (local, Duration Magnitude (once, Reversibility socioeconomic, watershed, (short-term, (minor, (negligible, low, intermittent, (reversible or cultural importance regional, medium-term, moderate, major) medium, high) continuous) irreversible) (negligible, low, provincial long-term) medium, high) scale) Surface Water and Sediment Quality Surface water Change in surface • Mine Site Water Management Plan Yes Medium Local Long-term Continuous Irreversible Medium Moderate The residual The proponent must quality water quality due to and Mine Site Water Monitoring Plan environmental complete an assessment of the TMF, Kitsault Pit, • Water quality at LC1, LC2 and in Lake effects are not the technical feasibility to WRMF, coarse ore 901 meets BC WQGs or site-specific likely to be segregate waste rock based stockpile, geologic water quality objectives approved by significant. on its potential for acid rock construction material BC MOE drainage and whether there and LGS (Lime Creek • Install monitoring and pump back would be measureable long- watershed) wells between the NSCPs and term benefits to water quality Change in surface Lake 901 to meet BC WQGs or Site No from segregation. water quality in Clary Specific Water Objectives Creek watershed • Project design to enable water treatment during operations, closure, and post closure to meet water quality guidelines (e.g., in-mill lime and sulphide water treatment, filtration system, lime addition to Kitsault Pit and High Density Sludge and sulphide treatment plant) • Measures to mitigate the onset of ML/ARD including on-site NP and AP sample analysis to identify PAG materials and submergence of scavenger tailings and pyrite concentrate • Development of AEMP and MEMP • Additional research on segregation of waste rock Sediment quality Change in sediment • Diversion and runoff collection ditches Yes Low Local Long-term Continuous Irreversible Low Minor The residual quality in Lime Creek • Construction of sediment control environmental ponds effects are not • Stabilization of disturbed land surfaces likely to be to minimise erosion significant. Change in sediment • Additional mitigation proposed in Yes Low Local Long-term Continuous Irreversible Low Minor The residual quality in Clary Creek the Erosion and Sediment Control environmental Management Plan and the Mine Site effects are not Water Management Plan likely to be • Development of AEMP and MEMP significant.

128 CEAA—Comprehensive Study Report: Kitsault Mine Project Table E-6: Environmental Effects Analysis for Fish and Fish Habitat

VEC Affected Potential Effect Proposed Mitigation Residual Predicted Degree of Effect After Mitigation Significance Agency Follow-up Effect of Effect After Conclusion Requirement Extent Ecological, Mitigation (yes/no) Duration Frequency Magnitude (local, Reversibility socioeconomic, (minor, (short-term, (once, intermittent, (negligible, low, watershed, (reversible or cultural importance moderate, medium-term, continuous) medium, high) regional, irreversible) (negligible, low, long-term) major) provincial scale) medium, high)

Fish and Fish Habitat Dolly Varden Increased fishing pressure and • No fishing policy for employees and Yes Low Local Long-term Continuous Irreversible High Minor The residual changes in surface water quality, contractors onsite environmental hydrology, water temperature and • Water quality at LC1, LC2 and in Lake effects are not BMI community in Lime Creek 901 meets BC WQGs or site-specific likely to be water quality objectives approved by significant. coho salmon Changes in surface water quality, BC MOE Yes Low Local Long-term Continuous Irreversible High Minor The residual hydrology, water temperature and • Mine Site Water Management Plan environmental BMI community in Lime Creek • Usage of low sulphur diesel fuels effects are not and maintenance of the mine fleet to likely to be reduce air emissions significant. • Control dust generation by using a dust collection system • Development of AEMP and MEMP rainbow trout • Increased fishing pressure, • Fish Habitat Compensation Plan Yes Low Watershed Short-term Once Reversible Medium Minor Additional information impingement or entrainment of • Mine Site Water Management Plan is required to fish in pumps and pipeline • No fishing policy for employees and demonstrate that the • Change in fish passage at contractors FHCP is technically, stream crossings • Water quality at LC1, LC2 and in Lake economically, and • Loss of fish and fish habitat due 901 meets BC WQGs or site-specific biologically feasible. to the TMF water quality objectives approved by • Changes in surface water quality, BC MOE lake levels, stream flows and • Collect seepage and runoff in the BMI community in Clary Creek NSCPs and pump back to the TMF watershed • Install monitoring and pump back wells between the NSCPs and Lake 901 to meet BC WQGs or Site Specific Water Objectives • Design and install gravity fed diversion between Lake 493 and Lake 901 • Install intake pipes with mesh screens • Install new structures in fish bearing streams along Kitsault FSR and new access roads to allow fish passage

Benthic Macro- Change to abundance and • Fish Habitat Compensation Plan Yes Low to medium Watershed Long-term Continuous Reversible Low Minor The residual Invertebrates composition in the Lime and Clary • Water quality at LC1, LC2 and in Lake environmental Creek watersheds 901 meets BC WQGs or site-specific effects are not water quality objectives approved by likely to be BC MOE significant. • Mitigation proposed in the Mine Site Water Management Plan • Development of AEMP and MEMP

129 CEAA—Comprehensive Study Report: Kitsault Mine Project Table E-7: Environmental Effects Analysis for Marine Aquatic Resources

VEC Affected Potential Effect Proposed Mitigation Residual Predicted Degree of Effect After Mitigation Significance Agency Follow-up Effect of Effect After Conclusion Requirement Extent Frequency Ecological, Mitigation (yes/no) (local, Duration Magnitude (once, Reversibility socioeconomic, watershed, (short-term, (minor, moderate, (negligible, low, intermittent, (reversible or cultural importance regional, medium-term, major) medium, high) continuous) irreversible) (negligible, low, provincial long-term) medium, high) scale) Marine Aquatic Resources Marine water • Potential effects of freshwater • Development of MEMP Yes Low Local Long-term Continuous Irreversible High Moderate The residual Information quality quality and quantity in Lime • Water quality at LC1, LC2 and in Lake 901 environmental collected Creek on marine waters near meets BC WQGs or site-specific water effects are not through the the mouth of Lime Creek quality objectives approved by BC MOE likely to be AEMP will be • Mine Site Water Management Plan and significant. shared with Mine Site Monitoring Plan Environment • No Canada to inform the proponent’s EEM program. Marine Biota No

Table E-8: Environmental Effects Analysis for Terrain, Surficial Geology, and Soils VEC Affected Potential Effect Proposed Mitigation Residual Effect Predicted Degree of Effect After Mitigation Significance Agency Follow-up of Effect After Conclusion Requirement (yes/no) Ecological, Frequency Mitigation Extent Duration socioeconomic, Magnitude (once, Reversibility (local, watershed, (short-term, cultural (minor, (negligible, low, intermittent, (reversible or regional, provincial medium-term, importance moderate, major) medium, high) continuous) irreversible) scale) long-term) (negligible, low, medium, high) Terrestrial Environment: Terrain, Surficial Geology, and Soils Physiography Alteration of existing • Maximizing previously disturbed areas to maintain a Yes Medium Local Long-term Continuous Reversible Low Moderate The residual and Topography landscape, accelerated compact project footprint environmental erosion and changes to • Erosion and Sediment Control Plan effects are not terrain stability • Reclamation and Closure Plan likely to be significant. Surficial Geology Removal of overburden • Maximizing previously disturbed areas to maintain a No material, re-contouring compact project footprint land surface, accelerated • Salvage and store suitable reclamation materials erosion and changes to • Erosion and Sediment Control Plan terrain stability • Reclamation and Closure Plan Soil Cover Soil disturbance and • Maximizing previously disturbed areas to maintain a No redistribution compact project footprint • Closure and Reclamation plan • Reclamation material replacement • Monitoring of soil erosion and vegetation Soil Quality • Accelerated erosion • Maximizing previously disturbed areas to maintain a No and changes to terrain compact project footprint stability • Soil salvage and stockpile • Dust deposition • Vegetation monitoring • Changes to the quality • Dust management Plan of reclamation material • Emergency and Spill response plan • Soil disturbance • Reclamation and Closure Plan contamination, and redistribution

130 CEAA—Comprehensive Study Report: Kitsault Mine Project Table E-9: Environmental Effects Analysis for Vegetation and Plant Communities

VEC Affected Potential Proposed Mitigation Residual Predicted Degree of Effect After Mitigation Significance Agency Follow-up Requirement Effect Effect of Effect After Conclusion Extent Frequency Ecological, Mitigation (yes/no) (local, Duration Magnitude (once, Reversibility socioeconomic, or watershed, (short-term, (minor, (negligible, low, intermittent, (reversible or cultural importance regional, medium-term, moderate, major) medium, high) continuous) irreversible) (negligible, low, provincial long-term) medium, high) scale) Vegetation and Plant Communities Ecosystem Loss of • Vegetation Management Plan Yes Medium Local Long-term Once Reversible Medium Moderate The residual Composition baseline • Maximize use of previously disturbed areas environmental ecosystems to maintain a compact project footprint effects are not • Dust suppression in line with the Dust likely to be Management Plan significant. • Maintain soil salvage for reclamation • Reclamation and Closure Plan Wetland Loss of listed • Wetland compensation plan Yes Medium Local Long-term Once Irreversible Medium Moderate The residual Additional information will be incorporated Ecosystems wetlands • Site survey and characterization of blue- and environmental into the draft Wetlands Compensation red-listed wetland communities, including effects are not Plan in consultation with Environment wetland function to migratory birds and SAR likely to be Canada. • Terrestrial Ecosystem Mapping to identify significant. wetlands before establishment of footprint and construction laydown areas • Maintaining soil salvage for reclamation • Maximize use of previously disturbed areas to maintain a compact project footprint • Reclamation and Closure Plan Old Forests Loss of • Site map of old forest stands within the Yes Low Local Long-term Once Irreversible Medium Minor The residual baseline old project footprint area environmental forests • Timber Salvage as part of the Vegetation effects are not Management Plan likely to be • Maximize use of previously disturbed areas significant. to maintain a compact project footprint • Reclamation and Closure Plan Species at Loss of • Species at risk avoidance during construction Yes Low Local Long-term Once Reversible High Minor The residual Prior to the commencement of Risk baseline clearing environmental construction, the proponent must conduct ecosystems • Invasive Species management effects are not a site assessment survey of Cryptic Paw for species at • Maximize use of previously disturbed areas likely to be Lichen within and near the immediate risk to maintain a compact project footprint significant. Kitsault Mine footprint in areas that • Maintain soil salvage for reclamation. include Cryptic Paw Lichen habitat. • Reclamation and Closure Plan The assessment will be undertaken by a lichen specialist and inform the development of guidance and protocols that will be implemented in the event Cryptic Paw Lichen is identified. Ecological Loss of • Site map of ecological communities at risk Yes Low Local Long-term Once Reversible High Minor The residual Communities baseline within the project footprint area. environmental at Risk ecological • Maximize use of previously disturbed areas effects are not communities to maintain a compact project footprint likely to be at risk • Invasive Species management significant. Introduction • Maintain soil salvage for reclamation and spread • Reclamation and Closure Plan of invasive plants Cultural Plants Loss of • Maximize use of previously disturbed areas Yes Medium Local Long term Once Reversible Medium Moderate The residual cultural plants to maintain a compact project footprint environmental and habitat for • Timber Salvage as part of the Vegetation effects are not cultural plants Management Plan likely to be • Invasive Species management significant. • Maintain soil salvage for reclamation • Reclamation and Closure Plan

131 CEAA—Comprehensive Study Report: Kitsault Mine Project Table E-10: Environmental Effects Analysis for Wildlife and Wildlife Habitat

VEC Affected Potential Effect Proposed Mitigation Residual Predicted Degree of Effect After Mitigation Significance Agency Follow-up Requirement Effect of Effect After Conclusion Extent Mitigation (yes/no) Duration Ecological, (local, Frequency Magnitude (short-term, Reversibility socioeconomic, or (minor, watershed, (once, (negligible, low, medium- (reversible or cultural importance moderate, regional, intermittent, medium, high) term, long- irreversible) (negligible, low, major) provincial continuous) term) medium, high) scale) Wildlife and Wildlife Habitat Western Toad Habitat loss, • Surveys (e.g., wetlands, ponds and along Yes Low to Medium Local Long-term Intermittent to Reversible Low Minor The residual • Prior to construction, a disruption of access roads) and salvage prior to clearing sensitive wildlife habitat continuous environmental movement, activities during breeding and dispersal effects are not map and site-specific mortality periods and protocols to minimize risks likely to be mitigation measures • Maximizing previously disturbed areas to significant. will be developed and maintain a compact project footprint provided to federal and • Wildlife Management Plan provincial authorities prior to implementation. • Protocols for minimizing Olive-sided Habitat loss, • Avoid activity during the sensitive bird Yes Low Local Long-term Intermittent Reversible Medium Minor The residual risks to western toads will Flycatcher disruption of breeding period (1 April to 31 July). environmental be provided to federal and movement, • Maximizing previously disturbed areas to effects are not provincial authorities prior mortality maintain a compact project footprint likely to be to implementation. • Noise Management Plan significant. • A desk-based assessment • Transportation and Access Management Plan to characterize and • Reclamation and Closure Plan identify potential bat hibernacula sites in the LSA. If the assessment Sooty Grouse Habitat loss, • Avoid activity during the sensitive bird Yes Low Local Long-term Intermittent Reversible Low Minor The residual identifies areas of high sensory breeding period (1 April to 31 July). environmental potential bat hibernacula, disturbance • Maximizing previously disturbed areas to effects are not a site assessment will (noise), mortality maintain a compact project footprint likely to be be conducted in those • Noise Management Plan significant. areas. The results of • Wildlife Corridor Management Plan the desk-based and • Reclamation and Closure Plan field assessment will be • Wildlife Management Plan provided to federal and Northern Mortality, sensory • See mitigation for Sooty Grouse No provincial authorities. Goshawk disturbance, and habitat loss American Habitat loss, • Maximizing previously disturbed areas to Yes Low Local Medium-term Intermittent Reversible Low Minor The residual Marten mortality maintain a compact project footprint environmental • Identify and avoid sensitive habitats adjacent effects are not to worksites likely to be • Removal of carrion along the road. significant. • Wildlife Corridor Management Plan • Solid Waste Management Plan • Reclamation and Closure Plan Mountain Goat Mortality • Road management strategies including No and sensory improving lines-of-sight, creating escape disturbance corridors along roadside snow banks during winter • Transportation and Access Management Plan • Wildlife Management Plan • Noise Management Plan

132 CEAA—Comprehensive Study Report: Kitsault Mine Project Table E-10: Environmental Effects Analysis for Wildlife and Wildlife Habitat continued

VEC Affected Potential Effect Proposed Mitigation Residual Predicted Degree of Effect After Mitigation Significance Agency Follow-up Requirement Effect of Effect After Conclusion Extent Mitigation (yes/no) Duration Ecological, (local, Frequency Magnitude (short-term, Reversibility socioeconomic, or (minor, watershed, (once, (negligible, low, medium- (reversible or cultural importance moderate, regional, intermittent, medium, high) term, long- irreversible) (negligible, low, major) provincial continuous) term) medium, high) scale) Moose Mortality, sensory • Wildlife Corridor Management Plan Yes Medium Regional Long-term Intermittent Reversible High Moderate The residual disturbance • Geographic Response Plan environmental and alteration • Transportation Safety Plan effects are not of movement • Noise Management Plan likely to be patterns • Reclamation and Closure Plan significant. • Maximize us of previously disturbed areas to maintain a compact project footprint • Provide transportation for employees • Support moose recovery • Participation in cross industry or government strategies to address road use adjacent to or intersecting moose habitat along Highway 37 • Provide on-site accommodation to Conservation Officers during enforcement activities • Develop and implement plan for barrier protection Grizzly Bear Mortality, attractant • Bear Interaction Management Plan Yes Low Regional Long-term Intermittent Reversible Medium Minor The residual to project activities • Solid Waste Management Plan environmental and infrastructure • See mitigation for moose effects are not likely to be significant.

133 CEAA—Comprehensive Study Report: Kitsault Mine Project Table E-11: Environmental Effects Analysis for Land and Resource Use

VEC Affected Potential Effect Proposed Mitigation Residual Effect Predicted Degree of Effect After Mitigation Significance Agency Follow-up of Effect After Conclusion Requirement (yes/no) Extent Ecological, Magnitude Duration Frequency Mitigation (local, Reversibility socioeconomic, or (negligible, (short-term, (once, watershed, (reversible or cultural importance (minor, moderate, low, medium, medium-term, intermittent, regional, irreversible) (negligible, low, major) high) long-term) continuous) provincial scale) medium, high) Land and Resource Use Current uses Project footprint • Environmental Management Yes Low Regional Long-term Continuous Reversible Medium Minor The residual of lands and reduces or removes Plans environmental resources for access to areas for • Marine Environment Monitoring effects are not traditional purposes traditional uses Program likely to be by Aboriginal • Wildlife Corridor Management significant. people Plan Trapping and guide Project footprint • Access management strategy Yes Low Local Long-term Continuous Reversible Negligible Minor The residual outfitting reduces or removes environmental access to trapping effects are not and guide outfitting likely to be opportunities significant. Country foods Potential human • Marine Environment Monitoring Yes Low Local Long-term Intermittent to Irreversible High Minor The residual health risk from Program continuous environmental exposure to metals in • Communications procedure with effects are not country foods local stakeholders likely to be • Transportation Safety Plan significant.

134 CEAA—Comprehensive Study Report: Kitsault Mine Project Appendix F Comparison of Predicted and Current Water Quality Against Water Quality Guidelines

Table F-1: Comparison of Predicted Water Quality with CWQG/BC WQG and Current Water Quality at LC1 in lower Lime Creek

Predicted concentrations for the “worst case” periods of time during the mine life

Operations Year 13 Closure Year 14 Post-Closure Year 2 Post-Closure Year 31 Current

Annual CWQG/ Annual CWQG/ Annual CWQG/ Annual CWQG/ Annual CWQG/ Maximum Maximum Maximum Maximum Maximum Average BC WQG Average BC WQG Average BC WQG Average BC WQG Average BC WQG

Cadmium (mg/L) 0.08* 0.13 0.04 0.04* 0.08 0.01 0.04* 0.08 0.05 0.06* 0.11 0.03 0.22 0.89 0.02

Aluminum 60.69 84.31 501/1002 36.18* 53.86 501/1002 41.89 60.58 501/1002 33.45* 49.75 501/1002 36.43 93.20 501/1002 (mg/L)

Sulphate (mg/L) 71.23 85.73 100 18.57* 28.39 100 138.65 188.48 100 56.42 74.75 100 37.67 69.60 100

a. For aluminum - 1BC WQG 30-day guideline and 2BC WQG maximum b. “Worst case” signifies a period when elevated concentrations of parameters are anticipated c. CWQG/BC WQG calculated with average annual hardness values for cadmium d. “*” signifies predicted annual average is below current average water quality concentrations e. Predicted concentrations exceeding CWQG/BC WQG concentrations f. Current conditions are average measured concentrations based on monthly data sampled at LC1 during water quality sampling

135 CEAA—Comprehensive Study Report: Kitsault Mine Project Appendix G Monthly Flows in Lower Lime Creek (LC1) Average Monthly Flows in Lower Lime Creek (Sourced from KPL Letter VA12-01685) Figure G-1: Comparison of Average Monthly Flows in Lower Lime Creek (LC1) Relative to the Natural Hydrograph

16,000,000 LC1 Current ‐ Average LC1 Operations Yr 13 Scenario 1 LC1 Operations Yr 13 Base Case 14,000,000 LC1 Closure Yr 14 LC1 Post‐Closure Yr 2 LC1 Post Closure Yr 31 12,000,000

10,000,000

8,000,000 /month 3 m

6,000,000

4,000,000

2,000,000

0 January February March April May June July August September October November December NOTE: 1. "CURRENT" FLOW CONDITIONS WERE EXTRACTED FROM THE LIME CREEK PRE‐MINE WATERSHED MODEL. 2. FLOW VOLUMES FOR THE VARIOUS MINE PHASES WERE EXTRACTED FROM THE FLOW BALANCE IN THE WATER QUALITY MODEL. 3. THE BASE CASE SCENARIO FLOWS FOR OPERATIONS YR 13 (DOTTED LINE) WERE REFERENCED FROM KNIGHT PIESOLD LTD LETTER VA11‐00964.

136 CEAA—Comprehensive Study Report: Kitsault Mine Project Appendix H Summary of Public Comments Consultation Consultation Summary of Comments Document Period • Risks to human safety and the potential effects to groundwater sources and marine ecology in Alice Arm in the event of failure of the TMF Conduct of the November 8– • Potential risks to the geotechnical stability of the TMF during seismic events Comprehensive December 10, • Ecological implications of removing Patsy Lake Study 2010 • Financial bonding for potential ecological effects to Alice Arm • Economic costs of moving forward with the Project • Project will provide an economic boost to nearby communities • Project will generate new investment and employment in Terrace and Northwest BC • Potential effects of seismic and volcanic activity on the Project, particularly in terms of Environmental the proposed TMF and soil storage areas May 11–June Impact • Potential decline in Lime Creek water quality 11, 2012 Statement (EIS) • Potential effects on Kitsault Resorts, including groundwater and surface water quality effects, increased road use and traffic, health and safety on residents and visitors, and the economics implications of mine development

CEAA—Comprehensive Study Report: Kitsault Mine Project 137 Appendix I FSRs. Develop the design and location of Aboriginal Consultation: Further information the pullouts through discussions with the Gitanyow First Nation and consider the best Mitigation and Monitoring available scientific research. ••Inspect the FSRs and brush vegetation Key mitigation measures and monitoring to improve wildlife visibility in areas requirements that address potential effects to where the lines-of-sight are poor. Develop asserted Aboriginal rights to hunting, trapping, brushing widths, frequency, and riparian fishing and other land uses are summarized below. set-backs through discussions with the Gitanyow First Nation and consider the best Metlakatla First Nation available scientific research. During the EA, the following measures were ••Create a map of the transportation developed to mitigate the potential effects of the corridors that identify important Project on the asserted marine harvesting rights environmental features and sensitive of the Metlakatla First Nation. moose habitats and identify measures to reduce disturbance to these areas (e.g., ••Implement new water treatment, including reduced speed limits, increased signage, an in-mill treatment and filtration system and increased vegetation brushing widths, conventional HDS treatment with sulphide snow escape routes). Distribute the map to addition in post closure, to improve water quality all mine-related vehicle drivers. in the Lime Creek and Clary Creek watersheds. ••Place wildlife signage along the FSRs ••Meet B.C. Water Quality Guidelines or Site in areas of potential wildlife collisions Specific Water Quality Objectives. with emphasis on high moose population ••Develop the MEMP in consultation with the areas. Establish the design and placement Metlakatla First Nation. The monitoring results of signage through discussions with the will be used to determine the effectiveness of Gitanyow First Nation. measures taken to mitigate effects on marine ••Develop protocols for reduced vehicle water uses and to determine if additional movement during dawn and dusk periods, management actions are warranted to prevent or and for convoys (a component of the Traffic address unforeseen impacts. Control Plan). ••Share the monitoring results from the MEMP ••Establish procedures for immediately with the Metlakatla First Nation. reporting moose kills to provincial ••Consult with the Metlakatla First Nation the authorities and Aboriginal groups, including development of management and monitoring plans. the Gitanyow First Nation. ••Implement a no hunting and fishing policy Gitanyow First Nation for all employees and contractors while During the EA, the following mitigation measures working directly or indirectly for the were developed to mitigate the potential effects of Project. transportation and FSR use on the asserted wildlife ••Develop a Wildlife Observe/Record/Report harvesting rights of the Gitanyow First Nation. Program in consultation with regional Conservation Officers. ••Develop a Wildlife Corridor Management Plan ••Establish an Employee Education and prior to construction, which will include the Environmental Awareness Program. following mitigation measures: ••Support recovery of the Nass moose ••Remove snow to create pullouts for wildlife population. escape routes at key locations along the

138 CEAA—Comprehensive Study Report: Kitsault Mine Project ••Develop a Large Mammal Monitoring and ••Develop requirements and procedures Reporting Program (i.e., moose, bears, and for spill reporting and notification to goats) that includes: government agencies, the NLG, and ••Procedures for contractor initiation Aboriginal groups and training; ••Establish five separate equipment ••Protocols with contractor companies, caches along the transportation independent drivers, and mine corridors for timely response to spills employee drivers that includes ••Identify and train spill responders to successive levels of penalties or respond and implement spill response consequences for non-compliance; tactics ••GPS wildlife recording devices ••Conduct regular spill response drills installed in mine-related vehicles; and exercises ••Recording and reporting of large ••Pursue opportunities to harmonize mammal-vehicle near miss, injury or spill response kits and plans with other mortality, and observations of dead industrial operators in the region large mammals; ••Develop and implement a plan describing ••Data reporting and radio appropriate forms of barrier protection communication protocols for along areas of the proposed transportation distributing information on large corridors with high aquatic values that could mammal observations and incidents; be at risk from spills of hazardous materials. ••Evaluation and reporting of results to identify high potential areas (i.e., Gitxsan Nation location, time of day, season) for large During the EA, the following mitigation measures mammal-vehicle collisions; and were developed to mitigate the potential effects ••Compliance monitoring, including of the transportation corridors on the asserted periodic audits for conformance and wildlife harvesting rights of the Gitxsan Nation. to assess the effectiveness of the program and identify opportunities for ••Develop and implement the measures set out improvements. in the Wildlife Corridor Management Plan ••Develop and implement a Geographic to minimize potential mine-related vehicle Response Plan prior to construction to collisions with wildlife. provide training and hazardous material ••Develop and implement the Transportation spill response approaches along the Safety Plan to prevent and address spills and transportation corridors. The Plan includes other potential impacts on water bodies along the the following elements: Cranberry Connector, including the installation ••Identify all hazardous and bulk of barriers in environmentally sensitive areas. materials that pose a risk to the ••Consult on barrier protection along the environment or public safety transportation corridors. ••Conduct a fate and effects assessment ••Participate in future regional cumulative effects for each identified material assessments, management, and planning efforts ••Produce maps identifying areas of related to traffic along the Highway 37 and high environmental sensitivity along Highway 113 transportation corridors. the transportation corridors ••Develop and implement the Vegetation ••Develop site specific spill response Management Plan, which will include invasive tactics and training and resources to species management to reduce the potential implement these tactics

CEAA—Comprehensive Study Report: Kitsault Mine Project 139 spread of invasive species from the mine site to areas of the proposed transportation corridors the transportation corridors. with high aquatic values that could be at risk from spills of hazardous materials. Kitsumkalum First Nation During the EA, the following mitigation Kitselas First Nation measures were developed to mitigate the potential The Kitselas First Nation did not submit any effects of the Project on the asserted fishing and comments or identify any issues or potential wildlife harvesting rights of the Kitsumkalum effects in relation to the Project. No specific First Nation. mitigation or accommodations were developed during EA Application Review specifically for the ••Develop a communications protocol as part Kitselas First Nation. The proposed transportation of the Wildlife Corridor Management Plan. mitigation measures should address the potential ••Develop and implement a Geographic Response effects to any potential Kitselas First Nation Plan prior to construction to provide training and Aboriginal rights. hazardous material spill response approaches along the transportation corridors. The Plan Métis Nation of British Columbia includes the following elements: The mitigation measures identified in the EA ••Identify all hazardous and bulk materials process are expected to address the potential that pose a risk to the environment or public effects of the Project on surface water and safety groundwater quality (Sections 4.2.3 and 4.4.3), ••Conduct a fate and effects assessment for and fish and fish habitat (Section 4.5.3), which each identified material were of interest to MNBC. ••Produce maps identifying areas of high environmental sensitivity along the transportation corridors ••Develop site-specific spill response tactics and training and resources to implement these tactics ••Develop requirements and procedures for spill reporting and notification to government agencies, the NLG, and Aboriginal groups ••Establish five separate equipment caches along the transportation corridors for timely response to spills ••Identify and train spill responders and implement spill response tactics ••Conduct regular spill response drills and exercises ••Pursue opportunities to harmonize spill response kits and plans with other industrial operators in the region ••Develop and implement a plan describing appropriate forms of barrier protection along

140 CEAA—Comprehensive Study Report: Kitsault Mine Project