IR3-1 Cumulative Effects Assessment

Marathon Palladium Project (CIAR File No. 54755) Prepared on July 29, 2021 Generation PGM Response to the Joint Review Panel’s Request for Information #3 Received July 13, 2021

References:

EIS Guidelines, Section 2.7.1.4 (CIAR# 150) EIS Addendum (2021), Chapter 6.3-6.7, Section 6.6.5 (CIAR# 727) EIS Addendum (2021), Appendix D2, Tables 6.2 and 6.4 (CIAR# 727) Information Request 5.3 and 5.4 – Noise Cumulative Effects (CIAR# 421) Information Request 20.1- Assessment of Cumulative Effects (CIAR# 489) Information Request 20.2 – Sources of Cumulative Effects (CIAR# 489) Information Request 20.3 - Existing and Future Projects in the Region (CIAR# 489) Information Request 20.4 – Transparency of Conclusions (CIAR# 489)) Supplemental Information Request 11 – Cumulative Effects Assessment (CIAR# 586)

Rationale:

The Panel has reviewed the proponent’s (Stillwater Canada Inc.) responses to previous information requests on cumulative effects and Generation PGM Inc.’s cumulative effects assessment in the EIS Addendum. The Panel has determined that GenPGM’s approach to its cumulative effects assessment lacks many of the key elements required in the Canadian Environmental Assessment Act, 2012 (CEAA 2012) and the Environmental Impact Statement (EIS) Guidelines, In addition, the approach does not incorporate many of the significant advancements made since the original EIS (2012) in carrying out a cumulative effects assessment (e.g. use of quantitative data, ecosystem environmental management, avoiding shifting baseline).

Inclusion of Past and Present Projects

CEAA 2012 requires that the environmental assessment take into account any cumulative effects that are likely to result from the designated project in combination with other physical activities that have been or will be carried out.

In addition, Section 2.7.1.4 of the EIS Guidelines requires the proponent to describe the analysis of the total cumulative effect on a valued ecosystem component (VEC) over the life of the Project, including the incremental contribution of all projects and activities, in addition to that of the Project. The EIS shall include different forms of cumulative effects (e.g., synergistic, additive, induced, spatial or temporal) and identify impact pathways and trends.

Generation PGM Inc. (GenPGM) assessed cumulative effects by examining the potential for the residual effects of the Project to combine with effects of other certain and reasonably foreseeable projects and activities. GenPGM states that the effects of past and present projects contribute to baseline conditions upon which Project effects are assessed. The cumulative effects of these past and present projects and physical activities are inherently considered, as relevant and appropriate, in the assessment of project effects. As such, the cumulative effects assessment largely focuses on the potential for the residual effects of the Project to act in combination with the residual effects of future projects and activities (CIAR# 727, Section 6.6.5).

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Through a brief regional historical overview GenPGM acknowledges that some VECs have been previously affected by past developments. However, considering the current conditions in an area that has experienced effects from previous projects and activities as the baseline may not provide a reasonable understanding of the cumulative effects from successive past and present projects. If each successive project in an area incorporates past effects into the baseline, the baseline would continually shift and significant effects to VECs could be overlooked. The effects from past and existing projects on a VEC, including how those project activities contribute(d) to the current state of the VEC, must be described and considered on their own and not simply incorporated as a reflection of the current baseline condition of the VEC. Cumulative effects should be defined as effects of an additive, interactive, synergistic nature that are caused by individually minor but collectively significant activities, accumulated over broad temporal and spatial scales. The use of an appropriate temporal baseline provides some sense of scale regarding the contribution of past and current projects and activities to cumulative effects in the region. This can be particularly important when assessing cumulative effects on a VEC that has no standards or guidelines, such as traditional land and resource use.

To fulfill the requirements of the EIS Guidelines and CEAA 2012, and to understand the cumulative environmental change, the assessment needs to provide a clear understanding of both the estimated cumulative effects on VECs from past, present and future projects and activities, and the contribution of the Project to the cumulative effects.

For example, in Section 6.6.6.6.1 of the EIS Addendum, GenPGM indicates that 17,514 ha of forest is scheduled to be harvested within the Pic Forest between 2020 and 2021 and during the life of the mine. The area cleared for commercial forestry in the Pic Forest FMU (and subsequently regenerated) will be at least two orders of magnitude larger than the footprint of the SSA. GenPGM further states that incremental loss of forest-type vegetation from other future projects/activities (e.g., wind and hydro power developments, mineral exploration) would require land clearing activities. GenPGM concludes that the cumulative residual effect on forest-cover associated with timber harvesting will likely be the most substantial and the relative contributions of the Project and other activities will be relatively minor in comparison. While this comparison may be accurate, without a clear depiction of the incremental changes over time (e.g. how past and current timber harvesting projects and activities have shaped the landscape quantitatively), it does not provide an accurate assessment of the total cumulative effect with the Project.

The Panel is of the view there is a gap in the current understanding of how effects from multiple other projects and activities in combination with the Project, and not in comparison to the effects of the Project, will accumulate over time and space to have a potential greater overall effect on the environment.

Project Interactions

In Chapter 6.6, Table 6.6-3 of the EIS Addendum, GenPGM presents a summary of other projects and activities (Project Inclusion List) that may interact with identified residual effects of the Project. Where it is possible for the residual effects from the Project to interact with residual effects from other projects and physical activities, a cumulative effects assessment was completed. GenPGM states that the Project Inclusion List is conservative and inclusive of potential projects and activities that could have the potential to act cumulatively with the proposed Project. However, many identified interactions have no further discussion or consideration in GenPGM’s cumulative effects assessment. While one could assume this to mean there is no spatial or temporal overlap between projects’ residual effects, there is little evidence to support such an assumption.

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For example, while Table 6.6-3 indicates that land and resource use, hydroelectric and wind power projects, construction activities associated with BN and Magino Gold Project have no interaction with the Project, it explains, to some degree, why these projects/activities do not contribute to cumulative effects on noise levels and ground vibration. However, it is not clear why noise levels from the Town of Marathon landfill and the Town of Marathon waste transfer station, which were identified as having an interaction with the Project, were not considered in GenPGM’s conclusion on cumulative effects on noise levels and vibration.

Similarly, while the cumulative effects assessment on vegetation identified eleven projects and activities interacting with the Project, the majority of them were not carried forward to the discussion or considered in GenPGM’s conclusion on cumulative effects on vegetation. Of particular note is the omission of a discussion on how the potential residual effects of the East-west tie transmission corridor, which is a 450 km by 70 m wide transmission line, may interact with the residual effects of the Project.

In Table 6.6-3 of the EIS Addendum, GenPGM indicates that the Magino Gold Project would interact with the Project for a number of VECs. GenPGM repeats that the Magino Gold Project is located well outside the Regional Study Area (RSA) and, therefore does not warrant further consideration. GenPGM’s approach to its cumulative effects assessment clearly states other projects and activities do not have to be located within the RSA, but their effects have to interact cumulatively with those of the Project. It is unclear what criteria GenPGM used to determine spatial overlap and why the Hemlo Gold Mine Camp located approximately 30 km southeast of the SSA was not identified or discussed for a number of VEC (e.g. Water Quantity and Quality).

Finally, GenPGM states that the Project will remove 1,116 ha of area from resource and recreational use and will overlap with waterbodies used for sport fishing. GenPGM further states that the potential for cumulative interactions is limited given the lack of defined future projects or activities and that the exact areas for future resource activities are currently unknown. It is unclear why GenPGM is only considering other land and resource projects in combination with land and resource use of the Project in its cumulative effects assessment. In the Project Inclusion List, twenty other projects and activities were identified with the potential to contribute to cumulative effects on the Socio-economic Environment, including timber harvesting, which GenPGM notes has largely contributed to land clearing in the area. The cumulative effects assessment on land and resource use may have underestimated effects given the number of current and reasonably foreseeable projects and past disturbances that appear to be in the RSA.

Assessment Approach

As defined by the EIS Guidelines, residual effects refer to those environmental effects of the Project that remain after the implementation of mitigation measures. As presented by GenPGM (EIS Addendum, Table 6.6-1), all VECs, with the exception of Physical and Cultural Heritage, have adverse environmental effects that will not be fully mitigated. The Panel understands that regardless of the overall rank of the residual effect (negligible, low, medium, high) additional mitigation measures are not being proposed. In its cumulative effects assessment, GenPGM states that with proposed mitigation and environmental management to be implemented with the Project, and other projects/activities, the overall adverse cumulative residual effect is predicted to be not significant. The concept of cumulative effects assessment is identify, mitigate and manage the effects of multiple stressors.

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The Panel also notes that in Section 6.1.3 of the EIS Addendum, GenPGM defines magnitude as "the amount of change in measurable parameters of the VEC relative to existing conditions". For its cumulative effects assessment, GenPGM does not define magnitude making it difficult to determine how magnitude was applied to the overall cumulative effects conclusions. GenPGM needs to define and quantify magnitude in a way that takes into account the amount of change in a measurable parameter from past, present and future baseline conditions and not broadly “in the context of the RSA”.

The Panel is of the view that the cumulative residual effects, especially in the absence of mitigation measures, have not been appropriately characterized.

Information Request:

1. a) Following GenPGMs approach to cumulative effects outlined in Section 6.6.5 of the EIS Addendum, and the approach detailed in question 2 below, where an interaction between projects and activities from the Project Inclusion List and Project-related residual effects is identified (), provide a cumulative effects assessment that includes a description on how the potential residual effects overlap temporally and spatially.

b) Provide a rational as to why projects, such as the Hemlo Gold Mine Camp, were not discussed or considered in the cumulative effects assessment.

2. Provide a cumulative effects assessment that clearly describes:

• how each VEC has been affected by past projects and activities (i.e. account for incremental changes over time to determine how past and current projects and activities contribute to the current baseline condition). • how residual effects of the Project could further affect each VEC; • how other certain and reasonably foreseeable projects and activities may also affect the VEC; and • the total (overall) cumulative effect from present condition to predicted future conditions. Total cumulative effects assessment will be characterized using well defined criteria and include a discussion on how the residual effects of some VECs can cumulatively add up to have a greater cumulative effect on other VECs.

3. Provide a cumulative effects assessment for land and resource use that includes:

a) a map of the RSA for land and resource use (SSA + 35 km buffer) that shows all the past, current and future foreseeable projects and activities.

b) a map that includes current and future disturbances in the RSA due to timber harvesting and associated road networks.

c) the total amount of area currently disturbed in the RSA due to timber harvesting.

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GenPGM Response:

A cumulative effects assessment (CEA) as requested here in IR 3-1 Part 1(a), and also as requested below in IR 3-1 Part 2 (which Part 1 mentions), has been provided. The following discusses the basis of this assertion.

The method used to conduct the CEA is summarized as follows, this following a sequential step-wise approach that reflects current CEA guidance and precedence:

• Step 1: Identification of Project effects on VECs: EIS Addendum Section 6.6.2, Table 6.6-1 itemizes each effect from the proposed Project (as assessed in Section 6.2).

• Step 2: Identification of other projects and activities that may interact cumulatively with the proposed Project: EIS Addendum Section 6.6.4, Table 6.6-2 itemizes past, present, and future (certain and reasonably foreseeable) projects and activities in the region (within the Regional Study Areas [RSAs] for each VEC), where those other projects and activities may also have the same effects that act cumulatively with those of the proposed Project. The location of those other projects and activities is shown in Figure 6.6-1.

• Step 3: Identification of potential incremental effects on a VEC by both the proposed Project and other projects and activities: EIS Addendum Section 6.6.5, Table 6.6-3 identifies which specific VECs, affected by the proposed Project, may also be affected by other projects and activities.

• Step 4: Assessment of potential cumulative effects: EIS Addendum Section 6.6.6 assesses potential cumulative effects for each VEC.

− The minimum basis of this assessment is a qualitative narrative that discusses potential project interactions when and where such interactions are due to the same effects on the same VEC. As such, this means that other project and activities are not explicitly discussed if they were not identified in Step 3 as having a potential cumulative effects interactions. As a result, not all other project and activities are explicitly named in this section. Some projects and activities may also be implicitly recognized for their contribution to cumulative effects, such as land clearing, hence, again, have not always been explicitly named. The effects of these unnamed projects are captured in the consideration of baseline conditions.

− That discussion is supplemented as appropriate and available with additional quantitative information.

− The assessment takes into consideration the historical information provided in EIS Addendum Section 6.6.1.1 Regional Historical Overview, organized by major groupings of projects and activities known to be representative of post-European contact anthropogenic disturbances. As appropriate and relevant, such past conditions are recognized regarding their contribution to current conditions, that combined (past and current) represent conditions against which potential incremental cumulative effects are assessed. Also, see below regarding applicability and

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adequacy of the CEA on the issue of invocation of historical baseline, as discussed in the IR rationale.

• Step 5: Assessment of cumulative effects without the Project: EIS Addendum Section 6.6.7 assesses cumulative effects without the proposed Project.

• Step 6: Overall cumulative effects and contribution of the proposed Project to cumulative effects: EIS Addendum Section 6.6.8, Table 6.6-4 summarizes the outcome of the assessment of residual cumulative effects by summarizing overall regional cumulative effects by all contributors for all relevant effects for all VECs (With the Project), cumulative effects without the Project (Without the Project), and contribution of the proposed Project to overall regional cumulative effects (Contribution from the Project to the Residual Cumulative Effect).

As such, given above, and as per the request, the CEA as conducted does “provide a cumulative effects assessment that includes a description on how the potential residual effects overlap temporally and spatially”. In summary, Step 1 states what effects the proposed Project may have. Step 2 states what other projects and activities there have been, are there, and will or may be there in the region. Step 3 combines steps 1 and 2 by stating if the proposed Project effects (Step 1) may interact with other projects and activities (Step 2). Step 4 proceeds to assess what may occur regarding cumulative interactions, and hence only mentions situations in which that may occur, and in recognition (often implicit) of the past (i.e., conditions prior to present). Step 5 assesses what the region may “look like” without the proposed Project. Finally, Step 6 summarizes the key outcomes of that assessment; i.e., what the cumulative effects by everything may be, what the cumulative effects may be if there was no proposed Project, and what the contribution of the proposed Project may be to the overall cumulative effects. As such, all relevant consideration spatially and temporally has been accomplished.

Regarding past or “historical” conditions, the CEA has followed guidance and precedence and as such represents an applicable and adequate assessment of cumulative effects. This is substantiated in the following two federal guidance publications. First, that “Present-day environmental conditions reflect the cumulative environmental effects of many past and existing physical activities” (Canadian Environmental Assessment Agency, Operational Policy Statement: Assessing Cumulative Environmental Effects under the Canadian Environmental Assessment Act, 2012, March 2015, p. 4). Second, that conditions should also recognize the “nature of the perturbation and the persistence of potential cumulative effects” (Canadian Environmental Assessment Agency, Assessing Cumulative Environmental Effects under the Canadian Environmental Assessment Act, 2012, Interim Technical Guidance, March 2018, Version 2, p. 19). In the Project region, dominant regional landscape drivers of change for many or all VCs over an historical period include forestry, settlement, power generation and transmission, and mining. This is recognized in the CEA starting with the Regional Historical Overview and continued as relevant in the subsequent assessment.

Further, regarding the characterization of historical baseline and future projects and activities, this CEA, as with any CEA, is limited in its ability to characterize environmental and anthropogenic conditions given the limited if not complete lack of adequate information in the far past and far future. That limitation typically means that the resolution of such information (i.e., degree of detail) actually available in any form is coarse and with gaps, and is not at an equivalent basis as the characterization of current conditions

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upon which the comparison of incremental direct project effects depends. As such, the CEA makes the best use of available information to provide as meaningful and useful information as possible towards the assessment of potential cumulative effects. Further, the CEA does not ignore the “shifting baseline syndrome” but recognizes, where appropriate and applicable, VECs that currently (which typically is a consequence of past conditions) may exist in a compromised state relative to some state in the far past. The inevitable trajectory of any environment subject to common post-Colonization influences (e.g., settlement, agriculture, industry) will be some degree of diminishment of environmental values when compared to post-glacial “pristine” conditions, along with thousands of years of broad landscape scale natural environmental change (such as climate, fire and floods), little to none of that (depending on the VC) resolvable in detail to allow other than generalized comparisons.

However, notwithstanding the above, in consideration of a key comment in the request’s Rationale, and of the specific Part 1 request, GenPGM offers in response to Part B below, a brief statement of additional clarification regarding in what way each other project and activity was considered in the assessment of cumulative effects for each VEC. As such, this will make explicit what may not have been adequately clear in the CEA.

b. Provide a rational as to why projects, such as the Hemlo Gold Mine Camp, were not discussed or considered in the cumulative effects assessment.

An updated project and activity inclusion list was provided in Section 6.6.4 of EIS Addendum Volume 2 (Table 6.6-2) and included known past, present and reasonably foreseeable future projects and physical activities that could act cumulatively with the Project’s residual environmental effects. The list was developed in consideration of the VEC specific Regional Study Areas (RSAs) and is believed to be fulsome in that context. As noted in Section 6.6.5 of EIS Addendum Volume 2, the effects of past and present projects contribute to baseline conditions upon which Project effects were assessed; as such, the cumulative effects of these past and present projects and physical activities are inherently considered, as relevant and appropriate, in the assessment of Project effects presented in Section 6.2 of EIS Addendum Volume 2. With this in mind, the cumulative effects assessment largely, though not exclusively, focused on the potential for the residual effects of the Project to act in combination with the residual effects of future projects and activities.

As indicated above, additional clarification regarding in what way each other project and activity was considered in the assessment of cumulative effects for each VEC (see Attachment A). In the attachment, Table 6.6-2 is revisited and a brief explanation of potential interactions with the Marathon Project, as well as the consideration of these interactions in Section 6.6 of the EIS Addendum Vol. 2 is provided.

It is noted that the information request specifically highlighted two existing projects/activities – Hemlo Gold Mine Camp and the East-West Tie Transmission Line Expansion – and further consideration of each is provided as follows:

• The Hemlo Gold Mine Camp is of particular interest locally/regionally as it would likely be considered one of, if not the most significant mining project in the area. Past issues have been documented on the environmental performance of the mines that make up the Hemlo Camp, though active

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reclamation is ongoing and only one of the mines is in operation. The project-interaction matrix (Table 6.6-3) did not identify specific interactions with biophysical VECs, but acknowledged interactions with the “socio-economic” and “indigenous considerations” VECs. No interactions were identified for the biophysical VECs, since, as described above, effects (such as for example, effects related to land disturbance) were inherently recognized in the assessment of Project-specific effects. As identified in Table 6.6.2, there is treated effluent discharge associated with the Hemlo Camp to the Black River (Pic River tributary); however, no spatial overlap is identified between this and associated Marathon project VECs will occur that would necessitate the consideration of cumulative effects from a water quality (and related) perspective.

• The East-West Tie Transmission Line Expansion project is associated with a disturbance corridor that is on the order of 450 km in length and 70 m wide. The corridor is largely associated with the expansion of existing disturbed areas. Most of the corridor falls outside the VEC-specific RSAs defined for the environmental assessment, though there is some spatial overlap. The construction of the East-West Tie Transmission Line Expansion project will be completed by the first quarter of 2022 and is unlikely to temporally overlap with the Marathon project in that respect. Potential land disturbance and associated effects, including those associated with the East-West Tie Transmission Line Expansion project within the RSA, were considered within the context of the assessment of Project effects presented in Section 6.2 of EIS Addendum Volume 2 as they were assumed to be already part of the existing landscape.

2. Provide a cumulative effects assessment that clearly describes:

The requested information has been provided. This Part 2 request is substantially similar to the previous Part 1 request. As such, the following response to each sub-part of this Part 2 request draws on aspects of the response to Part 1:

See response to Part 1 in reference to Step 4, which included consideration of the information provided in the Regional Historical Overview.

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• how residual effects of the Project could further affect each VEC:

See response to Part 1 in reference to Step 4.

• how other certain and reasonably foreseeable projects and activities may also affect the VEC

See response to Part 1 in reference to Step 4.

• the total (overall) cumulative effect from present condition to predicted future conditions. Total cumulative effects assessment will be characterized using well defined criteria and include a discussion on how the residual effects of some VECs can cumulatively add up to have a greater cumulative effect on other VECs

See response to Part 1 in reference to Step 6.

3. Provide a cumulative effects assessment for land and resource use that includes:

a) a map of the RSA for land and resource use (SSA + 35 km buffer) that shows all the past, current and future foreseeable projects and activities.

An updated version of Figure 6.6-1 from the EIS Addendum is provided as Figure 1 (Attachment B), which provides a map of the land and resource use RSA (SSA +35 km buffer) showing all past, current and future foreseeable projects and activities that have been identified.

b) a map that includes current and future disturbances in the RSA due to timber harvesting and associated road networks.

A map showing the current and future disturbances associated with timber harvesting within the land and resource use RSA (SSA +35 km buffer) is provided in Figure 2 and 3 (Attachment B). Past and planned disturbances due to timber harvesting include areas that have been / will be disturbed by tree clearing activities and the existing / planned roads necessary to access such areas, based on information obtained from the Forest Management Plans for the Pic River Forest and White River Forest. The information provided on Figure 2 and 3 is similar, with Figure 2 (Attachment B) being provided on a topographic base map and Figure 3 (Attachment B) overlaying similar information onto a satellite imagery base map.

All forestry operations data (i.e., Depletion Areas, Planned Harvest Areas, Existing and Planned Roads) were provided with permission of the two crown corporations for whom the Forest Management Plans for the Pic and White River forests and to the proponent’s understanding consistent with the data presented in the current Forest Management Plans.

c) the total amount of area currently disturbed in the RSA due to timber harvesting.

Based on the information from the Forest Management plans, Table 1 provides an indication of the amount of area currently disturbed in the RSA due to timber harvesting, as well as the area associated

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with future disturbances in the RSA due to timber harvesting and associated road networks as proposed in the latest version of the Forest Management Plan.

Table 1 Timber Harvest Disturbances within the RSA for Land and Resource Use

Disturbance within the LRU RSA Area (ha) % of RSA* Area currently disturbed in the RSA due to timber harvesting 7,032 ha 2.0% Area planned to be disturbed in the RSA due to timber harvesting 43,597 ha 12.6% Combined current and planned timber harvest disturbance in the RSA 50,629 ha 14.6% Planned disturbance within the SSA 1,116 ha 0.3% * The land area of the RSA for Land and Resource Use (excluding Lake Superior and its islands) is approximately 345,697 ha.

The extent of areas disturbed by tree harvesting (i.e., Depletion Areas and Planned Harvest Areas) is based on measurements using GIS layers provided. For the purposes of estimating the extent of road network disturbances, footprint effects were calculated assuming road widths of 30 m for Primary Roads, 20 m for Branch Roads and 15 m for Operations Roads.

References

Canadian Environmental Assessment Agency. 2015. Operational Policy Statement: Assessing Cumulative Environmental Effects under the Canadian Environmental Assessment Act, 2012, March 2015.

Canadian Environmental Assessment Agency. 2018. Assessing Cumulative Environmental Effects under the Canadian Environmental Assessment Act, 2012, Interim Technical Guidance, March 2018, Version 2.

List of Attachments

Attachment A: Projects and Activities and the Association to the Cumulative Effects Assessment Attachment B: Figures

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ATTACHMENT A: PROJECTS AND ACTIVITIES AND THE ASSOCIATION TO THE CUMULATIVE EFFECTS ASSESSMENT

Attachment A: Projects and Activities and the Association to the Cumulative Effects Assessment

Project Description Consideration in the Cumulative Effects Assessment (CEA) Past and Existing Projects / Activities Major Settlements and Within the combined Project components RSAs, there are several Major settlements and communities as listed are well established in the region. Communities larger and smaller communities, typically proximate to the local highway Each is associated with some level of “land disturbance” and their presence in the regionally landscape has historical relevance. network. The larger communities include White River, Marathon, Terrace Bay and Schreiber along Highway 17 and Manitouwadge along The level of disturbance was implicitly considered in the CEA – as stated in Section 6.6.5 of the CEA, “The effects of past and present projects contribute to Hwy 614. Indigenous communities include Netmizaaggamig baseline conditions upon which Project effects are assessed. As such, the cumulative effects of these past and present projects and physical activities are Nishnaabeg (Pic Mobert First Nation), Biigtigong Nishnaabeg (BN), inherently considered, as relevant and appropriate, in the assessment of Project effects presented in Section 6.2 of this EIS Addendum (Vol 2). As such, the Pays Plat First Nation/Pawgwasheeng First Nation, and Michipicoten cumulative effects assessment largely focusses on the potential for the residual effects of the Project to act in combination with the residual effects of future First Nation. projects and activities.” In consideration of the above, no interactions were envisioned for the biophysical VECs. Interactions with respect to the VECs “socio-economic environment” and “indigenous considerations” were identified. As it concerns the “socio-economic environment” VEC, major settlements and communities that occur within 100 km of the SSA were considered in recognition of existing centres where people live and work, contributing to the economy, establishing infrastructure, and drawing on services, land and resources uses. As it concerns the “indigenous considerations” VEC, effects of these past and existing projects and activities have altered the landscape of the area and have influenced the environmental characteristics reflected in the baseline conditions. BN have identified additional mitigation measures that they propose are required from the federal and provincial governments to address existing conditions and historical effects on Indigenous communities. Protected Areas and Parks There are national and provincial parks in the combined Project VEC National and provincial parks, as well as other protected areas (conservation reserves) as listed are well established in the region. RSAs, as well as protected areas. Federal parks include Pukaskwa Each is associated with some level of “land disturbance” and their presence in the regionally landscape has historical relevance National Park and the Lake Superior National Marine Conservation Area. Provincial Parks include Steel River, Slate Islands, Prairie River The level of disturbance was implicitly considered in the CEA – as stated in Section 6.6.5 of the CEA, “The effects of past and present projects contribute to Mouth, Neys, Red Sucker Point, Pan Lake Fen, Craig’s Pit, White Lake, baseline conditions upon which Project effects are assessed. As such, the cumulative effects of these past and present projects and physical activities are White Lake Peatlands, Pokei Lake/White River Wetlands, Nagagamisis, inherently considered, as relevant and appropriate, in the assessment of Project effects presented in Section 6.2 of this EIS Addendum (Vol 2). As such, the Pukaskwa River, Obatanga, Nimoosh, Michipicoten, Lake Superior, and cumulative effects assessment largely focusses on the potential for the residual effects of the Project to act in combination with the residual effects of future Michipicoten Island. Provincial Conservation Reserves include Gravel projects and activities.” River, Three Mile Narrows, Long Lake, Fishnet Lake, Lake Superior In consideration of the above, no interactions were envisioned for the biophysical VECs. North Shore, Killala Lake, Isko Dewabo Lake Complex, Kwinkwaga Interactions with respect to the VECs “socio-economic environment” and “indigenous considerations” were identified. Ground Moraine Uplands, Widgeon Lake Moraine, Kakakiwibik Esker, As it concerns the “socio-economic environment” VEC, these areas were implicitly considered in the CEA. The establishment of Protected Areas and Parks Strickland River Mixed Forest Wetland, Magpie River Terraces, and are largely administrative boundaries that influence land and resource uses, by restricting certain activities (i.e., forestry, development) and encouraging South Michipicoten River Superior Shoreline Conservation Reserve. others (i.e., recreation). The establishment of these areas focus mainly on maintaining areas within a natural state. These areas provide the opportunity for outdoor recreation (i.e., positive effect) through the provision of services and access, thereby contributing the baseline conditions. As it concerns the “indigenous considerations” VEC, effects of these past and existing projects and activities have altered the landscape of the area and have influenced the environmental characteristics reflected in the baseline conditions. Major Transportation Networks Highway 17 traverses the southern extent of the combined Project VEC The local and regional transportation networks and hubs as identified are well established in the region. and Hubs RSAs generally following the Lake Superior shoreline. Highway 11 is Each is associated with some level of “land disturbance” and their presence in the regionally landscape has historical relevance located within the northern extent of the combined Project VEC RSAs. Highway 614 extends north from Highway 17 east of White River to The level of disturbance was implicitly considered in the CEA – as stated in Section 6.6.5 of the CEA, “The effects of past and present projects contribute to baseline conditions upon which Project effects are assessed. As such, the cumulative effects of these past and present projects and physical activities are Manitouwadge. inherently considered, as relevant and appropriate, in the assessment of Project effects presented in Section 6.2 of this EIS Addendum (Vol 2). As such, the The CP corridor extends through the combined Project VEC RSAs cumulative effects assessment largely focusses on the potential for the residual effects of the Project to act in combination with the residual effects of future following Highway 17 and the Lake Superior Shoreline. projects and activities.” Regional airports that are no longer serviced by regularly scheduled In consideration of the above, no interactions were envisioned for the biophysical VECs. flights are found in Marathon, Manitouwadge and Terrace Bay. Interactions with respect to the VECs “socio-economic environment” and “indigenous considerations” were identified. As it concerns the “socio-economic environment” VEC, these facilities were implicitly considered in the CEA. Existing transportation facilities (i.e., roads, railways) establish the infrastructure to be used by project. Existing use of these facilities (i.e., access, traffic) are considered in conjunction with the planned movement of goods and people to and from the Project during all phases of the project. As it concerns the “indigenous considerations” VEC, effects of these past and existing projects and activities have altered the landscape of the area and have influenced the environmental characteristics reflected in the baseline conditions.

1 of 7 Attachment A: Projects and Activities and the Association to the Cumulative Effects Assessment

Project Description Consideration in the Cumulative Effects Assessment (CEA) Major Commercial / Industrial Commercial / industrial interests that are not specifically identified The identified enterprises are associated with some level of “land disturbance” and their presence in the regionally landscape has historical relevance. The Enterprises include the former Pulp and Paper Mill in Marathon (Marathon Pulp) level of disturbance was implicitly considered in the CEA – as stated in Section 6.6.5 of the CEA, “The effects of past and present projects contribute to that closed several years ago with the property now in the ownership of baseline conditions upon which Project effects are assessed. As such, the cumulative effects of these past and present projects and physical activities are the Town of Marathon. inherently considered, as relevant and appropriate, in the assessment of Project effects presented in Section 6.2 of this EIS Addendum (Vol 2). As such, the The Geco and Willroy mines are former base metal mines located just cumulative effects assessment largely focusses on the potential for the residual effects of the Project to act in combination with the residual effects of future north of Manitouwadge. No mining occurs but the sites remain in long- projects and activities.” Moreover, the locations of these enterprises do not spatially overlap with potential relevant VEC-specific RSAs. In consideration of term care and maintenance. the above, no interactions were envisioned for the biophysical VECs. The former Winston Lake Mine is located north of Schreiber and may Interactions with respect to the VECs “socio-economic environment” and “indigenous considerations” were identified. be subject to redevelopment (see below). As it concerns the “socio-economic environment” VEC, these commercial and industrial enterprises (i.e., businesses) were implicitly considered in the CEA. There are dozens of small aggregate pits (mostly inactive) in the They contribute to the past and existing economy and labour market in the RSA. These businesses and workers also draw on and contribute to services in combined Project VEC RSAs. the various communities. Relatively large areas of the combined Project VEC RSAs would have As it concerns the “indigenous considerations” VEC, effects of these past and existing projects and activities have altered the landscape of the area and been subject to past mining claims and, as described below, there are have influenced the environmental characteristics reflected in the baseline conditions. dozens of mineral exploration permits for the area. General Recreational and Land This would include general land and resource pursuits such as From the perspective of past and existing activities in the RSA and how they may interact with the Marathon Project, such activities, are of low intensity from Use Activities recreation and tourism (including recreational fisheries) and non- a disturbance point of view and considered de minimis on the landscape scale. As such, no interactions were envisioned for the biophysical VECs. This commercial forestry. does not diminish the importance of such activities to those land and resource users; rather, this characterization is specific to the past and ongoing impact such activities have had / or likely to have within the context of the CEA associated with the Marathon Project. The EIS does consider the cumulative effects on such activities from the “socio-economic environment” and “indigenous considerations” VECs, though the focus of the analysis is associated with the potential cumulative effects of the project with other activities on land and resource uses. As stated above, the land and resource uses envisioned are expected to be of such low intensity, as not to in and of themselves contribute to cumulative effects. Indigenous Land and Resource This would include traditional land and resource pursuits, including the From the perspective of past and existing activities in the RSA and how they may interact with the Marathon Project, such activities, are of low intensity from Use Activities collection of country foods and the Indigenous fishery. This includes a disturbance point of view and considered de minimis on the landscape scale. As such, no interactions were envisioned for the biophysical VECs. This traplines managed by individuals and Indigenous communities. does not diminish the importance of such activities to those traditional land and resource users; rather, this characterization is specific to the past and ongoing impact such activities have had / or likely to have within the context of the CEA associated with the Marathon Project. The EIS does consider the cumulative effects on such activities from the “socio-economic environment” and “indigenous considerations” VECs, though the focus of the analysis is associated with the potential cumulative effects of the project with other activities on traditional land and resource uses. As stated above, the traditional land and resource uses envisioned are expected to be of such low intensity, as not to in and of themselves contribute to cumulative effects. Hemlo Gold Mine Camp The Hemlo Gold Mine Camp comprises three mine properties: the The Hemlo Gold Mine Camp is of particular interest locally/regionally as it would likely be considered one of, if not the most significant mining project in the Golden Giant Mine, the David Bell Mine, and the Williams Mine are area. Past issues have been documented on the environmental performance of the mines that make up the Hemlo Camp, though active reclamation is located approximately 30 km southeast of the SSA. The Williams Mine ongoing and only one of the mines is in operation. The project-interaction matrix (Table 6.6-3) did not identify specific interactions with biophysical VECs, but is currently an underground mining operation only. Treated surface acknowledged interactions with the “socio-economic” and “indigenous considerations” VECs. No interactions were identified for the biophysical VECs, since, water discharge enters the Black River, a tributary of the Pic River, and as described above, effects (such as for example, effects related to land disturbance) were inherently recognized in the assessment of Project-specific enters the Pic River approximately 18 km downstream of the SSA. effects. Moreover, though as identified in Table 6.6.2, there is treated effluent discharge to the Black River, a Pic River tributary, it is well downstream of the Marathon project and no spatial overlap will occur that would necessitate the consideration of cumulative effects from a water quality (and related) perspective. Harte Gold Sugar Zone Mine The Sugar Zone Mine entered commercial production in 2019 and has The Harte Gold Sugar Zone Mine is well outside the boundary of any of the biophysical environment VEC-specific RSAs and therefore not considered within an anticipated mine life of approximately 13 years at current production the CEA for these VECs. levels. The mine is located 30 km northeast of White River. Interactions with respect to the VECs “socio-economic environment” and “indigenous considerations” were identified. As it concerns the “socio-economic environment” VEC, this mining project was considered in the CEA as it employs trained workers in the RSA and will ultimately compete with GenPGM for resourcing / employment opportunities. As it concerns the “indigenous considerations” VEC, this project has altered the landscape of the area and has influenced the environmental characteristics reflected in the baseline conditions. Wesdome Gold Mines Ltd. Wesdome’s Eagle River Complex is located ~100 km southeast of The Eagle River Complex is well outside the boundary of any of the biophysical environment VEC-specific RSAs and therefore not considered within the Marathon. It consists of two operating gold mines which have been CEA for these VECs. developed using common infrastructure and feeding the same mill. The Interactions with respect to the VECs “socio-economic environment” and “indigenous considerations” were identified. As it concerns the “socio-economic complex includes the Eagle River Underground Mine (producing since environment” VEC, this mining project was considered in the CEA as it employs trained workers in the RSA and will ultimately compete with GenPGM for 1995) and the Mishi Open Pit Mine (started production in 2002). resourcing / employment opportunities. As it concerns the “indigenous considerations” VEC, this project has altered the landscape of the area and has influenced the environmental characteristics reflected in the baseline conditions.

2 of 7 Attachment A: Projects and Activities and the Association to the Cumulative Effects Assessment

Project Description Consideration in the Cumulative Effects Assessment (CEA) Peninsula Harbour Sediment The Peninsula Harbour Sediment Remediation Project at Jellicoe Cove A potential interaction between the Marathon Project and the Peninsula Harbour Sediment Remediation Project and the “atmospheric environment” VEC was Remediation Project at Jellicoe was conducted in the summer of 2013. The remediation project identified, as well as “socio-economic environment” and “indigenous considerations” VECs. The Peninsula Harbour Sediment Remediation Project was Cove, Peninsula Harbour Area of included covering contaminated sediments with 15 to 20 cm of clean specifically mentioned in Section 6.6.6.1 (Atmospheric Environment) of the CEA; however, there was implicit recognition that no actual spatial overlap as it Concern sand over a total area of 25.6 ha. Monitoring for cap effectiveness will concerns the potential interaction was present. The text indicates “ … project-related incremental increases in constituent levels in air are noted, air quality take place periodically over approximately 20 years. The Peninsula assessment benchmarks are not exceeded at the LSA boundary.”. Since there is no spatial overlap between the residual project-specific effect and the Harbour remains classified as an Area of Concern (AOC). atmospheric environment RSA there can be no cumulative effect. As it concerns the “indigenous considerations” VEC, this project has altered the landscape of the area and has influenced the environmental characteristics reflected in the baseline conditions. This project improved upon environmental conditions in the harbour as a means to remediate past effects from previous activities that altered sediment and water quality. Lastly, though not specific to this current IR, previously questions had been raised about potential cumulative effects between the Project and the Peninsula Harbour Sediment Remediation Project as it pertains to water quality – that is, did project-specific residual effects interact with the remediated sediments within the harbour. There is no spatial overlap with respect to water quality between the Marathon Project and the Peninsula Harbour Sediment Remediation Project – project-specific effects do not extend to the RSA. Jackfish Bay Area of Concern Jackfish Bay was designated an Area of Concern (AOC) because a The Jackfish Bay was designated an Area of Concern (AOC) is outside the boundary of any of the biophysical environment VEC-specific RSAs and therefore review of available data indicated that water quality and environmental not considered within the CEA for these VECs. health were severely degraded. Effluents from the pulp and paper mill Interactions with respect to the VECs “socio-economic environment” and “indigenous considerations” were identified. in Terrace Bay, which began operations in 1948, resulted in poor water quality, contamination of sediment, and fish and fish habitat destruction, As it concerns the “indigenous considerations” VEC, this project has altered the landscape of the area and has influenced the environmental characteristics along with impairment of populations of sediment-dwelling organisms in reflected in the baseline conditions. This project improved upon environmental conditions in the harbour as a means to remediate past effects from previous Jackfish Bay on Lake Superior. A natural recovery plan and long-term activities that altered water quality from previous pulp and paper mill operations. monitoring are in place for the Jackfish Bay AOC in Recovery. While the environment has improved significantly, more time is needed to continue natural recovery. BN Hydroelectric Facilities Currently, BN owns and operates three hydroelectric facilities: Umbata No interactions between these hydroelectric facilities and the biophysical VECs were identified, since the facilities are well outside VEC-specific RSAs (e.g., (Umbata Falls, Twin Falls, Falls, Twin Falls, and Wawatay Falls. Umbata Falls, a 23 MW facility, atmospheric environment, acoustic environment), are not associated with non-mitigatable effects (e.g., fish and fish habitat) and where spatial overlap exists Wawatay Falls) was commissioned in early November 2008, and is located on the have disturbance footprints that are small in magnitude and considered within the overall assessment of existing conditions and therefore have been White River, approximately 30 km southeast of the Marathon Palladium considered within the context of project-specific effects. Project site. Twin Falls, a 4.9 MW facility, was commissioned in 2000, Interactions with respect to the VECs “socio-economic environment” and “indigenous considerations” were identified. but BN did not assume full ownership of the facility until 2009. Twin Falls is located on the Kagiano River, approximately 50 km north of the As it concerns the “socio-economic environment” VEC, these facilities were implicitly considered in the CEA. These facilities employ workers in the area and SSA. Wawatay, a 13.5 MW facility, was commissioned in 1992, and is have influenced land and resource uses in the RSA. located on the Black River, approximately 65 km north of the SSA. As it concerns the “indigenous considerations” VEC, this project has altered the landscape of the area and has influenced the environmental characteristics reflected in the baseline conditions. Highway 17 Improvements According to the MTO, the following activities are underway/planned on Though identified as projects/activities of potential interest that fall within VEC specific RSAs, such activities as proposed are of such a localized nature there Highway 17 between White River and Terrace Bay over the next two were no specific project interactions that were identified for consideration within the CEA. Execution of these projects/activities is not likely associated with years: effects on VECs that would alter conditions with the VEC specific RSAs that they warrant specific inclusion in the CEA. Moreover, given the proposed time- • Resurfacing – Approximately 78 km of shoulder paving between frame of these projects/activities there is limited likely temporal overlap with the Marathon Project. Marathon and Terrace Bay; Approximately 21 km of shoulder paving west of White River. • Bridge Rehabilitation – Bertrand Creek Bridge, West White River Bridge, White Lake Narrows Bridge, Wabikoba Creek Bridge, Little Pic River Bridge, Aguassabon River Bridge • Bridge Replacement – White River Bridge • Culvert Rehabilitation – McKellar and Ripple Creeks • Culvert Replacement – Hare Creek, Mink Creek In addition, the Pic River bridge over Highway 627 will be replaced.

3 of 7 Attachment A: Projects and Activities and the Association to the Cumulative Effects Assessment

Project Description Consideration in the Cumulative Effects Assessment (CEA) Pic Mobert Hydroelectric Facility PMFN is involved in hydroelectric generation with Regional Power Inc., No interactions between these hydroelectric facilities and the biophysical VECs were identified, since the facilities are well outside VEC-specific RSAs (e.g., specifically the Gitchi Animki (Big Thunder) Hydroelectric Project atmospheric environment, acoustic environment), are not associated with non-mitigatable effects (e.g., fish and fish habitat) and where spatial overlap exists located on the White River approximately 50 km south of the Town of have disturbance footprints that are small in magnitude and considered within the overall assessment of existing conditions and therefore have been White River. The project consists of two developments located on the considered within the context of project-specific effects. White River: Gitchi Animki Bezhig (Upper Site), an 8.9 MW site; and Interactions with respect to the VECs “socio-economic environment” and “indigenous considerations” were identified. Gitchi Animki Niizh (Lower Site), a10 MW site located approximately 16 km south of the Gitchi Animki Bezhig. The facilities were opened in As it concerns the “socio-economic environment” VEC, these facilities were implicitly considered in the CEA. These facilities employ workers in the area and 2016. have influenced land and resource uses in the RSA. As it concerns the “indigenous considerations” VEC, this project has altered the landscape of the area and has influenced the environmental characteristics reflected in the baseline conditions. Timber Harvesting The SSA is located within the Pic River FMU; however, a number of Timber harvesting, as a past, present and future activity was considered explicitly throughout the CEA, particular, though not exclusively, as it related to the additional FMUs are located within the RSA. These include the “vegetation”, “wildlife”, “SAR”, “socio-economic” and “indigenous considerations” VECs. Kenogami Forest and the White River Forest. Combined, hundreds of Further information, as requested by the Panel, regarding timber harvesting and land and resource uses has been provided in response to IR 3-3, part C, thousands of hectares of forest would have been subject to timber and is presented herein. harvesting and re-planting activities within these FMUs in the past. The total area of the Pic River FMU is ~1.1 million ha; approximately 17,514 ha of forest is scheduled to be harvested in the Pic Forest FMU in 2020-2021 and the planned harvest from 2021 to 2031 is on the order of 100,000 ha. The total area of the Kenogami Forest is 1,977,684 ha, and the planned harvest from 2011 to 2021 is ~150,00 ha, with ~ 75,000 ha of regeneration planned. The Kenogami Forest is located north and west of the Project site. The White River Forest is located southeast and east of Marathon and the Pic Forest. The planned harvest from 2018 to 2028 is ~62,00 ha, with ~ 18,500 ha of regeneration planned. It is noted that coincident with timber harvesting activities under the appropriate FMUs, an extensive network of forestry roads has been developed. Bell Communication Towers There are as many as 22 cellular towers located along the corridor, and Potential project interactions were identified for the “vegetation”, “wildlife” and “SAR” VECs, as well as for the “socio-economic environment” and “indigenous in the communities along the corridor between White River and Terrace considerations” VECs. Bay. No explicit consideration of this project/activity was provided in the CEA, however the following is noted: o The level of disturbance associated with this project/activity is de minimis within the context of the VEC-specific RSAs for “vegetation”, “wildlife” and “SAR” and in this context the level of disturbance was implicitly considered in the CEA. As stated in Section 6.6.5 of the CEA, “The effects of past and present projects contribute to baseline conditions upon which Project effects are assessed. As such, the cumulative effects of these past and present projects and physical activities are inherently considered, as relevant and appropriate, in the assessment of Project effects presented in Section 6.2 of this EIS Addendum (Vol 2). As such, the cumulative effects assessment largely focusses on the potential for the residual effects of the Project to act in combination with the residual effects of future projects and activities.” o As it concerns the “indigenous considerations” VEC, these projects have altered the landscape of the area and has influenced the environmental characteristics reflected in the baseline conditions. AV Terrace Bay Inc. In July 2012, the Aditya Birla Group purchased the former Terrace Bay This project was identified with having potential interactions with the Marathon project from a CEA perspective for the “vegetation”, “wildlife”, “SAR” and Pulp Mill and restored pulp mill production in the late fall of 2012. The “indigenous considerations” VECs. No other potential interactions were identified largely because of a lack of spatial overlap with the VEC-specific RSAs – pulp mill is located in Terrace Bay approximately 100 km west of the the mill is some 100 km west of the project site. SSA. The pulp mill operates as AV Terrace Bay Inc., producing For the aforementioned biophysical environment VECs it is noted that no explicit consideration of this project/activity was provided in the CEA, however the dissolving pulp. Treated effluent from the mill discharges to Blackbird level of disturbance associated with this project/activity was implicitly considered in the CEA. As stated in Section 6.6.5 of the CEA, “The effects of past and Creek that enters Lake Superior in Jackfish Bay (identified as an AOC present projects contribute to baseline conditions upon which Project effects are assessed. As such, the cumulative effects of these past and present above). projects and physical activities are inherently considered, as relevant and appropriate, in the assessment of Project effects presented in Section 6.2 of this EIS Addendum (Vol 2). As such, the cumulative effects assessment largely focusses on the potential for the residual effects of the Project to act in combination with the residual effects of future projects and activities.” As it concerns the “socio-economic environment” VEC, this facility was implicitly considered in the CEA. This project (i.e., business) contributes to the past and existing economy and labour market in the RSA. This business and workers also draw on and contribute to services in the community. As it concerns the “indigenous considerations” VEC, this project has altered the landscape of the area and has influenced the environmental characteristics reflected in the baseline conditions.

4 of 7 Attachment A: Projects and Activities and the Association to the Cumulative Effects Assessment

Project Description Consideration in the Cumulative Effects Assessment (CEA) East-West Tie Transmission Line The East-West Tie transmission project is a 450 km double-circuit 230 The East-West Tie Transmission Line Expansion project is associated with a disturbance corridor that is on the order of 450 km in length and 70 m wide. Expansion kV transmission line connecting the Lakehead Transformer Station in The corridor is largely associated with the expansion of existing disturbed areas. Most of the corridor falls outside the VEC-specific RSAs defined for the the Municipality of Shuniah near the City of Thunder Bay to the Wawa environmental assessment, though there is some spatial overlap. The construction of the East-West Tie Transmission Line Expansion project will be Transfer Station located east of the Municipality of Wawa. It will also completed by the first quarter of 2022 and is unlikely to temporally overlap with the Marathon project in that respect. Potential land disturbance and connect to the Marathon Transformer Station. Construction of the associated effects, including those associated with the East-West Tie Transmission Line Expansion project, were considered within the context of the project began in September 2019 and is expected to be complete by assessment of Project effects presented in Section 6.2 of EIS Addendum Volume 2 as they were assumed to be already part of the existing landscape. the end of the first quarter of 2022. The right-of-way is on the order of 70 m wide. Town of Marathon Landfill A new regional landfill was commissioned in 2015 by the Town of This project was identified with having potential interactions with the Marathon project from a CEA perspective for the “atmospheric environment”, “acoustic Marathon on the site of a closed pulp mill landfill along the Camp 19 environment”, “water quality and quantity”, “vegetation”, “wildlife”, “SAR” and “indigenous considerations” VECs. Road, about 1 km east of the Highway 17 intersection. The site has Consideration of cumulative effects for the “atmospheric environment”, “acoustic environment” VECs were explicitly incorporated in the project-specific projected capacity for more than 100 years of waste disposal. effects analysis – that is, emissions associated with the landfill were inherently incorporated into the existing conditions onto which Marathon project emissions were layered in the predictive modeling assessment. Given that this assessment showed no project-related benchmarks are not exceeded at the LSA boundary it can be concluded that there are no cumulative effects. With respect to surface water quality/quantity there is no spatial overlap between the Marathon project residual effect and landfill and therefore no cumulative effect. Similarly, no spatial overlap was identified between the Marathon project residual effect and landfill for groundwater VEC indicators. As it concerns the “indigenous considerations” VEC, this project has altered the landscape of the area and has influenced the environmental characteristics reflected in the baseline conditions. Town of Marathon Waste The Waste Transfer Station is the site of the former town landfill, Consideration of cumulative effects for the “atmospheric environment”, “acoustic environment” VECs were explicitly incorporated in the project-specific Transfer Station located within the town limits on Penn Lake Road. The landfill was effects analysis – that is, emissions associated with the transfer station were inherently incorporated into the existing conditions onto which Marathon project closed in 2015. emissions were layered in the predictive modeling assessment. Given that this assessment showed no project-related benchmarks are not exceeded at the LSA boundary it can be concluded that there are no cumulative effects. With respect to surface water quality/quantity there is no spatial overlap between the Marathon project residual effect and transfer station and therefore no cumulative effect. Similarly, no spatial overlap was identified between the Marathon project residual effect and transfer for groundwater VEC indicators. As it concerns the “indigenous considerations” VEC, this project has altered the landscape of the area and has influenced the environmental characteristics reflected in the baseline conditions. Future (Certain and Reasonably Foreseeable) Projects/Activities BN Community Water System A Feasibility Study (July 2019) for a water system upgrade for BN has Per the interaction matrix no interactions with biophysical VECs were identified for this project/activity. This project/activity was deemed to be well outside Upgrade been completed. The federal and provincial governments have the potential zone of influence of the Marathon Project (i.e., no spatial overlap – e.g., atmospheric environment, acoustic environment, water quality and announced funding to support the initiative (December 2020). The quantity) and was of such minor relative disturbance intensity and footprint that no interactions with other VECs of this sort warranted further consideration Feasibility Study recommended the following: within the CEA. • an infiltration gallery along the shores of Lake Superior as the new The interaction matrix identified potential interactions with the “socio-economic environment” and “indigenous considerations” VECs, explicitly and implicitly water supply source, a water transmission line to connect the water • Explicit consideration of this project/activity within the context of the “socio-economic environment” VEC is seen with reference to economy and source to the plant, a new water treatment plant with conventional employment (Section 6.6.6.9.1) and infrastructure and services (6.6.6.9.2). Though no direct specific mention of this project/activity was made in regard filtration, both UV and chlorination as primary disinfection, a new to land and resource use (Section 6.6.6.9.3) and human health the text of the CEA does implicitly indicate that the other projects in the PIL (and below-grade reservoir under the new water treatment plant, therefore including this one) are not expected to act in a cumulative way with the Marathon project for those indicators that fall within the “socio- extension of existing water distribution system to new development economic environment” VEC. for the Holistic Healing Centre, replacing high lift pumps and • installing appropriate disinfection system. Once implemented, the Explicit consideration of this project/activity within the context of the “indigenous considerations” VEC is seen with reference to change to traditional land new water system will meet the requirements for drinking water and resource use (Section 6.6.6.11.1), and was considered in more general implicit terms for the other “indigenous considerations” VEC indicators systems in Ontario and will provide a multi-barrier approach, as (change to indigenous heritage and archaeological resources, change to indigenous health) that were part of the evaluation given that it was stated that required by the Ontario SDWA and in guidance with the Ten State the other projects in the PIL (and therefore including this one) are not expected to act in a cumulative way with the Marathon project. Standards, 2012, including fire protection; and meet all current and • It is noted that notwithstanding the discussion/evaluation of cumulative effects as reiterated briefly above the CEA does acknowledge the concerns future water demands with a 20-year planning period. The new expressed by local indigenous communities with the adverse effects of past and present projects and activities within their traditional territories and the WTP will be built out of the Regional Flood Zone. implication on their interests and rights (see Section 6.6.6.11.4). • This project is viewed by BN as an additional mitigation measure required from the federal and provincial governments to address existing conditions and historical effects on Indigenous communities.

5 of 7 Attachment A: Projects and Activities and the Association to the Cumulative Effects Assessment

Project Description Consideration in the Cumulative Effects Assessment (CEA) Magino Gold Project Prodigy Gold Incorporated, a wholly-owned subsidiary of Argonaut Gold Per the interaction matrix, potential interactions with the “vegetation”, “wildlife”, “SAR”, “socio-economic environment” and “indigenous considerations” VECs Incorporated, is undertaking the construction, operation, were identified for this project/activity. This CEA did not consider this project/activity within the context of other biophysical VECs at this level as there was decommissioning and abandonment of an open-pit gold mine and metal clear no spatial overlap between the Marathon project and the Magino Gold Project for the RSAs associated with those VECs. mill at the site of a former underground mine located 14 km southeast Further to the above, the CEA text clarified that the Magino Gold Project is outside the “vegetation” VEC RSAs, explicitly for the forest and non-forest cover of Dubreuilville, Ontario, about 145 km southeast of the SSA. Mining components. Though not explicitly stated this extends the other vegetation indicators (rare plants, plants species of interest to indigenous communities). will occur over 10 years with an ore production capacity of 45,200 Similarly, the CEA text also clarified that the Magino Gold Project is outside the “wildlife” “SAR” and “socio-economic environment” VEC RSAs. Consistent tonnes per day. The on-site metal mill will have an ore input capacity of with the CEA methodology employed, no further consideration of the Magino Gold Project was made for these VECs. 35,000 tonnes per day and will operate for approximately 12 to 15 years. Construction (tree clearing) has commenced, consistent with a As it concerns the “indigenous considerations” VEC, this project was implicitly considered in the CEA. It is planned to alter the landscape of the area and will influence the environmental characteristics within the RSA. It is anticipated that this project will implement appropriate mitigation measures to avoid or reduce recent press release indicating construction would begin early in 2021. potential environmental effects that may alter existing conditions. However, the presence of this project and associated disturbance to the existing landscape is located within the traditional territories of Indigenous peoples. Mineral Exploration There are several dozens of mining exploration permits that have been The interaction matrix does not specifically identify interactions between mineral exploration activities and Project VECs, with the exception of the granted within a 100 km radius of the SSA, which may give rise to “indigenous interests” VEC, though the text of the CEA does provide context to the potential cumulative effects of these activities. As it concerns the exploration activities in the next 5 to 10 years. Of note, Rudolph Wahl “indigenous considerations” VEC, this project is planned to alter the landscape of the area and will influence the environmental characteristics within the Exploration has numerous sites in relatively close proximity to the SSA. RSA. It is anticipated that this project will implement appropriate mitigation measures to avoid or reduce potential environmental effects that may alter GenPGM is engaged in exploration activities north and west of the existing conditions. However, the presence of this project and associated disturbance to the existing landscape is located within the traditional territories of SSA. Indigenous peoples. The Ontario Mining Association cites one property in the advanced This project/activity was deemed to be well outside the potential zone of influence of the Marathon Project (i.e., no spatial overlap) as it concerns the exploration stage: “atmospheric environment”, “acoustic environment” and “water quality and quantity” VECs. • Superior Lake Resources’ Superior Lake Zinc Project is located at Acknowledgement of the potential for interaction with the “fish and fish habitat”, “vegetation”, “wildlife” and “SAR” VECs was given in the text in association the historic Winston Lake site ~ 75 km northwest of Marathon. with land/habitat disturbance; however, given the minor relative disturbance intensity and footprint that are likely to be associated with such activities no further consideration within the CEA was deemed necessary. The distribution of mining claims by the Crown does not represent a project/activity in and of itself that would be consider relevant from the perspective of most VECs, since the distribution of mining claims does not equate to activity on the mining claim. The potential for mineral exploration activities to interact with land and resource uses (indigenous and non-indigenous) was acknowledge in the CEA.

BN Hydroelectric Facilities BN is proposing to construct hydroelectric facilities at Manitou Falls and These projects/activities were identified with having potential interactions with the Marathon project from a CEA perspective for the “vegetation”, “wildlife”, High Falls, located on the Pic River approximately 70 and 85 km “SAR” and “indigenous considerations” VECs. No other potential interactions were identified largely because of a lack of spatial overlap with the VEC- upstream from Lake Superior (50 and 65 km north of the SSA), specific RSAs. respectively. The facility at Manitou Falls would have a generating For the aforementioned biophysical environment VECs, potential cumulative effects were acknowledged in relation to land disturbance from both direct and capacity of 2.8 MW and would consist of an overflow weir with an intake indirect effects perspective. canal leading to the powerhouse, located on the east side of the river, adjacent to the downstream end of the falls. The facility at High Falls As it concerns the “indigenous considerations” VEC, this project is planned to alter the landscape of the area and will influence the environmental would have a generating capacity of 3.2 MW and would consist of a characteristics within the RSA. It is anticipated that this project will implement appropriate mitigation measures to avoid or reduce potential environmental short overflow weir with two sluices and an adjacent intake structure at effects that may alter existing conditions. However, the presence of this project and associated disturbance to the existing landscape is located within the the head of the falls, with a penstock leading to the powerhouse at the traditional territories of Indigenous peoples. base of the falls. The facilities will convey power from their switchyards to an interconnection point on the existing 48-kV distribution line running from the Twin Falls GS on the Kagiano River south of the proposed facilities. BN is proposing to construct a hydroelectric facility at the Aguasabon River, approximately 16 km north of Terrace Bay. It is a joint venture partnership with the Pays Plat First Nation and contemplates construction of a 10 MW run-of-river hydroelectric facility. Chigamiwinigum Falls is on the White River within Parks Canada's Pukaskwa National Park. A concept for a 20-30 MW facility has been developed. BN has not secured the rights to develop the site at this time.

6 of 7 Attachment A: Projects and Activities and the Association to the Cumulative Effects Assessment

Project Description Consideration in the Cumulative Effects Assessment (CEA) BN Wind Energy Projects The Superior Shores Wind Farm is a joint venture between BN and These projects/activities were identified with having potential interactions with the Marathon project from a CEA perspective for the “vegetation”, “wildlife”, Innergex of Quebec. This 24 MW wind energy project would be located “SAR” and “indigenous considerations” VECs. No other potential interactions were identified largely because of a lack of spatial overlap with the VEC- approximately 12 km southeast of the SSA. specific RSAs. Coldwell Wind Farm is a joint project between the Pic River First Nation For the aforementioned biophysical environment VECs, potential cumulative effects were acknowledged in relation to land disturbance from both direct and and Brookfield Power. Approval to build the Coldwell Wind Energy indirect effects perspective. Project has been granted. The project is situated approximately 20 km As it concerns the “indigenous considerations” VEC, this project is planned to alter the landscape of the area and will influence the environmental northwest of Marathon. The wind energy project as described would characteristics within the RSA. It is anticipated that this project will implement appropriate mitigation measures to avoid or reduce potential environmental have a total capacity of up to 100 MW utilizing 66 wind turbine effects that may alter existing conditions. However, the presence of these projects and associated disturbance to the existing landscape is located within the generators (WTGs) each with a generating capacity of 1.5 MW. The traditional territories of Indigenous peoples, although as joint ventures / projects with BN, these projects are viewed as providing future benefits to Indigenous specific timeline for this project is dependent, among other things, on communities. the East-West Tie transmission line expansion. Pic River Road Rehabilitation Infrastructure Canada must determine whether the proposed Pic River This project/activity was deemed to be well outside the potential zone of influence of the Marathon Project (i.e., no spatial overlap – e.g., atmospheric Roads Rehabilitation project, located within the BN reserve, is likely to environment, acoustic environment, water quality and quantity) and was of such minor relative disturbance intensity and footprint that no interactions with cause significant adverse environmental effects. This project will other VECs of this sort warranted further consideration within the CEA. rehabilitate and widen approximately 4 km of Access Road and 1.7 km The potential for these activities to interact with land and resource uses (indigenous and non-indigenous) was acknowledge in the CEA but considered of Pic River Road including re-pavement, drainage and culvert unlikely since this work, will be completed within built-up areas. This project is viewed as an additional mitigation measure required from the federal and replacement, traffic calming devices, improved sidewalks/walking trails provincial governments to address existing conditions and historical effects on Indigenous communities. along the road and a bus pull-over.

7 of 7 Marathon Palladium Project (CIAR File No. 54755) Prepared on July 29, 2021 Generation PGM Response to the Joint Review Panel’s Request for Information #3 Received July 13, 2021

ATTACHMENT B: FIGURES

U T U

! T U T

! !

! ! !

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! U T

! U 500000 520000 540000 560000 580000 T

! ! T McKergow Lake Manitouwadge !Lake Manitouwadge ! U Vein Lake ! ! T (General ! ! TOWNSHIP! ! OF Hospital) Airport Killala Lake !

5440000 MANITOUWADGE 5440000 Steel Lake Conservation Kaginu Lake Reserve ! Morley Lake $$ Manitouwadge! Killala Lake Airport ¯ Legend ! ( Ruffle Lake Route Lake Gaffhook Lake Site Study Area Boundary Forest Management Unit ! (FMU) Boundary Mitchele Lake Regional Study Area for Barehead! Lake Steel River Land and Resource Use Municipal Boundary

Provincial ! Park Agonzon Lake (! Past, Current and Future Municipal Boundary, Lower ! ! 3 ! ! ! Prairie Lake ! Project Location ! ! ! Kenogami Forest Management Plan ! ! ! Marathon Pulp and Paper 4 ! ! Forest FMU !. Mapping ! Mill (Closed) ! ! ! ! ! Forestry Roads Existing ! ! ! East-West Tie (FMP) ! Owl Lake Cairngorm ! Transmission Line ! ! Forestry Roads Planned ! Lake Expansion ! Planned Forest Harvest ! ! ! ! HIGHWAY 614 Hydro Line Area (FMP 2021 - 2031)

! ! ! ! Larry Lake Fourbay Lake UT Transmission Line Planned Forest Harvest ! ! ! ! Area (FMP 2021 - 2031) ! Foxtrap Lake Glory Lake Highway ! ! ! 5420000 Fishnet Lake 5420000 Area Currently Disturbed ! Isko Dewabo Major Road ! ! Conservation Pic Cirrus Lake ! due to Timber Harvesting ! Lake Complex ! Reserve Martinet Lake ! ! Conservation Reserve Minor Road ! Forest FMU ! ! ! ! Pukatawagan Dotted Lake Railway ! ! Willie Lake Lake ! ! Ravine Watercourse ! ! Goodchild Dead Otter ! Coldwell Wind ! Lake ! ! Santoy Lake ! ! Boyer Lake Lake! Lake ! Waterbody ! ! TOWNSHIP OF ! ! ! Culvert Pan Lake ! Conservation Reserve ! TERRACE BAY Coubran Lake DISTRICT! OF Theresa Lake ! ! Rehab ! Pan Lake Fen (Regulated) ! (2022) THUNDER! BAY ! Provincial Park ! ! ! !

! ! Jackfish Lake ( Culvert Provincial Park

! ! !

! ! ! !

! Replacement White River ! ! ! ! ! ! !

! ! Solong

! ! ! ! Bamoos Lake

! ! ! ! First Nations Reserve

! ! ! ! (2021) !

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! ! Lake Forest FMU

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! ! ! Seeley Lake!

! ! ! Federal Protected Area

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! (2022) ! Lake Prairie (2020) ! HI H! W

(! G 1 ! Marathon Gowan Lake ! River Mouth ! ! 0 10 20 ! ! 7 ! Landfill Etna Lake ! Provincial Park ! (!

Little Red Sucker Point C km !

a ! Marathon Ellis Lake Steel Lake Provincial Park n Harriet Lake 1:330,000 (At original document size of 11x17)

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n ! 1. Coordinate System: NAD 1983 UTM Zone 16N

Provincial P !

5400000 !! 5400000 ! 2. Base features produced under license with the Ontario Ministry of Natural ! a !

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f ! ! ! Bridge Rehab !

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(! ! !

Harbour Sediment MARATHON Shores 3. Symbol is for cartographic representation and is not intended to depict the actual

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Remediation Project ! size of the project.

! Wind Farm

! ! !

! ! ! (!

! Dunc Lake 4. Forest Management Plan Mapping is based on the FMPs for the White River and

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! Provincial Lake Rust Lake ! ! Hydroelectric !

! Park Cache Lake ! ! Molson Lake

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! ! (! ! ! Slate Islands (! !

Campfire! Lake ! Provincial Park Ell Lake ! ! White

! ! Gitchi Animki Ontario Québec River ! Biigtigong

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Nishnaabeg Project Fearless Lake ! ! Lake

(BN) !

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Waste BN Community Mussy Lake Jumbo Lake ! ! ! Transfer (!(!

Lake Superior Water System (! Lake Superior ! Herrick Lake ! Upgrade Mashkigomin National Marine ! ! Lake

! ! Chain of Wisconsin Conservation Area Umbata Falls Hayward Lake ! Bridge Lakes Hydroelectric White River Michigan ! 5380000 5380000 Rehab ! ! Toronto ! (2021) ! Forest FMU ! !

! !! Project Location 129673006 REVA ! !( ! White Lake Marathon Prepared by DH on 2021-07-26 ! ! Provincial ! Park ! ! Client/Project ! GENERATION PGM INC. ! MARATHON PALLADIUM PROJECT !

! Rein Lake ! Figure No. Pukaskwa ! Lurch Lake 1 National ! Title Park ! Birch Lake ! Past, Current and Future Foreseeable ! Projects and Activities Within the Regional ! 500000 520000 540000 560000 580000 ! Study Area for Land and Resource Use

\\Ca0220-ppfss01\work_group\01609\active\_Other_PCs_Active\296 -Manitoba\129673006 Marathon PGM\gis_cad\gis\mxds\IRs\IR_3_1\129673006Disclaimer:_EIS_Fig01_CumulativeEffectsProjects_LRU_RSA_20210723.mxd Revised: 2021-07-26 By: swen Stantec assumes no responsibility for data supplied in electronic format. The recipient accepts full responsibility for verifying the accuracy and completeness of the data. The recipient releases Stantec, its officers, employees, consultants and agents, from any and all claims arising in any way from the content! or provision of the data. ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! !

! ! ! ! ! ! ! ! ! ! ! ! ! ! 500000 520000 540000 560000 580000 McKergow Lake Manitouwadge Lake Manitouwadge Vein Lake (General TOWNSHIP OF Hospital) Airport

5440000 MANITOUWADGE 5440000 Steel Lake Kaginu Lake

Manitouwadge Morley Lake $$ Killala Lake Airport (¯ Legend Ruffle Lake Route Lake Gaffhook Lake Site Study Area Boundary Area Currently Disturbed due to Timber Harvesting Mitchele Lake Barehead Lake Regional Study Area for Land and Resource Use Agonzon Lake Highway Prairie Lake Kenogami Major Road Forest FMU Minor Road Railway Owl Lake Cairngorm Lake Watercourse Waterbody HIGHWAY 614

Larry Lake Fourbay Lake Municipal Boundary Foxtrap Lake Glory Lake Municipal Boundary, Lower 5420000 5420000 First Nations Reserve Pic Forest Cirrus Lake Martinet Lake Forest Management Unit FMU (FMU) Boundary Dotted Lake Pukatawagan Forest Management Plan Willie Lake Lake Ravine Mapping 3 Goodchild Dead Otter Lake Santoy Lake Boyer Lake Lake Lake Forestry Roads Existing TOWNSHIP OF Pan Lake (FMP) TERRACE BAY DISTRICT OF Theresa Lake Forestry Roads Planned Coubran Lake THUNDER BAY Planned Forest Harvest Jackfish Lake Area (FMP 2021 - 2031) Bamoos Lake Pic Solong White River Seeley Lake Planned Forest Harvest c River Lake Forest FMU Little cifi Area (FMP 2021 - 2031) Santoy Lake Pa Lorna Lake White adi an Wabikoba Lake Can Lake TOWN OF Gowan Lake Etna Lake 0 10 20 Little MARATHON Ellis Lake km Steel Lake Harriet Lake 1:330,000 (At original document size of 11x17) Marathon Airport Lampi's Lake Notes 1. Coordinate System: NAD 1983 UTM Zone 16N

5400000 5400000 2. Base features produced under license with the Ontario Ministry of Natural Resources and Forestry © Queen's Printer for Ontario, 2018. 3. Forest Management Plan Mapping is based on the FMPs for the White River and MARATHON Pic FMUs and was provided by the Nawiinginokiima Forest Management Cedar Lake Dunc Lake Corporation. HIGHWAY 627 Little Cedar Rous Lake IGHWAY 17 H Lake Rust Lake Cache Lake Molson Lake

Campfire Lake Ell Lake White River Ontario Québec Biigtigong Nishnaabeg Spangle Lake Fearless Lake (BN) Minnesota Mussy Lake Jumbo Lake Lake Superior Herrick Lake Mashkigomin Lake Chain of Wisconsin Hayward Lake White River Lakes Michigan 5380000 5380000 Toronto Forest FMU Project Location 129673006 REVA Marathon Prepared by DH on 2021-07-26

Client/Project GENERATION PGM INC. MARATHON PALLADIUM PROJECT

Rein Lake Figure No. Lurch Lake 2 Title Birch Lake Forest Harvesting Activities Within the Regional Study Area for Land and

500000 520000 540000 560000 580000 Resource Use

\\Ca0220-ppfss01\work_group\01609\active\_Other_PCs_Active\296 -Manitoba\129673006 Marathon PGM\gis_cad\gis\mxds\IRs\IR_3_1\129673006Disclaimer:_EIS_Fig02_ForestHarvestingActivities_LRU_RSA_20210723.mxd Revised:2021-07-26 By: swen Stantec assumes no responsibility for data supplied in electronic format. The recipient accepts full responsibility for verifying the accuracy and completeness of the data. The recipient releases Stantec, its officers, employees, consultants and agents, from any and all claims arising in any way from the content or provision of the data. 500000 520000 540000 560000 580000 5440000 5440000 $$ (¯ Legend Site Study Area Boundary Area Currently Disturbed due to Timber Harvesting Regional Study Area for Land and Resource Use Highway Major Road Minor Road Railway Watercourse Waterbody Municipal Boundary Municipal Boundary, Lower

5420000 5420000 First Nations Reserve Forest Management Unit (FMU) Boundary Forest Management Plan Mapping 3 Forestry Roads Existing (FMP) Forestry Roads Planned Planned Forest Harvest Area (FMP 2021 - 2031) Planned Forest Harvest Area (FMP 2021 - 2031)

0 10 20 km 1:330,000 (At original document size of 11x17) Notes 1. Coordinate System: NAD 1983 UTM Zone 16N

5400000 5400000 2. Base features produced under license with the Ontario Ministry of Natural Resources and Forestry © Queen's Printer for Ontario, 2018. 3. Forest Management Plan Mapping is based on the FMPs for the White River and Pic FMUs and was provided by the Nawiinginokiima Forest Management Corporation. 4. Orthoimagery Source:© 2021 Microsoft Corporation Earthstar Geographics SIO © 2021 TomTom. Image Date- Unknown

Ontario Québec

Minnesota

Wisconsin Michigan

5380000 5380000 Toronto

Project Location 129673006 REVA Marathon Prepared by DH on 2021-07-26

Client/Project GENERATION PGM INC. MARATHON PALLADIUM PROJECT

Figure No. 3 Title Forest Harvesting Activities Within the Regional Study Area for Land and

500000 520000 540000 560000 580000 Resource Use