Phase 2 Passive Dustfall Monitoring August 14, 2019

Project No: 19Y0006 EDI ENVIRONMENTAL DYNAMICS INC. 11 Mary River Project Phase 2 Proposal

ECCC-FC1 ATTACHMENT 2: HUMAN HEALTH BASED DUSTFALL THRESHOLDS FOR MINE AND PORT SITE

Date: October 15, 2019 To: Lou Kamermans, BIM From: Christine Moore, Intrinsik cc : Mike Setterington, EDI; Mike Lepage, RWDI, Richard Cook, KP; Sara Wallace and Dan Jarratt, Stantec Re: Human Health Based Dustfall Thresholds for Mine and Port Site – DRAFT V 3

While dustfall guidelines exist in several jurisdictions (such as Ontario and Alberta), they are generally based on soiling, as opposed to human health considerations. The Government of is requesting that Project-specific dustfall guidelines protective of human health be developed for use within the Air Quality and Noise Abatement Management Plan (AQNAMP) to define rates which would be associated with management actions. Project-specific dustfall guidelines developed for consideration of human health within the Project area need to consider the model predictions for dustfall, in addition to the size of affected areas and potential exposure that could occur based on consumption rates for resources harvested within the area. These factors were used to define potential exposure scenarios.

An additional consideration when developing dustfall rates protective of human health is the different geochemistry at the mine and port areas based on the existing site-specific geochemistry of the dustfall samples previously collected. As all rock and soil contain naturally occurring metals and metalloids (which will be referred to as metals), the dustfall generated from Project activities also contains metals. Iron is the most common metal in the dustfall, representing 4.43% of total dustfall at the Mine site, and 3.03% at the Port site. This is expected because the ore is rich in iron. Aluminium is the second most common metal in the dustfall (averaging 2.83% at the Mine and 1.58% at the Port). All remaining metals are either present at less than 0.02% (e.g., copper, chromium, barium, nickel), or present at even lower percentages (e.g, antimony, cobalt, lead, silver, thallium). Arsenic was detected in 39 of 216 dustfall samples, with the vast majority of samples being below a level of detection. Mercury and selenium were completely non-detectable in all dustfall samples at the Mine, Port and Tote road stations. Cadmium was also rarely detected in dustfall (7 samples had detectable cadmium levels of 216 samples taken).

Human Health Risk Assessment (HHRA) modelling conducted in HC-TIR-03 (Country foods submission, March 2019), and supplementary modelling conducted to determine dust management action trigger levels has indicated that the most sensitive risk drivers are the consumption of berries (as a result of dust deposition onto berries), and consumption of caribou organ meats (due to potential for accumulation of cadmium and/or mercury as a result of lichen consumption by caribou). For berry consumption, arsenic exposure was the most sensitive Chemical of Potential Concern (COPC) at the Milne Port site. At the Mine site, aluminum exposure related to berry consumption was the most sensitive COPC.

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The HHRA model used conservative (i.e., biased high) cadmium, mercury and arsenic geochemistry ratios for the following reasons:

• Cadmium is generally not detectable in the dustfall samples (detected in only 3% of near field dustfall samples from 2015 to 2016). The geochemistry for cadmium applied in the assessment was based on a ratio derived from a single detected sample at the mine site (the rest of the samples from 2015 to 2016 were below the level of detection for cadmium). To be conservative (i.e., concentration biased high), the selected geochemistry ratio of 0.0012% was applied at the Mine (based on a single detected sample), whereas ratios for the Port were lower at 0.0009% (based on an average of all samples). Therefore, since the assumed geochemistry is likely biased high, the predicted risks are also biased high. • Mercury was not detectable in all dustfall samples. The geochemistry ratio at the Mine site was 0.0011%, and at the Port was 0.0021%, based on non-detect values (see TSD-11). The geochemistry ratios are therefore based on a non-detect ratio, and therefore the risk estimates are biased high. • Arsenic geochemistry ratio at the Mine was based on detected samples only (0.00333%), whereas the Port arsenic geochemistry ratio was based on an average of all data (0.018%). Had detected samples been used at the Port, the ratio would have been lower (0.0114%).

To identify possible dustfall indicator rates for the AQNAMP to be protective of human health and to derive levels associated with management action trigger levels, the HHRA model was used to run a variety of exposure scenarios based on varying annualized dustfall rates (g/m2/year) selected from the air dispersion modelling isopleths presented in TSD-07. The size of the area affected by dustfall in the isopleth figures was used to tailor the various exposure scenarios [see Figures D-14 (Milne Port) and E- 13 (Mine site) from TSD-07 — attached]. For example, if dust is deposited across a wide area at a given rate, then a higher exposure potential was assumed based on the potential for a greater number of berries to be harvested in a broader area, and for caribou to spend a greater amount of time in a larger area. In contrast, if dustfall of the same concentration occurs in a smaller area, then there is lower exposure potential given the smaller size of the potentially affected area and associated lesser amount of harvest.

The following consumption assumptions were either held constant or varied based on the following reasoning:

• In all scenarios, the full annualized consumption rate for Arctic hare, ptarmigan and medicinal plants was assumed to occur in the Project areas, regardless of the size of the affected area. • Consumption of berries varied depending on the size of the area potentially affected by dust deposition. Consumption rates were varied in the dust management action trigger level analysis from 100% (i.e., all berry consumption for a year was assumed to come from areas affected by dust), to 50% (half of the annual berry consumption rate was assumed to come from areas affected by dust) to 0%. Note that berries are not prevalent in the area in general (EDI 2015). • Consumption of caribou was held constant (i.e., all caribou meat and organ meat consumption were assumed to come from the Project area experiencing dustfall). However, the time that a

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caribou spent in the area influenced by dustfall varied from 1% of their annual cycle to up to 33% of their annual cycle. In HC-03, caribou were assumed to be not affected by the Project because the majority of caribou are found distant to the Project area, and the time spent in the Project area has been quantified as less than one day, based on existing collar analysis (EDI; M. Setterington, personal communication). As discussed in HC-TIR-03, collar data for caribou illustrates very low interaction with the PDA (including a 100 m buffer beyond the PDA, which approximates the maximum extent of measurable dustfall). Of the three collared caribou that were found within 100 m of the PDA between 2008 – 2010, the number of hours in a given year ranged from 0:51 hours to 4:05 hours, with a total percentage of time in the PDA/Year ranging from 0.009% to 0.0047% (based on 8,760 hours in a year). Based on this, and the large home range of caribou, the potential for the project to influence either caribou meat or organ meats is extremely low. Regardless, caribou were included in the baseline Country Foods assessment and it was assumed that influence from the Project on meat concentrations was limited. In order to identify management action trigger levels for the dustfall rates in this dust exposure analysis, it was assumed that caribou could move into the area for periods of time, thus accounting for potential exposures which may be incurred from dustfall via consumption of lichen, and to enable the risk-based dustfall rate to reflect this potential.

Based on these considerations, a matrix was used to create low, moderate and high exposure scenarios for annual dustfall rates. In each of these scenarios, the Incremental Lifetime Cancer Risk (ILCR) for arsenic exposures remains at levels at or below 1: 100,000, and therefore risks are considered negligible. For other important COPCs, such as cadmium and mercury, Hazard Quotients (HQ) for the Project scenario remain below 0.2, and are therefore considered to be negligible, or are considered acceptable based on the conservative assumptions used (e.g., mercury is non-detect in the ore, but was assumed to be present). Table 1 presents the various scenarios for each of the selected dustfall management action trigger levels. Note that due the arsenic geochemistry ratios at the Milne Port project area being higher than those at the mine (based on the site-specific geochemistry data from the dustfall samples), dust management action trigger levels are more conservative at the Milne Port area than the mine area. The arsenic geochemistry ratio at the Mine (based on detected samples only) was 0.0033%, whereas the ratio applied at the Port (based on all samples, including non-detect samples) was 0.018%.

Based on the model results, the dustfall predictions from the Phase 2 Project do not raise concerns about berry or caribou consumption given that; 1) there are few berry sources within the PDA, and 2) caribou are unlikely to be “tied” to foraging in the project area and the exposures used in this model are likely gross overestimates of potential uptake – and even so are unlikely to create a health risk.

In keeping with agreed upon management steps between Baffinland and Government of Nunavut, an exceedance of a dust management action trigger level will initiate a stepwise approach to air quality management, which will include:

1. Identifying the cause of exceedance (e.g., identification of sources; spatial / temporal aspects of exceedance); 2. Implementing the source mitigation, based on source identification; 3. Determining need for, and focus of, additional monitoring; and

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4. Conducting a supplemental risk assessment based on the triggered exceedances, if necessary.

The application of the dustfall rates provided in Table 1 are meant as follows:

• Low dustfall rates are only to be used for distant monitoring sites. These are meant to verify that dustfall rates within the LSA at distant locations remain low; • Moderate dustfall rates in Table 1 are provided for perspective and assessment purposes, when examining annualized dustfall rates from areas within the LSA, but closer to the PDA boundary. • High dustfall rates should be used to assess dustfall at the PDA boundary, or areas within distant parts of the PDA which could be accessed and used for foraging/harvesting. These rates are not to be applied on dustfall data collected within the active Project areas (e.g., inside of the PDA boundary). These rates can be modified to examine additional exposure scenarios, as needed. For example, berries are likely absent in areas immediately adjacent to the PDA, based on historical baseline sampling attempts.

Long-term follow-up monitoring associated with the results of the HHRA will include dustfall quantities and content (e.g., COPCs), metals in vegetation and soil, and caribou behaviour. Based on measured dustfall rates and the potential return of caribou to the project area, future monitoring results can allow further examination of dustfall rates provided in Table 1, which can be used to determine whether consumption rate and time on site assumptions for berries and caribou are reasonable and realistic (to confirm that the consumption estimates are appropriate to actual dustfall and caribou behaviour [e.g., time in an area influenced by dustfall]).

Isopleths are provided for perspective on the size of areas affected, based on modelling presented in TSD-07.

References:

EDI (Environmental Dynamics Inc.) 2015. 2014 Terrestrial Annual Environmental Monitoring Report. 124 pp. Prepared for Baffinland Iron Mines Corporation.

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Table 1: Low, Moderate and High Dustfall Management Action Trigger Levels Based on Exposure Scenarios and Potential Size of Affected Areas

Scenario Low Dustfall Management Action Moderate Dustfall Management Action High Dustfall Management Action Trigger Trigger Levels Trigger Levels Levels

Mine Milne Port Mine Milne Port Mine Milne Port

Dustfall Rates (g/m2/year) < 10 < 5 25 15 55 35

Size of area affected based A substantial Most of the LSA; A small portion of LSA, A very small portion Small percentage of Mostly inside the on annual dustfall predictions portion of LSA; as well as a reasonable of LSA; extends over LSA PDA, except for provided in TSD-07 extends slightly portion of PDA Phillips Creek to the western side and beyond LSA in west (approx. 1 km northern (Port) area. the west and from the PDA); southwest contained within PDA on east side

Scenarios

Exposure Assumptions 100% of berries 100% of berries 50% of berries 33% of berries 33% of berries 5% of berries consumed are consumed are consumed are exposed consumed are consumed are consumed are exposed to this exposed to this to this level of dustfall. exposed to this level exposed to this level exposed to this level level of dustfall level of dustfall; of dustfall. of dustfall of dustfall Caribou spend 10% of Caribou spend Caribou spends year in areas with this Caribou spend 5% of Caribou spend 5% of Caribou spend 1% of 33% of year in 33% of year in level of dustfall year in areas with year in areas with this year in areas with this areas with this areas with this this level of dustfall level of dustfall level of dustfall level of dustfall level of dustfall (small area)

Risk Low: Project Low: Project Low: project related Low: Project related Low: Project related Low: Project related related HQs< 0.2; related HQs< 0.2; HQs < 0.2; or considered HQs< 0.2; or HQs are < 0.2; or HQs <0.2; or or considered or considered acceptable based on considered considered considered acceptable based acceptable based conservatisms in acceptable based on acceptable based on acceptable based on on conservatisms on conservatisms assessment conservatisms in conservatisms in conservatisms in in assessment in assessment assessment assessment assessment

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Mary River Project Phase 2 Proposal

ECCC-FC6 ATTACHMENT 1: WEATHERING OF ARCTIC DIESEL RELEASE, SHOULDER SEASON FIGURE

ECCC-FC6-1: Attachment 1

Figure ECCC-FC6-1 Weathering of Arctic Diesel Release, Shoulder Season

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Mary River Project Phase 2 Proposal

APPENDIX H HEALTH CANADA

Mary River Project Phase 2 Proposal

THERE ARE NO ATTACHMENTS IDENTIFIED FOR THIS GROUP OF RESPONSES, AT THIS TIME

Mary River Project Phase 2 Proposal

APPENDIX I NATURAL RESOURCES CANADA ATTACHMENTS

Mary River Project Phase 2 Proposal

THERE ARE NO ATTACHMENTS IDENTIFIED FOR THIS GROUP OF RESPONSES, AT THIS TIME

Mary River Project Phase 2 Proposal

APPENDIX J PARKS CANADA AGENCY ATTACHMENTS

Mary River Project Phase 2 Proposal

THERE ARE NO ATTACHMENTS IDENTIFIED FOR THIS GROUP OF RESPONSES, AT THIS TIME

Mary River Project Phase 2 Proposal

APPENDIX K TRANSPORT CANADA ATTACHMENTS

Mary River Project Phase 2 Proposal

THERE ARE NO ATTACHMENTS IDENTIFIED FOR THIS GROUP OF RESPONSES, AT THIS TIME

Mary River Project Phase 2 Proposal

APPENDIX L OCEANS NORTH ATTACHMENTS

Mary River Project Phase 2 Proposal

ON-01-02 ATTACHMENT 1 MEMORANDUM: INUIT EMPLOYMENT AND THE PHASE 2 PROPOSAL ECONOMIC IMPACT MODEL

October 2019

MEMORANDUM: INUIT EMPLOYMENT AND THE PHASE 2 PROPOSAL ECONOMIC IMPACT MODEL

Introduction

This memorandum provides a response to issues raised by Oceans North on Baffinland’s Economic Impact Model (TSD-25, Appendix A) during the Technical Comment and Final Written Submission stages for the Phase 2 Proposal. It describes model limitations and assumptions made related to future Inuit employment levels, and presents the results of sensitivity analyses conducted to ascertain the influence of increased/decreased levels of Inuit employment on the model’s results. Finally, this memorandum describes conservative measures Baffinland has employed during the modelling process, and ongoing actions the Company is taking to increase Inuit employment at the Project.

Overview of the Economic Impact Model

An Economic Impact Model for the Phase 2 Proposal (EcoTec Consultants, 2018) was prepared to determine the Project’s anticipated effect on several economic variables, including:

• Total employment in Full-Time Equivalent (FTE) terms in Canada and Nunavut • Total Expenditures in Canada and in Nunavut • Total GDP Generated in Canada and Nunavut • Revenues that will accrue to the Federal Government, Government of Nunavut, and Nunavut Inuit Organizations • Average Annual Territorial Export Value

The model clearly demonstrates the Mary River Project’s potential to deliver significant benefits in all the economic areas identified in the study, contributing prominently to the territorial and national economies. Baffinland’s long-term objective is to realize all of this potential throughout the entire life of the Project. This requires a degree of stability that will be achieved through the Phase 2 Proposal’s investments in productivity and efficiency. A financially successful operation is the most secure means to meeting this objective. Furthermore, the expansion of production proposed through Phase 2 will provide greater certainty for the long-term delivery of economic benefits and enable a more rapid delivery of royalty payments to QIA and NTI.

Model Assumptions

Various assumptions and estimations were made during the modelling process; this is a standard practice in forward-looking planning activities such as an environmental assessment. These are elaborated on below.

Assumptions Regarding Inuit Employment Used in the Economic Impact Model

During the April 8-10, 2019 Technical Meeting held in Oceans North raised concerns about Inuit employment levels projected in the Economic Impact Model (primarily during construction, when overall employment demand will be highest). Baffinland responded by clarifying the assumptions it made in this part of the model. Namely, a 20% (approximate) Inuit employment rate was applied to the

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Phase 2 Proposal’s construction and operations workforce projections. This percentage was selected after comparing actual Inuit employment levels at the Project in 2016 (approximately 15% of total employment) against the Minimum Inuit Employment Goal (MIEG) established through the Mary River Inuit Impact and Benefit Agreement (IIBA) at the time (25%). A 20% level of Inuit employment was believed to represent an appropriate ‘middle ground’ between these two values.

While the MIEG is established annually with the Qikiqtani Inuit Association (QIA) and can change over time, Baffinland remains committed to meeting it through the implementation of Inuit training and hiring strategies developed in consultation with QIA and through compliance with the IIBA. The Company is actively involved in various initiatives to increase Inuit employment, training, and contracting at the Project, and notable gains have been made in recent years. The Company’s performance on Inuit employment, training and contracting is reported annually in its Socio-Economic Monitoring Report filed with the NIRB (e.g. JPCSL, 2019), and quarterly/annually in its IIBA Implementation Reports submitted to QIA.

Inuit Employment Sensitivity Analysis

A sensitivity analysis has been conducted using 10%, 15%, 20%, and 25% Inuit employment levels to determine their influence on key modelling variables and findings. The results of this analysis were provided by EcoTec Consultants and are summarized in Table 1.

This sensitivity analysis has revealed that, in all scenarios, the Phase 2 Proposal will remain a significant economic contributor regardless of the exact percentage of Inuit employment projected. However, Baffinland acknowledges the substantial differences in earned income between 10% and 25% Inuit employment. Baffinland continues striving to maximize Inuit employment at the Project and further acknowledges regional benefits will grow alongside gains that are made in this area. The sensitivity analysis also reveals the main impact of differing Inuit labour content at the Project would be felt in the labour market. The 16,221 Full-Time Equivalents (FTEs) of work for Nunavut residents under the 20% scenario would increase to 18,854 FTEs under a 25% scenario (+16.2%). Employment is further estimated at 13,754 FTEs (-15.2%) under the 15% scenario and at 11,258 FTEs (- 30.6%) under the 10% scenario.

The analysis also shows that most economic benefit measures would see small to no changes. For example, the GDP would move in a narrow band between +0.4% (under the 25% scenario) to -0.7% (under the 10% scenario). These small changes can be explained by the fact that the bulk of GDP generation is from the improvement of the balance of trade (i.e. exports minus imports); there is no change in this under the various scenarios. There is a bit more variation in government revenues under the different scenarios, but not much: Nunavut government revenues would increase by 1.2% under the 25% scenario, and would decrease by -1.1% or -2.3% under the other two scenarios. No changes are expected with revenues for Nunavut Inuit organizations, as the production schedule and profitability of the Project remain unchanged under the four different scenarios.

Put more simply, the Mary River Project will continue to provide substantial economic benefits at the territorial and national scales under all scenarios.

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Conservative Measures Employed

Assumptions and limitations are inherent in any modeling exercise. In acknowledgement of this, Baffinland has employed conservative measures in the modeling process where appropriate. This includes:

Clearly describing the limitations of the modelling exercise “The estimations of economic benefits outlined in this report are just that: estimations based on scenarios and hypotheses taking place in future years… A mining project by its very nature is highly dynamic and the economics of such a project, including costs, employment, production schedules, exchange rates and other elements change on a weekly basis.” (EcoTec Consultants, 2018: 4)

Not accounting for all additional indirect economic ‘spin-off’ benefits of the Project “In order to provide prudent estimates of economic benefits for Nunavut, no attempt was made to calculate additional economic benefits by spending either (a) Nunavut Government fiscal revenues or (b) projected revenues for the Qikiqtani Inuit Association (QIA) generated by the Mary River Project in the Nunavut economy.” (EcoTec Consultants, 2018: 10)

Selecting an Inuit employment level below the 25% MIEG A 20% (approximate) level of Inuit employment was believed to represent an appropriate ‘middle ground’ that was considerate of actual Inuit employment observed at the Project (approximately 15% in 2016) and the MIEG established with QIA at the time (25%).

High import content “Efforts have been made to identify direct imports of goods and services (including financing costs). The Economic Impact Model (EIM) did also calculate likely import content for items purchased in Canada but likely manufactured in other countries. An example of this is machinery and equipment purchased by Baffinland from a dealer or wholesaler in Ontario: the initial expenditure is made in Canada, but the real Canadian content is much lower (due to large import content).” (EcoTec Consultants 2018: 10)

Ongoing Actions to Increase Inuit Employment at the Project

Baffinland acknowledges its Inuit employment goals cannot be achieved over the course of a single year and that significant ongoing efforts will be required to maximize Inuit employment. Baffinland is committed to using best efforts to improve its Inuit employment record each year. An evaluation of efforts to achieve the MIEG is undertaken annually with QIA through the IIBA Joint Executive Committee; as appropriate, actions are identified jointly to improve Inuit employment in the short- and long-term. Recent efforts and commitments Baffinland has made to increase Inuit employment at the Project include, but are not limited to:

• Finalization of the Inuit Human Resources Strategy (IHRS) • Qikiqtani Skills and Training for Employment Partnership (Q-STEP) training program with QIA • Work Ready Program • Apprenticeship Program • Morrisburg Heavy Equipment Operator Training Program

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• Inuit Internship Program • Inuit summer student employment • Quarterly employment and training information sessions held in Point of Hire communities • Hiring of an Inuit recruiter • Employment of an Inuit Employment and Training Specialist, and funding for QIA to hire an Inuit Engagement Specialist • $10 million commitment to construct the Baffinland Inuit Training Centre in

Issues of IIBA implementation, non-conformance, and enforcement are addressed directly in the IIBA. For example, an IIBA Employment Committee has been established to implement provisions of the IIBA that maximize Inuit employment at the Project, including all provisions relating to employment, education and training, including the IHRS. Likewise, an IIBA Contracting Committee has been established to implement provisions of the IIBA that maximize business opportunities at the Project for Inuit Firms, including the Inuit Procurement and Contracting Strategy (IIBA Article 4.4). IIBA Article 10 and Article 21 describe various enforcement, mediation, and arbitration instruments that may be used by QIA and Baffinland if required.

Furthermore, in response to QIA Final Written Submission #33-36 (QIA, 2019), Baffinland has committed to work with QIA to develop an updated Inuit Training Plan that covers the period between Phase 2 construction and the first three years of operations. This plan will provide updates on programs that will be offered and how Baffinland intends to maximize Inuit engagement with the Project.1 Baffinland would also like to note that construction periods are short-term in nature, and that Inuit employment during this time is but one of many influences on the Project’s overall economic contributions.

Conclusion

The conclusions of the Economic Impact Model indicate the potential for significant economic benefits to be provided as a result of the Phase 2 Proposal. The results of a subsequent Inuit employment sensitivity analysis, the conservative measures employed during the modelling process, and ongoing actions to increase Inuit employment at the Project give Baffinland continued confidence in its ability to provide meaningful economic benefits through the Phase 2 Proposal.

References

Baffinland Iron Mines Corporation (Baffinland). 2019. Response to QIA Technical Comment #32 - 2018 Training Program Evaluation & Response to QIA Technical Comments #33-26 – Phase 2 Construction Training Plan. Submitted to NIRB on July 12, 2019.

EcoTec Consultants. 2018. Assessment of Economic Benefits Generated by the Mary River Project’s Phase 2 Proposal. Report prepared for Baffinland Iron Mines Corporation. June 2018.

1 Baffinland would like to note that in response to QIA Technical Comments #33-36, the Company has already provided a summary of the training programs and plans that are expected to be put in place by its contractors who will be constructing major components of the Phase 2 Proposal, if approved (Baffinland, 2019). Baffinland also notes that the relevant training and administration provisions of the IIBA, and the IIBA Implementation Guide, are the overriding documents that will guide the review and approval of training to take place at the Mary River Project. Training plans and programs will be reviewed through the IIBA Employment Committee before being considered final and in use.

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Jason Prno Consulting Services Ltd. (JPCSL). 2019. 2018 Socio-Economic Monitoring Report for the Mary River Project. Report prepared for Baffinland Iron Mines Corporation. March 31, 2019.

Qikiqtani Inuit Association (QIA). 2019. Final Written Submission for the NIRB Review of Baffinland Iron Mines Corp.’s “Phase 2 Development” Project Proposal. September 27, 2019.

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Table 1: Economic Impact Model Sensitivity Analysis Results – Inuit Employment

20% Inuit Employment 10% 15% 25% (Assumption used in Inuit Employment Inuit Employment Inuit Employment Economic Impact Model Report) Total Full-Time Equivalents (FTEs) 137,263 FTEs 136,999 FTEs 136,745 FTEs 136,478 FTEs in Canada Total Full-Time Equivalents (FTEs) 11,258 FTEs 13,754 FTEs 16,221 FTEs 18,854 FTEs in Nunavut Total Canadian $19.82 billion $19.82 billion $19.82 billion $19.82 billion Expenditures Total Nunavut $4.41 billion $4.55 billion $4.69 billion $4.84 billion Expenditures Total GDP Generated $30.94 billion $30.80 billion $30.67 billion $30.52 billion in Canada Total GDP Generated $19.18 billion $19.25 billion $19.32 billion $19.40 billion in Nunavut Revenues Generated for the $1.69 billion $1.68 billion $1.68 billion $1.67 billion Federal Government Revenues Generated for the $664.6 million $672.3 million $679.9 million $687.9 million Government of Nunavut Revenues Generated for $1.98 billion $1.98 billion $1.98 billion $1.98 billion Nunavut Inuit Organizations

Average Annual Territorial Export Value $1.10 billion $1.10 billion $1.10 billion $1.10 billion

Source: EcoTec Consultants

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Mary River Project Phase 2 Proposal

ON-01-02 ATTACHMENT 2: TABLES ASSOCIATED WITH ON-01- 02 RESPONSE

ON-01-02 Attachment 2: Tables Associated with ON-01-02 Response

Table 1: Number of Project and Non-Project vessel transits in the RSA presented by month – Phase 2 Proposal

Vessel/Month July August Sept Oct Total Ore carriers 44 124 120 64 352 Cargo/Fuel 10 12 12 6 40 Icebreaker 4 0 0 0 4 Tugs 10 0 0 10 20 Cruise ships 0 30 20 0 50 Non-project cargo/sealift 4 4 4 4 16 Non-project vessels (CCG, Navy) 4 4 4 4 16 Total 76 174 160 88 498 Daily Avg/Mth 5.1 5.6 5.3 5.9 4.2

Table 2: Estimated cumulative daily noise exposure period for marine mammals during open water shipping - Average Case

Disturbance noise field - R95%Exposure Period Average # of Daily Exposure Scenario R95% range (km) (h) per transit Transits per Day Period (h) 1 Capesize carrier (solo) 18.2 2.2 3 6.6 1 Postpanamax (solo) 11.2 1.3 2 2.6 Non-project vessels 18.2 2.2 1 2.2 Combined 6 11.4

Table 3: Estimated cumulative daily noise exposure period for marine mammals during open water shipping - Maximum Case*

Disturbance noise field - R95%Exposure Period (h) Average # of Daily Exposure Scenario R95% range (km) per transit Transits per Day Period (h) 1 Capesize carrier (solo) 18.2 2.2 4 8.8 1 Postpanamax (solo) 11.2 1.3 4 5.2 Non-project vessels 18.2 2.2 1 2.2 Combined 9 16.2 *due to potential delays in the shipping schedule that may occur occasionally during the season, a maximum case of 8 transits per day was considered. ** given that source levels of non-Project related vessels are not available, and these were not acoustic modeled, non-Project related vessels were conservatively assumed to generate a noise field equivalent to a capsize carrier.

1 of 2 ON-01-02 Attachment 2: Tables Associated with ON-01-02 Response

Table 4: Comparison of modeled vs. measured ‘per transit’ and ‘cumulative daily’ noise exposure periods for icebreaker transits - DISTURBANCE (120 dB)

Scenario R95% Noise field – Cum. daily Ice exposure # of transits Speed R95% range exposure Conditions period (h) per per day (km) period (h) transit

1 icebreaker + 2 Capesize 4.6 knots 10/10 40.3 9.5 1 9.5 carriers - MODELED 9 knots 3/10 37.3 4.5 2 9

9 knots 0/10 25.9 3.1 4 12.4

1 icebreaker + 2 Capesize carriers - MEASURED 9 knots 0/10 N/A 1.3* 4 5.2 (Bylot)

Table 5: Comparison of modeled vs. measured ‘per transit’ and ‘cumulative daily’ noise exposure periods for icebreaker transits - AVOIDANCE (135 dB)

Scenario Noise field – R95% exposure Cum. daily Ice # of transits Speed R95% range period (h) per exposure period Conditions per day (km) transi (h)

4.6 knots 10/10 8.7 2 1 2 1 icebreaker + 2 Capesize 9 knots 3/10 6.6 0.8 2 1.6 carriers - MODELED 9 knots 0/10 2.5 0.3 4 1.2

1 icebreaker + 2 Capesize carriers - MEASURED 9 knots 0/10 0.2 4 0.8 (Bylot)

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APPENDIX M WORLD WILDLIFE FUND ATTACHMENTS

Mary River Project Phase 2 Proposal

WWF-FWS 04 ATTACHMENT 1: VESSEL SPEEDS IN RSA DURING 2019 SHIPPING SEASON

WWF-FWS-04: Attachment 1 – Table 1

Table 1: Vessel Speeds in RSA during 2019 Shipping Season

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Mary River Project Phase 2 Proposal

WWF-FWS 06 ATTACHMENT 1: SPILL RISK ANALYSIS

October 15, 2019 Knight Piésold Ltd. 1650 Main Street West North Bay, Ontario Mr. Lou Kamermans Canada, P1B 8G5 Director, Corporate Sustainability T +1 705 476 2165 Baffinland Iron Mines Corporation E [email protected] #300-2275 Upper Middle Road East www.knightpiesold.com Oakville, Ontario Canada, L6H 0C3

Dear Lou,

RE: The Mary River Project – Phase 2 Proposal: Review of WWF’s Marine Spills Probability Analysis

1.0 INTRODUCTION

In July 2019, the World Wildlife Fund (WWF) filed the report Baffinland Oil Spill Probability: Updated Analysis for Phase 2 Expansion Proposal Vessel Traffic prepared by Environmental Research Consulting (ERC, 2019) with the Nunavut Impact Review Board (NIRB) as part of the technical review of the Mary River Project’s Phase 2 Proposal. The ERC Report provides estimates of the probability of accidents and oil spills from vessel traffic in Milne Inlet Port as a result of the increased vessel traffic associated with the Phase 2 Proposal. Baffinland Iron Mines Corporation (Baffinland) requested that Knight Piésold Ltd. (KP) review and provide comments on the ERC Report. Our review focused on the following aspects of the report:

• Vessel traffic assumptions used in the assessment • The data used to derive spill probabilities to the Project, particularly in light of trends in marine safety • The methods used to calculate spill probabilities and frequencies This letter presents our comments and questions on this report. Fednav Ltd. (Fednav) also provided comments, presented in Appendix A.

2.0 BACKGROUND

Baffinland is currently in the reconsideration process of its Project Certification No. 005 by the NIRB regarding the Phase 2 Proposal, which will increase the quantity of ore shipped from Milne Port to 12 Mtpa. Several modifications are required to the current Project to accommodate the increased production rate. With respect to the marine shipping component of the Project, the Phase 2 Proposal will involve the following:

• Construction of a second ore dock at Milne Port capable of berthing capesize ore carriers • Lengthening the current shipping season of July 15 - October 15 to July 1 – November 15 (approximate 45-day increase) • Increased traffic with larger vessels to ship the ore A complete description of shipping activities associated with the Phase 2 Proposal is provided in Technical Supporting Document (TSD) No. 2 of the Addendum to the Final Environmental Impact Statement

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(FEIS Addendum) for the Phase 2 Proposal (Baffinland, 2018). Forecasted vessel traffic is provided in the key facts table in Appendix C of TSD 2. The ERC Report presented probabilities of spill-related accidents for various vessel types to be used by the Project. The probability data were sourced from Det Norske Veritas, 2011a and 2011b and The Glosten Associates Inc. et al., 2013, which generated accident and spill probabilities based on global shipping statistics for the period of 1980 to 2010. Probabilities are based upon ship traffic estimates for both the current operation and the Phase 2 Proposal.

3.0 REVIEW OF THE ERC REPORT

As mentioned in Section 1, a detailed review of the ERC Report was completed. Our review comments can be summarized as follows:

• Tug Boat transits are shown to be higher than will likely occur for the Project, based on the latest shipping scenarios • The reliance on historic data (i.e. data predating year 2000) to establish probabilities for the marine traffic and accidents (spills) o Historic higher accident data can skew probabilities, as the marine safety trends have greatly improved over time, especially over approximately the last decade • Oil spill probabilities and return periods appear high, despite the improving statistics worldwide • Baffinland’s existing mitigation measures and safety protocols are not considered The following sections describe our comments in further detail. There are areas that we have identified as points of discussion that we would like to have with the author, if that is a possibility.

3.1 TUG BOAT TRANSIT DATA

Table 3 of the ERC Report presents estimated vessel traffic data for the Phase 2 Proposal. Phase 2 traffic data was estimated based on percentage increase of ore carriers and overall operations at the Project. These values were inflated based off baseline vessel traffic (presented in Table 1 of the ERC Report). Table 1 references a Baffinland report that was issued in 2015 regarding the Trans-Shipping of Ore in Greenland Waters. The Tug Boat scenarios described in that report are not applicable to the current Project and/or the Phase 2 Proposal. There will be 6 to 10 Tug Boats providing docking services in Milne Inlet during Phase 2, which will only enter and depart Milne Inlet once at the beginning and the end of the season (unless there is a safety issue) (Fednav, 2019, Appendix A). As such, the estimated 730 transits should be discussed with ERC, given that the Tug Boats will be primarily operating within the harbour for most of the season.

3.2 REFERENCED STATISTICAL DATA

ERC (2019) drew from three reports to generate probabilities of spills by vessel type and accident type (Table 5 of the ERC Report). These include: 1. Final Report: Assessment of the Risk of Pollution from Marine Oil Spills in Australian Ports and Waters (Det Norske Veritas [DNV-GL], 2011a) 2. Ship Oil Spill Risk Models (DNV-GL, 2011b) 3. Gateway Pacific Terminal Vessel Traffic and Risk Assessment Study: Accident Probability Statistics (The Glosten Associates Inc. et al., 2013)

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DNV-GL, 2011a and DNV-GL, 2011b utilized the Lloyd’s Register Fairplay (LRF) Casualty and Fleet database. This database covers all ships over 100GT world-wide. DNV-GL, 2011a includes casualty and fleet databases from 2000-2010. DNV-Gl, 2011b data were extracted in 2011 and include figures from 1980 to 2010. While it is not clear what data were used for the calculations of accident probabilities, it is assumed that the data were inclusive of historic accident data. There has been a marked reduction in the frequency of marine accidents including fuel spills over the past several decades, and hence the use of historic data may not be reflective of current probabilities. It is believed that the use of outdated data from the 1980s and 1990s could negatively skew the data, as there has been a marked decline in accidents (with or without oil spills) over time (as seen below in Figures 3.1 and 3.2). The Glosten Associates, Inc. et al. 2013, is a document that was issued for an Environmental Impact Statement (EIS) for a terminal project in Washington, USA. The project was abandoned in 2017, and we cannot now locate this reference, so we were unable to assess the dataset that was used. It should be noted that the LRF database includes data from both cargo and non-cargo ships (ex. ferries, fishing vessels) (Statistics Canada, 2005). Most of the accidents that were reported within the Transportation Safety Board of Canada (TSB) 2018 accident database, involved fishing vessels (TSB, 2019). Including fishing vessels with ships involved with the Project may negatively affect the accident probabilities. As shown on Figure 3.1, illustrates the decline in shipping related accidents in Canada since 2004 (John, 2015). Since 1970, there has been an overall decline in the frequency of oil spills from tankers greater than7 tonnes, despite an increase in overall shipping frequency (ITOPF, 2019). This is shown on Figure 3.2.

Figure 3.1 Shipping Accidents in Canada, 2004 to 2013

NOTES: 1. SOURCE: ENERGY TRANSPORTATION AND TANKER SAFETY IN CANADA (JOHN, 2015). 2. DATA SOURCE: TRANSPORTATION BOARD OF CANADA (2014), STATISTICAL SUMMARY – MARINE OCCURRENCES 2013. RETRIEVED FROM: HTTPS://WWW.TC.GC.CA/MEDIA/DOCUMENTS/POLICY/STATS-ADDEND-2011-ENG.PDF.

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Figure 3.2 Seaborne Oil Trade and Oil Spills Greater Than 700 Tonnes, 1970 to 2013

NOTES: 1. SOURCE: ENERGY TRANSPORTATION AND TANKER SAFETY IN CANADA (JOHN, 2015). 2. DATA SOURCE: INTERNATIONAL TANKER OWNERS POLLUTION FEDERATION (2014). OIL TANKER SPILL STATISTICS 2013; UNCTAD (2013), UNCTADSTAT: WORLD SEABORNE TRADE BY TYPES OF CARGO AND COUNTRY GROUPS, ANNUAL, 1970-2011. We acknowledge that it is preferable to utilize a database that focusses on Canadian waters, however given the limited number of large ship-source spills in Canada and the unreliability of smaller spill reporting, this is not entirely possible (WSP, 2014). However, we believe that utilizing recent statistics (i.e. 2008 to 2018), may provide more current probabilities, as there has been a marked decline in accidents (with or without spills) over the recent decade (Figure 3.3).

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Figure 3.3 Shipping Accident Rates for Canadian Commercial Non-Fishing Vessels, 2008 to 2018.

NOTES: 1. SOURCE: STATISTICAL SUMMARY: MARINE TRANSPORATION OCCURRENCES IN 2018 (TSB, 2019).

3.3 GENERAL REPORT INQUIRIES

3.3.1 ACCIDENT TYPES AND PROBABILITIES

Table 5 of the ERC Report outlines the accident types that were assessed for this study. They include: collision, allision, ground, other (non-impact), and transfer error. Generally, the accident probability for other and transfer error is much higher than that of collision, allision, and grounding. Figure 3.4 provides a breakdown of the causes of medium and large spills since 1970. The majority of the spills have resulted from grounding (32%) and collision/allisions (30%). Gucma and Przywarty (2008) also indicate that the most contributing factors in ship accidents (inclusive of spills) are collisions between ships, groundings, and fire (Figure 3.5).

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Figure 3.4 Cause of Spills, 1970 to 2018

NOTES: 1. SOURCE: OIL TANKER SPILL STATISTICS 2018 (ITOPF, 2019).

Figure 3.5 Shipping Accidents by Accident Type, 2008 to 2017 Average and 2018

NOTES: 1. SOURCE: STATISTICAL SUMMARY: MARINE TRANSPORATION OCCURRENCES IN 2018 (TSB, 2019).

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3.3.2 PROBABILITIES OF BUNKER OUTFLOWS

Tables 11 and 13 of the ERC Report shows probabilities for bunker outflows resulting from impact and non-impact accidents. This is referring to the outflow of oil from the fuel tanks aboard the ships. Tables 11 and 13 include a probability associated with 0.001% to 100% bunker outflow (oil spillage from fuel tanks). It should be noted that the ships arriving at Milne Inlet will not have full bunker tanks, as they will be consuming fuel en-route to the Project (Fednav, 2019). Additionally, Tables 11 and 13 indicate that there is a 4% to 23% probability of an oil spill released from a bunker fuel tank from all vessel impact accidents, and a 2% to 20% probability from all vessel non-impact incidents. These probabilities imply to us that approximately one fifth to one quarter of all accidents/incidents would result in an oil spill from their bunkers. KP would like to discuss this high probability with the author, to understand the origin of these statistics.

3.3.3 DEVELOPMENT OF SPILL RETURN PERIODS:

The spill probability per accident values are not clearly defined and we would like to gain some clarity on their calculation. Based on an oil spill risk modeling study completed by the Puget Sound Institute, only 2 percent of all accidents resulted in an oil spill of any size (Puget Sound Institute, 2019). According to Table 5 of the ERC Report, this probability ranges from 4% for collision, allisions, and groundings to 92% for transfer error. We would like to better understand the data involved with the accident probability calculations. Additionally, we believe that the likelihood of collisions, allisions, and groundings are lower than the average due to overall lower vessel traffic, the use of well operated vessels in well charted deep waters, and the existing mitigation measures existing for the Project (discussed in Section 4). Once the spill size is introduced, the spill frequencies were difficult to reconcile. We attempted to follow the values from Table 6 through to Table 16, however we were unable to develop a spill frequency value equivalent to that of the ERC Report. The report stated that the per-transit probabilities are associated with spills of any volume (ERC, 2019). As such, it is unclear how these values were carried through, given that they are referring to varying volumes of spills. There are several categories and groupings presented throughout the ERC Report and some clarity on the calculations would be helpful to understand the logic of the return period calculations. For example, Table 17 indicates that the return period for a small spill (0.1 m3) is 1 in 440 years, however for a large spill (1,000 m3), the return period is 1 in 5.7 years. This seems counter-intuitive, and we would like to completely understand the process in developing these values.

4.0 BAFFINLAND’S SAFETY AND SPILL PREVENTION MEASURES

Within the ERC report, states that: “These likelihood and frequency of the additional spills could be lower if safety and spill prevention measures are implemented” (ERC, 2019). Baffinland has implemented several mitigation measures which will greatly reduce the chances of accidents, as well as oil spills. The following mitigation measures are included in the “Standing Instructions to Master” (Fednav, 2016), which is a document provided to all vessels that enter Milne Inlet. These measures include:

• Reduced speed of 9 knots. • The presence of Ice Navigators on board the vessels. This will reduce the chance of vessels making potentially dangerous contact with ice. • Vessel traffic is controlled by the Port Captain. Vessels are not permitted to enter the Regional Study Area (RSA) unless given specific instruction to do so.

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• The vessels are provided with specific way points which they must abide. • Vessels are monitored 24/7 and relevant parties are alerted if vessels speed or deviate from waypoints. • The availability of Tug Boats is in itself a mitigation measure for reducing risk of spills from the larger vessels. Baffinland maintains specific criteria regarding contracted vessels that will enter the Project area. Ore Carriers must be vetted by RightShip (a maritime risk management and environmental assessment organization) and must be less than 20 years old. This ensures that credible, well-maintained, and safe vessels are entering and departing Milne Inlet. In addition to ongoing updates to existing mitigation measures, Baffinland held a simulator meeting at the Marine Institute in St. John’s Newfoundland in April 2019 (Appendix B). This workshop evaluated the maneuverability of Capesize vessels in and out of the RSA in varying environmental conditions, with two-way traffic, to learn about the effect of the increased traffic expected in Phase 2. The workshop included representatives from Baffinland, Groupe Ocean (including a Tug Master), and Fednav (including an Ice Pilot). Various scenarios (including worst-case scenarios) were simulated. Some of the simulations which relate to the probability of an oil spill included: 1. How many vessels can safely anchor with a mixture of Panamax and Capesize vessels? 2. Review use of 2 additional anchorage locations in Milne Inlet. a. Can all 5 anchorages be utilized at one time with all the different combinations of vessel types and still provide a safe lane to transit in and out of the port? 3. For North/South transit between Ragged Island and Milne Inlet, at what points can Capesize and Panamax, or other vessel design, safely pass each other? 4. Role of escort Tug Boat for North/South transit between Ragged Island and Milne Inlet. The results from the majority of these scenarios indicated that the ships would be able to avoid an incident from occurring (collisions, grounding, etc.) (Fednav, 2019). A conclusion from a specific “worst case scenario” simulation indicated that there was a risk of a collision. As a result of this simulation, Baffinland put measures into place to ensure that vessels were not allowed to cross paths in this specific channel. This instruction is included in the Standing Instructions to Master and the Port Captain sends a reminder to all vessels before they enter the RSA (Fednav, 2019). Baffinland continues to review and update existing mitigation, including performing spills response exercises on site. The ERC Report stated that: “future spill frequencies are likely to go down if accident and spill prevention measures continue to be implemented and improved” (ERC, 2019), however it does not appear that the existing measures were incorporated in their calculations.

5.0 SUMMARY

Our review has established:

• The assumptions used to estimate the Tug Boat transit data may not be indicative of Project traffic values. • The data used to generate the spill probabilities extend back to 1980, and thus given the marked reduction in marine incidents since that time, the calculated probabilities may be overstated. • We are left with questions as to how the probabilities were calculated, and we would be pleased to engage with the author of the ERC Report to further discuss the following comments: o Tug Boat transit data for Phase 2.

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o The data utilized for probability statistics (1980 – 2010) may not represent improving current marine safety trends. o Clarity as to how the probabilities and frequencies of accidents and spills were calculated. ▪ Accident probabilities per transit. ▪ Spill probabilities per accident. ▪ Bunker outflow probabilities. ▪ Expected oil cargo and bunker spill frequencies by vessel type. o Recognition and inclusion of the mitigation measures that have been implemented by Baffinland. o Recognition and inclusion of Baffinland’s ongoing efforts Baffinland (i.e. the vessel traffic and anchorage simulation workshop or on-site spill response exercises).

Yours truly, Knight Piésold Ltd.

Prepared: Reviewed: Amber Blackwell, P.Geo. Richard Cook, P.Geo. (Ltd.) Project Geoscientist Specialist Scientist | Associate

Approval that this document adheres to the Knight Piésold Quality System:

Attachments: Appendix A Comments on Baffinland Oil Spill Probability: Updated Analysis for Phase 2 Expansion Proposal Vessel Traffic Appendix B Baffinland Vessel Traffic and Anchorage Study Final Report

References:

Baffinland Iron Mines Corporation (Baffinland), 2018. Addendum to the Final Environmental Impact Statement - Mary River Project - Phase 2 Proposal. NIRB File No. 08MN053. September. Det Norske Veritas (DNV-GL). 2011a. Final Report: Assessment of the Risk of Pollution from Marine Oil Spills in Australian Ports and Waters. Det Norske Veritas Project No. PP002916. Prepared for Australian Maritime Safety Authority. December 2011. 50 p. Det Norske Veritas (DNV-GL). 2011b. Ship Oil Spill Risk Models. Det Norske Veritas Project No. PP002916. Prepared for Australian Maritime Safety Authority. December 2011. 50 p.

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Environmental Research Consulting (ERC), 2019. Baffinland Oil Spill Probability: Updated Analysis for Phase 2 Expansion Proposal Vessel Traffic. Submitted to WWF-Canada. July 2019. Fednav Ltd., 2016. Standing Instructions and General Information for Masters of Vessels Loading at Milne Inlet Port. Fednav Ltd., 2019. Comments on Baffinland Oil Spill Probability: Updated Analysis for Phase 2 Expansion Proposal Vessel Traffic. Submitted to Knight Piésold. August 2019. Gucma L., Przywarty M., 2008. The Model of Oil Spills Due to Ship Collisions in Southern Baltic Area. Retrieved from: https://www.researchgate.net/publication/237467218_The_model_of_oil_spills_due_to_ship_colli sions_in_Southern_Baltic_Area (accessed October 13, 2019). International Tanker Owners Pollution Federation (ITOPF), 2019. Oil Tanker Spill Statistics 2018. Retrieved from: https://www.itopf.org/knowledge-resources/data-statistics/statistics/ (accessed October 13, 2019). John, P., 2015. Energy Transportation and Tanker Safety in Canada. Fraser Institute. Retrieved from: https://www.fraserinstitute.org/sites/default/files/energy-transportation-and-tanker-safety-in- canada.pdf. (accessed October 13, 2019). Puget Sound Institute, 2019. Oil Spill Risks by the Numbers. University of Washington, Encyclopedia of Puget Sound. March 2019. Retrieved from: https://www.eopugetsound.org/magazine/oil-spill-risk- numbers (accessed October 13, 2019). Statistics Canada, 2005. Evolution of the Deep-Sea Fleet That Supports Canada’s International Trade. Retrieved from: http://publications.gc.ca/Collection/Statcan/54F0002X/54F0002XIE.html (accessed October 13, 2019). The Glosten Associates, Inc. et al. 2013. Gateway Pacific Terminal Vessel Traffic and Risk Assessment Study: Accident Probability Statistics. Prepared by The Glosten Associates, Inc., Northern Economics, Inc., and Environmental Research Consulting. 22 March 2013. 84 p. Transportation Board of Canada (TSB), 2014. Transportation in Canada 2011 – Statistical Addendum. Retrieved from: https://www.tc.gc.ca/media/documents/policy/Stats-Addend-2011-eng.pdf. (accessed October 13, 2019). Transportation Board of Canada (TSB), 2019. Statistical summary: Marine transportation occurrences in 2018. Retrieved from: http://www.tsb.gc.ca/eng/stats/marine/2018/ssem-ssmo-2018.html (accessed October 13, 2019). United Nations Conference on Trade and Development [UNCTAD] (2013), UNCTADstat: World Seaborne Trade by Types of Cargo and Country Groups, Annual, 1970-2011. Retrieved from: http://unctadstat.unctad.org/wds/ReportFolders/reportFolders.aspx. (accessed October 13, 2019). WSP Canada Inc. (WSP), 2014. Risk Assessment for Marine Spills in Canadian Waters Phase 1, Oil Spills South of the 60th Parallel. Final Study Report Prepared for Transport Canada. January 2014. Ref. No. 131-17593-00. Rev. 0.

/ab

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Comments on Baffinland Oil Spill Probability: Updated Analysis for Phase 2 Expansion Proposal Vessel Traffic.

(Pages A-1 to A-3)

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29/08/2019 Tim Keane Courtney Legault

Comments on Baffinland Oil Spill Probability: Updated Analysis for Phase 2 Expansion Proposal Vessel Traffic

Page Comment Page 6, Table 1 - A definition of transits should be provided. - Tug boats will not do 292 transits, they stay in Milne Inlet providing docking services. They only enter and depart Milne Inlet once at the beginning and once at the end of the season. (Unless there is a safety issue)

Page 6, Table 2 - The ships arriving at Milne Inlet will not have their bunker tanks filled to capacity, as there are no fuel suppliers in Milne Inlet, and fuel will be consumed en route to Milne Inlet. - Ships will take bunkers prior to departure to Milne Inlet, and it is very rare that ships will fill their bunker tanks to capacity. - Shippers want to maximize the amount of cargo loaded on board, and the more fuel which is carried on board, the least amount of cargo they can load, thus less profits. - The volumes of fuel attributed to different ship types should be reviewed. In 2018 for example the average amount of fuel carried by Bulkcarriers serving Baffinland is about 1038 mt (on arrival at Milne) - In any case, cargo vessels have multiple tanks, and just as with tankers, it should be considered that only a portion of any volume onboard would be released in anything but a catastrophic situation - One possible mitigation measure is to limit the amount of fuel vessels carry when on the BIM trade. The minimum reasonable fuel load would be about 800 - 1000 mt. Page 9, Par. 2, - This line states that between 2% and 18% of vessel accidents may line 4-5 actually result in spillage, however there is no reference. - Thus it is difficult to know which type of ships which had accidents were involved in a spill, as well as the age of these ships. Page 20, Table - The results shown in some tables are difficult to reconcile. For 17 example, Table 17 indicates a 1 in 24,000 chance of a spill of .1 m3 but 1 in 310 for a 1000 m3 spill? Then a Total of 1 in 25. Can someone explain the methodology?

FEDNAV LIMITED 1000 de La Gauchetière Street West, Suite 3500 Montreal , Quebec Canada H3B 4W5

T 514.878.6500 www.fednav.com A-1 of 3

Comments :

This document states that vessel congestion is not likely a significant factor in Milne Inlet, and does not state other factors. However the odds of an ore carrier oil spill are 1 in 30 each year (which seems high in our view).

This document does not include the mitigation measures enforced by Baffinland which will greatly reduce the odds of an oil spill. These mitigation measures are included in the Standing Instructions to Master which is provided to all vessels calling Milne Inlet. Such measures include: - Reduced speed of 9 knots. - The presence of Ice Navigators on board the vessels. This will reduce the chances of vessels making potentially dangerous contact with ice. - Vessel traffic is controlled by the Port Captain. Vessels are not permitted to enter the RSA unless given specific instructions to do so. - The vessels are provided with specific way points which they must abide by. - Vessels are monitored 24/7 and relevant parties are alerted if vessels speed or deviate from waypoints. - The availability of tugs is in itself a mitigation measure for reducing risk of spills

In addition, when contracting vessels, BIM has the following criteria :

- Baffinland only contracts ore carriers which are vetted by RightShip. - Baffinland only contracts ore carriers less than 20 years old.

Furthermore, in April 2019 Baffinland held a simulator meeting at the Marine Institute in St John’s Newfoundland (see document Baffinland Vessel Traffic and Anchorage Study Final Report). For this simulation study, the institute worked with Baffinland to evaluate the maneuverability of Capesize vessels in and out of the RSA in varying environmental conditions, with two-way traffic, to learn about the effect of the increased traffic expected in Phase 2. During this meeting 18 different scenarios were simulated, some of which were “worst-case scenarios”. A description of each of these scenario as well as results and recommendations are included in the document.

Some of the simulations which relate to the probability of an oil spill include:

1) How many vessels can safely anchor with a mixture of Panamax and Capesize vessels?

2) Review use of 2 additional anchorage locations in Milne Inlet.

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T 514.878.6500 www.fednav.com A-2 of 3

i) Can all 5 anchorages be utilized at one time with all the different combinations of vessel types and still provide a safe lane to transit in and out of the port?

3) For North/South transit between Ragged Island and Milne Inlet, at what points can Capesize and Panamax, or other vessel design, safely pass each other?

4) Role of escort tug for North/South transit between Ragged Island and Milne Inlet.

It was found that during the majority of these scenarios, the ships would be able to avoid an incident from occurring (collision, grounding, etc). During one simulation however (Day 2 RUN # 2 from document), it was found that the chance of a collision during this worst case scenario was more likely. Thus Baffinland put measures into place to ensure that vessels were not allowed to cross paths in this specific channel. This instruction is included in the Standing Instructions to Master and the Port Captain sends a reminder to all vessels before they enter the RSA.

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T 514.878.6500 www.fednav.com A-3 of 3

Baffinland Vessel Traffic and Anchorage Study Final Report

(Pages B-1 to B-8)

October 15, 2019 NB19-00772

Memo

TO: Mark D'Aguiar, DFO From: Lou Kamermans, Director Sustainable Jacquie Bastick, Parks Canada Development Baffinland Iron Mines Corporation

File: Baffinland Vessel Traffic and Anchorage Date: May 13, 2019 Study Final Report

INTRODUCTION

This memo presents a summary of the results of the Vessel Traffic and Anchorage Study prepared by the Centre for Marine Simulation (CMS), which is part of the Fisheries and Marine Institute of Memorial University of Newfoundland.

CMS worked with Baffinland and its partners to evaluate the feasibility of maneuvering Capesize vessels in and out of Milne Inlet and the effect that this increased traffic would have on tug use and on anchorages in the area. Anchorage locations are shown on Figures 1 and 2 (Attachment 1). CMS’s geographic database with Milne Inlet was modified and generic Capesize and Panamax ship models were used to closely match future operations. A tug model was developed to simulate the OCEAN Tundra vessel currently in use.

The study looked at several questions, presented in Table 1, relating to the use of Capesize vessels and the increased traffic flowing in and out of Milne Inlet that is planned for Phase 2. Table 1 Summary of Study Questions

Subject Question How many vessels can safely anchor knowing with a mixture of Ragged Island Anchorages Panamax and Capesize Vessels? Operational implications of not being able Only vessels that can drift in Eclipse Sound are those that to use Eclipse Sound for controlled drifting previously dropped anchor at Ragged Island. Can all 5 anchorages be used at one time with all the different Review use of 2 additional anchorage combinations of vessel types and still provide a safe lane to locations in Milne Inlet transit in and out of the port? For North/South transit between Ragged Island and Milne Inlet, Safe passage for North/South transit at what points can Capesize and Panamax, or other vessel between Ragged Island and Milne Inlet designs, safely pass each other? • What does it mean for vessel traffic management in Milne Inlet and ensuring maximum berth utilization? North/South convoy in open water • How could anchorages be used to hold loaded vessels waiting for convoy versus vessels waiting to load? Role of escort tug for North/South transit Is one enough? Especially for Capesize vessels? between Ragged Island and Milne Inlet

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Reference: Baffinland Vessel Traffic and Anchorage Study Final Report

METHODS

The geographic database of Milne Inlet was modified to include the newest terminal plan and chart data; several in-house vessels and vendor-supplied vessels were also provided. The simulation area was approximately 220 km2 and was designed for docking at both Milne Inlet docks.

For ship model development, CMS used in-house ownship vessels, specifically a Capesize and Panamax bulk carrier. Other vessels used included a product tanker and sealift vessel.

CMS developed a numerical model of the OCEAN Tundra, a 110 tonne bollard pull vessel (tug) that currently operates in Milne Inlet. The escort tug’s performance was benchmarked against client- supported data and from International Maritime Organization (IMO) standards. It was also tested through the HDMT and Polaris interfaces. As part of CMS’s quality assurance program, internal validation tests were performed on the OCEAN Tundra tug. These tests are designed to ensure that the vessel is performing adequately based on its characteristics and client-supported information. External validation was also conducted and provided a more subjective evaluation of the tug from an individual who has first hand experience operating the vessel.

The simulation exercises took place in St.John’s, NL at the CMS facility from April 15-18th, 2019. All scenarios were developed in consultation with Baffinland and other partner representatives. Within the 4 days of simulation, 18 runs were executed and recorded, these are summarized in Attachment 2. All exercises were completed in real time, and the same instructor was used for consistency. Results

The findings from the simulation run profiles are summarized below:

• North/South bound vessel traffic should not cross in the area of Stephen’s Island or in the area between Bruce Island and Poirier Island • North/South bound Capesize vessel traffic from Ragged Island to Milne Inlet, other than areas identified above, have plenty of navigable space for safe transit • Vessel control issues were identified in conditions of northerly winds of 30 knots when the vessel is transiting at operational speed (9 knots). Control was improved by increasing speed to 10-11 knots • Milne Inlet channel at Cape Kwaunang could be an area of congestion as traffic increases • A standby tug should always be considered for the area just south of Bruce Head and should consist of a double crew; this will enable the tug to respond immediately to emergencies • Vessel traffic service will be an important requirement for safe and efficient vessel transit movements • Tug redundancy at the Milne Inlet terminal is considered essential • Ice management will be an important requirement for vessel traffic service; ice movements should be continually tracked, especially from Stephen’s Island to the terminal • Anchorages Nos. 3 and 5 were determined to be unsuitable

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Mark D'Aguiar, DFO, Jacquie Bastick, Parks Canada Page 3 of 8

Reference: Baffinland Vessel Traffic and Anchorage Study Final Report

• The three anchorages at Ragged Island are considered suitable for one Panamax and two Capesize vessels • Two Capesize vessels cannot anchor safely together at Anchorage No. 4. Another location would need to be identified as an alternate location for Capesize standby, specifically in cases where the operation is delayed, and the Capesize anchorages at Ragged Island are already occupied. Eclipse Sound was noted as the safest alternative. • An indirect tow maneuver is very effective to stop a disabled Capesize vessel in loaded condition. The maneuver should only be facilitated with a capable tug and experienced pilot. Formal training was suggested for pilots and tug masters.

CONCLUSION

The vessel traffic study provided information on the feasibility of Capesize vessels using current anchorage locations, the addition and use of two other anchorage locations, the feasibility of North and South bound transits between Ragged Island and Milne Inlet, the need and role of an escort and standby tugs, and the impact of increased traffic on vessel traffic management.

This information will be used to guide decision making and procedure development related to shipping.

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Reference: Baffinland Vessel Traffic and Anchorage Study Final Report

Attachment A Figures

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Reference: Baffinland Vessel Traffic and Anchorage Study Final Report

Attachment 2 Summary of Simulation Scenarios

Day/Run Description Day 1 RUN # 1 Southbound Ballast Capesize Vessel and Northbound Loaded Capesize Vessel Passing East of Stephen’s Island Day 1 RUN # 2 Southbound Ballast Capesize Vessel and Northbound Loaded Capesize Vessel Passing East of Stephen’s Island Day 1 RUN # 3 Southbound Ballast Capesize Vessel and Northbound Loaded Capesize Vessel Passing between Bruce Head and Poirier Island Day 1 RUN # 4 Southbound Ballast Capesize Vessel and Northbound Loaded Capesize Vessel Passing in Milne Inlet Channel at Cape Kwaunang Day 2 RUN # 1 Southbound Ballast Capesize Vessel and Northbound Loaded Capesize Vessel Passing between Bruce Head and Poirier Island. Inbound Cape Loses Steering and Standby Tug Dispatched to Put a Line on the Vessel. Day 2 RUN # 2 Southbound Ballast Capesize Vessel and Northbound Loaded Capesize Vessel Passing between Bruce Head and Poirier Island. Outbound Cape is Being Escorted by Tug and Blacks Out During Transit. Day 2 RUN # 3 Southbound Ballast Capesize Vessel and Northbound Loaded Capesize Vessel Transiting between Bruce Head and Poirier Island. Outbound Cape Blacks Out During Transit and Nearby Tug Asked to Assist Day 2 RUN # 4 Southbound Ballast Capesize Vessel and Northbound Loaded Capesize Vessel Transiting between Bruce Head and Poirier Island. Outbound Cape Blacks Out During Transit and Nearby Tug Asked to Assist (Delayed 10 Minutes Before Departing) Day 2 RUN # 5 Inbound Ballast and Outbound Loaded Capesize Vessels Meeting Near Entrance of Eclipse Sound with Ice and Sea Smoke. Day 2 RUN # 6 Milne Inlet Vessel Traffic Service Coordinating an Inbound Ballasted Capesize Vessel and two Outbound Loaded Panamax Vessels in the Vicinity of Bruce Head Day 3 RUN # 1 Ballast Panamax at Anchor on the Eastern Outer Anchorage #5. Day 3 RUN # 2 Ballast Panamax at Anchor on Anchorage #3. Day 3 RUN # 3 All Anchorages in Milne Inlet Occupied. Two Panamax on West Anchorages and Capesize and Product on East Anchorages. Flow of Traffic Begins; Inbound Panamax Vessel Approaching for Outer West Anchorage; Outer West Anchorage Panamax Moving to Inner West Anchorage; and Inner West Anchorage Vessel Moving to Panamax Terminal Berth with the Assistance of Two Tugs. Black Out Occurs on Outer West Anchorage Panamax Vessel as it Moves to Inner West Anchorage. Day 3 RUN # 4 Two Capesize Vessels at Milne Inlet East Anchorage in Drifting Position as the Weather Transitions. Sealift and Tanker Vessels Included. Day 4 RUN # 1 Ballast Capesize Vessel Approach to Ragged Island Anchorage #2 with One Panamax and One Capesize Vessel at Anchorage #1 and #3, respectively.

B-7 of 8 May 13, 2019

Mark D'Aguiar, DFO, Jacquie Bastick, Parks Canada Page 8 of 8

Reference: Baffinland Vessel Traffic and Anchorage Study Final Report

Day/Run Description Day 4 RUN # 2 Loaded Outbound Capesize with Tug Escort out of Milne Inlet Channel. Capesize Vessel Blacks out in Channel and Tug Required to Turn Vessel Around Using Indirect Tow Manoeuvre Day 4 RUN # 3 Two Outbound Vessels, a Capesize and Panamax, Leaving Milne Inlet Anchorages and Transiting North with Incoming Icebergs in the Channel Day 4 RUN # 4 Inbound Ballast and Outbound Loaded Capesize Vessels Meeting West of Stephen’s Island

B-8 of 8 Mary River Project Phase 2 Proposal

APPENDIX N ATTACHMENTS RELATED TO THE MARINE ENVIRONMENT

Mary River Project Phase 2 Proposal

ATTACHMENT 1: MEMO CLARIFICATION RESPECTING SHIPPING THROUGH THE NORTHWEST PASSAGE

Ryan Barry Sept. 20 2019 Executive Director Nunavut Impact Review Board

Re: Clarification respecting "Mary River Project: Environmental Review of Shipping Through the Northwest Passage (Stantec, July 12, 2019)"

Dear Ryan,

The purpose of this letter is to provide clarity with respect to Baffinland’s intentions regarding shipping through the Northwest Passage (NWP) and Navy Board Inlet.

Based on an article that appeared in Nunatsiaq News on September 5, 2019, we understand that there are some questions respecting a document filed by Baffinland with NIRB, "Mary River Project: Environmental Review of Shipping Through the Northwest Passage (Stantec, July 12, 2019)" (the Northwest Passage Report). The use of Navy Board Inlet and the NWP as potential alternative routes was identified through the Phase 2 process. During the Technical Review period of the Phase 2 Proposal, Baffinland was asked by Fisheries and Oceans Canada and the Government of Nunavut to provide additional information about alternative marine shipping routes through Navy Board Inlet and the NWP. Baffinland committed to provide additional information and filed the Northwest Passage Report with NIRB on July 12, 2019 in order to fulfil its commitments. The Northwest Passage Report was not provided for the purpose of seeking NIRB permission to use Navy Board Inlet or the NWP for the Phase 2 Project at this time, but rather to support ongoing conversations respecting optional alternative shipping routes.

For clarity, Baffinland is not seeking permission from NIRB to proceed with shipping via Navy Board Inlet or the NWP as part of the Phase 2 Project Proposal.

What follows is intended to provide clarity on potential future use of Navy Board Inlet and the NWP:

• Use of Navy Board Inlet is highly unlikely unless Baffinland gets a specific request to use it from the community. Through the life of the project and the Phase 2 Project Proposal NIRB reconsideration process, Navy Board Inlet has been identified to Baffinland by community members as a potential mitigation for future consideration that could reduce the number of vessel transits in front of Pond Inlet. Should future community consultation identify that Baffinland should give serious consideration to revising the shipping route to include Navy Board Inlet, prior to utilizing Navy Board Inlet, Baffinland would seek advice from NIRB and NPC following the established policies relating to project modifications. Baffinland would follow any required regulatory process as identified.

• As discussed during technical meetings, Baffinland continues to consider the issue of access to Eastern markets for iron ore. Should Baffinland identify the need to advance discussions regarding the issue of access to Eastern markets for iron ore, Baffinland may develop a pilot

2275 Upper Middle Road East, Suite 300 | Oakville, ON, Canada L6H 0C3 Main: 416.364.8820 | Fax: 416.364.0193 | www.baffinland.com

study in future which would send limited numbers of test vessels to help evaluate feasibility of this option. Should the pilot study support further consideration of requesting permission for Baffinland to use the NWP as a permitted Mary River Project shipping route, Baffinland may seek approval for use of this route in the future. For both the pilot study and any future route revision, Baffinland would seek advice from NIRB and NPC following the established policies relating to project modifications. Baffinland would follow any required regulatory process as identified.

Should you have additional questions about this letter please do not hesitate to contact me directly.

Sincerely,

Megan Lord-Hoyle Vice-President, Sustainable Development

2275 Upper Middle Road East, Suite 300 | Oakville, ON, Canada L6H 0C3 Main: 416.364.8820 | Fax: 416.364.0193 | www.baffinland.com

2 Mary River Project Phase 2 Proposal

ATTACHMENT 2: TECHNICAL MEMO ANALYSIS OF 2018 NARWHAL TAGGING DATA DURING FALL SHOULDER SEASON

TECHNICAL MEMORANDUM DATE 15 October 2019 Reference No. 1663724-162-TM-Rev0-12000

TO Megan Lord-Hoyle Baffinland Iron Mines Corporation CC

FROM Phil Rouget EMAIL [email protected]

MOVEMENT OF TAGGED NARWHAL (MONODON MONOCEROS) IN RELATION TO ICEBREAKING OPERATIONS AND ASSOCIATED VESSEL TRAFFIC DURING THE 2018 FALL SHOULDER SEASON

Golder Associates (Golder) partnered with Fisheries and Oceans Canada (DFO) in 2017 and 2018 to undertake a narwhal tagging study based out of Tremblay Sound in the North Baffin Region of Nunavut. The collaborative research program involved Golder expanding on DFO’s existing tagging program by supplying additional biologging tags that were customized to address Baffinland’s Project-specific study objectives related to understanding behavioural response of narwhal to vessel traffic.

This technical memorandum presents a limited scope relative to this program and has been prepared in response to commitments made by Baffinland Iron Mines Corporation (Baffinland) to assess narwhal (Monodon monoceros) behavioral response to Project-related icebreaking operations in support of the Mary River Project (the Project) Phase 2 proposal.

1.0 BACKGROUND Two narwhal were tagged with a combination of GPS Fastloc location tags (CTD-SRDL; SMRU), pop-up archival dive tow tags (MiniPAT/Mk10PAT; Wildlife Computers), and passive acoustic recording tags (Acousonde 3MB; Greenridge Sciences) during the 2018 Tremblay Sound Narwhal Tagging Program. Both individuals were tagged on 17 August 2018, with narwhal NW21 transmitting ARGOS location data until 08 October 2018 (53 days) and narwhal NW22 transmitting GPS Fastloc location data until 02 November 2018 (76 days). Dive and acoustic data collected for NW21 (24 and 3 days, respectively) and NW22 (20 and 7 days, respectively) did not extend into the fall shoulder season. Therefore, to assess narwhal behavioral response to icebreaking operations and associated vessel traffic, this technical memorandum is focused solely on narwhal positional data collected between 29 September and 17 October 2018, coincident with the period the MSV Botnica (97-m icebreaker) was conducting Project-related icebreaking operations along the Northern Shipping Route in the Regional Study Area (RSA) (Figure 1).

Golder Associates Ltd. 2nd floor, 3795 Carey Road, Victoria, British Columbia, V8Z 6T8, Canada T: +1 250 881 7372 F: +1 250 881 7470

Golder and the G logo are trademarks of Golder Associates Corporation golder.com

Megan Lord-Hoyle Reference No. 1663724-162-TM-Rev0-12000 Baffinland Iron Mines Corporation 15 October 2019

Given the limited data presented in this report, the sample size is insufficient for a comprehensive statistical analysis to be undertaken. Instead, narwhal interactions with icebreaking operations and associated vessel traffic are presented for the purpose of visualizing and qualitatively discussing potential behavioral responses of narwhal to icebreaker transits in the RSA during the 2018 fall shoulder season. Statistical analysis of the full extent of the tagging data (i.e., all tags) will be undertaken as part of the 2017/2018 integrated tagging report, which will build on information presented in the 2017 Narwhal Tagging Study – Technical Data Report (Golder 2018). The integrated tagging report will be provided in draft form to the Marine Environmental Working Group (MEWG) in Q1 of 2020.

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P 1663724 30000 1 0 Megan Lord-Hoyle Reference No. 1663724-162-TM-Rev0-12000 Baffinland Iron Mines Corporation 15 October 2019

2.0 METHODS 2.1 Narwhal GPS Data Management Narwhal positional data presented in this technical memorandum were obtained from CTD-SRDL GPS location tags. The CTD-SRDL tag is an ARGOS satellite tag manufactured by Sea Mammal Research Unit (SMRU) Instrumentation that includes sensors to measure horizontal and vertical movement, as well as record water temperature, conductivity, and wet/dry periods to decipher surfacing events. Data collected by the CTD-SRDL tags are summarized and compressed for transmission each time the animal surfaces. Depth data collected by the CTD-SRDL is associated with individual dives and pre-determined depth intervals, not recorded at specific time intervals as in the MiniPAT, Mk10-Pat and Splash-10 tags (Wildlife Computers). Both CTD-SRDL tags were attached to narwhal using a ‘backpack’ style design with three nylon pins inserted subdermally on the back of the animal.

To reduce erroneous locations, GPS data were filtered to remove all narwhal positions calculated from less than six satellite positions and for which the residual value was ≤30 (Dujon et al. 2014). Where gaps in GPS locations were evident, narwhal positional data were interpolated at 1-min intervals and only raw GPS data or interpolated data within 20 min from a raw GPS point were used for this study. Further details on the approach undertaken to manage narwhal positional data is presented in Golder (2018).

Although both tags deployed on NW21 and NW22 included Fastloc GPS capability, only lower-resolution ARGOS location data were available for NW21 during the fall shoulder season (Fastloc data stopped transmitting several weeks earlier). As such, daily movements of both animals in relation to icebreaking operations and associated vessels are presented for visualization purposes (Appendix A) but location data associated with NW21 is of insufficient resolution to assess behavioral responses during the animal’s closest point of approach (CPA) with icebreaking vessels (see Section 2.3).

2.2 Vessel AIS Data Management Vessel GPS data used in this study were a combination of shore-based and satellite-based Automated Identification System (AIS) data, which provided accurate real-time data on all large vessel passages along the Northern Shipping Route during the 2018 shipping season. AIS is mandatory for all commercial vessels >300 gross tonnage and passenger ships. A shore-based AIS station was installed on a high cliff near Bruce Head, which provided a continuous record of ship positions within line-of-sight of the station, inclusive of Milne Inlet (north and south) and portions of Eclipse Sound and Navy Board Inlet. A second shore-based AIS station in Pond Inlet provided a continuous record of ship positions for the eastern portion of Eclipse Sound and Pond Inlet. Satellite-based AIS data, acquired from exactEarth Ltd1, was used to supplement vessel position information during periods when there were gaps in the shore-based data. The temporal resolution of the shore-based AIS data was approximately five seconds, whereas the satellite-based AIS data exhibited longer interposition times (ten minutes on average), resulting in a comparatively lower spatial and temporal resolution with respect to vessel position. To best represent vessel movement in the along the Northern Shipping Route during periods when only satellite-based AIS was available, vessel position was interpolated at one-minute intervals.

1 exactEarth Ltd. Is a data services company that leverages advanced microsatellite technology and globally deployed ground systems to deliver exactAIS™, a global vessel tracking and monitoring system based on world leading space-based advanced AIS detection technology.

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Megan Lord-Hoyle Reference No. 1663724-162-TM-Rev0-12000 Baffinland Iron Mines Corporation 15 October 2019

Vessels were classified into three categories – small vessels (<50 m in length), medium vessels (≥50 m but <100 m in length), and large vessels (≥100 m in length). For non-icebreaking vessels present in the RSA, only large vessels (≥100 m in length) were used in subsequent analyses. Two icebreaking vessels were present in the RSA during the 2018 fall shoulder season, one procured by Baffinland to provide escort to ore carriers (the MSV Botnica), and another 88-m icebreaker that was not Project-related (Canadian Coast Guard Service (CCGS) Terry Fox). AIS data were filtered to retain only transiting vessels (speed ≥1 knot), to avoid representing interactions between narwhal and stationary vessels.

2.3 Identification of Closest Point of Approach (CPA) Events Horizontal movements of the single narwhal (NW22) outfitted with a GPS Fastloc tag were analyzed in relation to AIS vessel track data to determine the location and time of narwhal-vessel interactions. Using customized functions in R v. 3.6.1 (R Core Team 2019), the closest point of approach (CPA) was identified for all ‘events2’ in which vessels transiting along the Northern Shipping Route were within 54.4 km of the animal. This distance (54.4 km) was selected based on acoustic modeling results by JASCO Applied Sciences (Quijano et al. 2019) which predicted icebreaker noise would extend above the 120 dB re: 1µPa (SPLrms) disturbance threshold for distances up to 54.4 km (Rmax), based on a modelled scenario of an icebreaker escorting two Capesize ore carriers through Eclipse Sound in 10/10 ice concentration.

For each narwhal GPS position, all vessel AIS positions recorded within the preceding or following 30 minutes of the timestamp were retrieved and the nearest AIS position to a given narwhal location was identified. Of these, the points in time when the distance between the narwhal and the vessel decreased and then increased were retrieved as potential CPA points. These “potential” CPA points were further assessed in a second step, so that only a single CPA point within each 6-h time period was retained. A CPA event was then defined as the ±3 h time window around each CPA timestamp. As a quality control measure, animations were created depicting real-time movements of NW22 in relation to transiting ships over the period of interest (29 September– 17 October 2018). Visual examination of the animations allowed the analyst to confirm individual CPA events and qualitatively assess the movements of NW22 in relation to icebreaking operations and associated vessel traffic in greater detail. For each CPA event (i.e., each narwhal-vessel interaction within ±3 h from a CPA point), two plots were then generated. The first plot included a zoomed-out map depicting the horizontal relocations of individual narwhal in relation to the vessel in the ±3 h from the CPA timestamp. The second plot included a zoomed-in map showing the finer resolution movements for the same narwhal during the same time period. All analyses and plotting were performed in R v.3.6.1 (R Core Team 2019).

3.0 RESULTS 3.1 Narwhal Interactions with All Vessel Types Both NW21 and NW22 remained in the vicinity of the Northern Shipping Route for extended periods during the 2018 fall shoulder season, despite being exposed to thickening ice conditions, icebreaking operations and associated vessel traffic. Although the ARGOS location data associated with NW21 were not of sufficient resolution to assess fine scale movements of this animal in relation to icebreaker movements, it is evident from

2 Event = the 6 h time period associated with each CPA (3 h before and 3 h after CPA), where the whale-vessel distance was ≤54.4 km along the Northern Shipping Route. Events more than 3 h apart, even of the same narwhal with the same vessel, are considered different events.

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Megan Lord-Hoyle Reference No. 1663724-162-TM-Rev0-12000 Baffinland Iron Mines Corporation 15 October 2019

the daily narwhal tracks presented in Figures A-1 to A-19 (Appendix A) that exposure to icebreaker and ship traffic during this time did not result in displacement of either narwhal from the RSA.

In general, NW22 had multiple close encounters with all vessel types throughout the fall shoulder season and did not appear to actively avoid icebreaking operations and associated vessel traffic as the season progressed (Figure 2). A total of 84 CPA events were identified in which NW22 was within 54.4 km of active vessel transits. Of these, 26 events were with icebreakers, 47 with ore carriers, 6 with fuel tankers, and 5 with cargo vessels. NW22’s closest encounters with the different types of Project vessels were as follows:  Icebreaker: 0.84 km (15 October 2018; MSV Botnica)  Ore carrier: 1.66 km (02 October 2018; Nordic Orion),  Fuel tanker: 4.25 km (14 October 2018; Sarah Desgagnés)  Cargo vessel: 1.32 km (10 October 2018; Zelada Desgagnés).

Figure 2: Closest points of approach (CPAs) of NW22 with different vessel classes during the 2018 Fall shoulder season (29 September - 17 October 2018)

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Megan Lord-Hoyle Reference No. 1663724-162-TM-Rev0-12000 Baffinland Iron Mines Corporation 15 October 2019

3.2 Narwhal Interactions with Icebreaking Operations Of the total 84 CPA events identified for NW22 within 54.4 km from active vessel transits, 25 events occurred in relation to icebreaking transits undertaken by the MSV Botnica and one event occurred in relation to icebreaking transits by the CCGS Terry Fox (Table 1; Figure 3 through Figure 11. Other Project-related vessels present during close encounters of NW22 with icebreaker transits are noted in Table 1 and presented as black hatched tracks in Figure 3 through Figure 11. In general, each of the 26 CPA events identified represents the closest encounter of NW22 with icebreaking operations during one active vessel transit in/out of Eclipse Sound, although transits by the icebreaker and associated vessel traffic did not always extend the full extent of the route between Milne Port and the eastern edge of the RSA (e.g. CPA events 1 and 7). The distance between NW22 and an icebreaker during active transits (CPA < 54.4 km) ranged between 0.84 km and 52.97 km.

Table 1: Closest point of approach (CPA) events of NW22 within 54.4 km of icebreaking vessels. All CPA events presented are interactions of NW22 with the MSV Botnica, except for CPA event #6 which is an interaction of NW22 with the CCGS Terry Fox

CPA Date Time Average CPA Ice Escort / Other Vessels Event (UTC) Vessel Distance Concentration Present Speed (km) @ CPA (kts)

1 30 September 5:16:24 8.1 32.47 < 1/10 Eastward with Golden Ice 2018 until CPA, then turned back westward while Golden Ice continued out of RSA.

2 1 October 2018 20:29:31 8.3 3.60 7-8/10 Eastward with NS Yakutia.

3 3 October 2018 02:43:24 8.8 14.21 < 1/10 Westward with Sarah Desgagnés; Golden Opportunity also nearby, heading westward; Nordic Orion also nearby, heading eastward.

4 3 October 2018 09:59:24 8.6 11.06 9-10/10 Eastward without escort; Golden Pearl also nearby, heading westward.

5 4 October 2018 04:27:24 8.7 12.78 9-10/10 Westward without escort. CCGS Terry Fox with Kitikmeot W and W also nearby, heading south from Navy Board Inlet; Nordpol also nearby.

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Megan Lord-Hoyle Reference No. 1663724-162-TM-Rev0-12000 Baffinland Iron Mines Corporation 15 October 2019

CPA Date Time Average CPA Ice Escort / Other Vessels Event (UTC) Vessel Distance Concentration Present Speed (km) @ CPA (kts)

6 4 October 2018 06:46:24 6.2 22.69 9-10/10 South and then eastward with Kitikmeot W and Qikiqtaaluk W; Botnica also nearby, heading westward; Nordpol also nearby.

7 5 October 2018 1:30:24 7.9 36.58 9-10/10 Eastward with Golden Opportunity until CPA and then westward with Golden Amber.

8 6 October 2018 10:32:24 8.3 16.54 9-10/10 Eastward with Golden Pearl; Nordic Odin also nearby.

9 6 October 2018 15:04:24 8.4 23.99 9-10/10 Westward3 without escort (departed Golden Pearl in middle of Eclipse Sound to return west). Nordic Odin also nearby.

10 7 October 2018 12:34:24 8.1 25.01 9-10/10 Eastward with Nordpol; Nordic Odin also nearby.

11 7 October 2018 18:26:24 8.3 28.61 9-10/10 Westward without escort (departed Nordpol in middle of Eclipse Sound to return west).

12 8 October 2018 12:56:24 8.4 6.96 9-10/10 Eastward with Golden Amber

13 8 October 2018 17:48:36 8.5 5.78 9-10/10 Westward without escort; Golden Amber moving eastward.

14 9 October 2018 14:51:24 6.9 4.23 9-10/10 Eastward with Nordic Olympic; Nordic Odyssey and Arkadia also nearby.

3 Note that the arrow showing vessel direction of travel in Figure 5 does not point west due to the initial part of the track being oriented eastward.

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Megan Lord-Hoyle Reference No. 1663724-162-TM-Rev0-12000 Baffinland Iron Mines Corporation 15 October 2019

CPA Date Time Average CPA Ice Escort / Other Vessels Event (UTC) Vessel Distance Concentration Present Speed (km) @ CPA (kts)

15 10 October 2018 20:02:24 7.0 0.95 9-10/10 Westward with Zelada Desgagnés; Nordic Odyssey and Arkadia also nearby.

16 11 October 2018 19:51:24 6.7 2.11 9-10/10 Eastward without escort; Nordic Odyssey and Arkadia also nearby.

17 12 October 2018 15:23:29 7.1 2.74 9-10/10 Westward with Nordic Oshima; Nordic Odyssey and Arkadia also nearby.

18 13 October 2018 11:10:24 7.7 4.37 9-10/10 Eastward without escort.

19 13 October 2018 20:34:24 7.8 5.14 9-10/10 Westward with Qamutik; Nordic Odyssey and Arkadia also nearby.

20 14 October 2018 15:39:24 8.3 4.11 9-10/10 Eastward with Sarah Desgagnés. Nordic Odyssey also nearby.

21 15 October 2018 1:12:24 8.1 0.84 9-10/10 Westward without escort. Nordic Odyssey also nearby.

22 15 October 2018 17:55:24 6.4 4.30 9-10/10 Eastward with Nordic Odin.

23 16 October 2018 04:02:24 7.9 2.53 9-10/10 Westward without escort.

24 16 October 2018 17:30:24 6.5 3.64 9-10/10 Eastward with Nordic Oshima

25 17 October 2018 02:39:24 8.2 10.02 9-10/10 Westward without escort; Zelada Desgagnés also nearby.

26 17 October 2018 22:36:24 7.6 52.97 7-8/10 Eastward with Arkadia and Zelada Desgagnés

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Megan Lord-Hoyle Reference No. 1663724-162-TM-Rev0-12000 Baffinland Iron Mines Corporation 15 October 2019

Figure 3: Closest point of approach (CPA) events of NW22 within 54.4 km of icebreaking operations and associated vessel traffic during the 2018 fall shoulder season (29 September - 17 October 2018; CPA events 1 through 3). The left panel shows the track of NW22 (thick line, color-coded for time) in relation to the icebreaker track (thin line, color- coded for time; average speed specified) and associated vessel tracks (black hatched lines; vessel names specified). The right panel is zoomed in to better illustrate the fine-scale movements of NW22. The CPA between NW22 and the icebreaking vessel is represented by a red dot on both the narwhal and the vessel tracks. Daily ice concentrations are also provided.

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Megan Lord-Hoyle Reference No. 1663724-162-TM-Rev0-12000 Baffinland Iron Mines Corporation 15 October 2019

Figure 4: Closest point of approach (CPA) events of NW22 within 54.4 km of icebreaking operations and associated vessel traffic during the 2018 fall shoulder season (29 September - 17 October 2018; CPA events 4 through 6). The left panel shows the track of NW22 (thick line, color-coded for time) in relation to the icebreaker track (thin line, color- coded for time; average speed specified) and associated vessel tracks (black hatched lines; vessel names specified). The right panel is zoomed in to better illustrate the fine-scale movements of NW22. The CPA between NW22 and the icebreaking vessel is represented by a red dot on both the narwhal and the vessel tracks. Daily ice concentrations are also provided.

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Megan Lord-Hoyle Reference No. 1663724-162-TM-Rev0-12000 Baffinland Iron Mines Corporation 15 October 2019

Figure 5: Closest point of approach (CPA) events of NW22 within 54.4 km of icebreaking operations and associated vessel traffic during the 2018 fall shoulder season (29 September - 17 October 2018; CPA events 7 through 9). The left panel shows the track of NW22 (thick line, color-coded for time) in relation to the icebreaker track (thin line, color- coded for time; average speed specified) and associated vessel tracks (black hatched lines; vessel names specified). The right panel is zoomed in to better illustrate the fine-scale movements of NW22. The CPA between NW22 and the icebreaking vessel is represented by a red dot on both the narwhal and the vessel tracks. Daily ice concentrations are also provided.

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Megan Lord-Hoyle Reference No. 1663724-162-TM-Rev0-12000 Baffinland Iron Mines Corporation 15 October 2019

Figure 6: Closest point of approach (CPA) events of NW22 within 54.4 km of icebreaking operations and associated vessel traffic during the 2018 fall shoulder season (29 September - 17 October 2018; CPA events 10 through 12). The left panel shows the track of NW22 (thick line, color-coded for time) in relation to the icebreaker track (thin line, color- coded for time; average speed specified) and associated vessel tracks (black hatched lines; vessel names specified). The right panel is zoomed in to better illustrate the fine-scale movements of NW22. The CPA between NW22 and the icebreaking vessel is represented by a red dot on both the narwhal and the vessel tracks. Daily ice concentrations are also provided.

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Megan Lord-Hoyle Reference No. 1663724-162-TM-Rev0-12000 Baffinland Iron Mines Corporation 15 October 2019

Figure 7: Closest point of approach (CPA) events of NW22 within 54.4 km of icebreaking operations and associated vessel traffic during the 2018 fall shoulder season (29 September - 17 October 2018; CPA events 13 through 15). The left panel shows the track of NW22 (thick line, color-coded for time) in relation to the icebreaker track (thin line, color- coded for time; average speed specified) and associated vessel tracks (black hatched lines; vessel names specified). The right panel is zoomed in to better illustrate the fine-scale movements of NW22. The CPA between NW22 and the icebreaking vessel is represented by a red dot on both the narwhal and the vessel tracks. Daily ice concentrations are also provided.

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Megan Lord-Hoyle Reference No. 1663724-162-TM-Rev0-12000 Baffinland Iron Mines Corporation 15 October 2019

Figure 8: Closest point of approach (CPA) events of NW22 within 54.4 km of icebreaking operations and associated vessel traffic during the 2018 fall shoulder season (29 September - 17 October 2018; CPA events 16 through 18). The left panel shows the track of NW22 (thick line, color-coded for time) in relation to the icebreaker track (thin line, color- coded for time; average speed specified) and associated vessel tracks (black hatched lines; vessel names specified). The right panel is zoomed in to better illustrate the fine-scale movements of NW22. The CPA between NW22 and the icebreaking vessel is represented by a red dot on both the narwhal and the vessel tracks. Daily ice concentrations are also provided.

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Figure 9: Closest point of approach (CPA) events of NW22 within 54.4 km of icebreaking operations and associated vessel traffic during the 2018 fall shoulder season (29 September - 17 October 2018; CPA events 19 through 21). The left panel shows the track of NW22 (thick line, color-coded for time) in relation to the icebreaker track (thin line, color- coded for time; average speed specified) and associated vessel tracks (black hatched lines; vessel names specified). The right panel is zoomed in to better illustrate the fine-scale movements of NW22. The CPA between NW22 and the icebreaking vessel is represented by a red dot on both the narwhal and the vessel tracks. Daily ice concentrations are also provided.

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Figure 10: Closest point of approach (CPA) events of NW22 within 54.4 km of icebreaking operations and associated vessel traffic during the 2018 fall shoulder season (29 September - 17 October 2018; CPA events 22 through 24). The left panel shows the track of NW22 (thick line, color-coded for time) in relation to the icebreaker track (thin line, color- coded for time; average speed specified) and associated vessel tracks (black hatched lines; vessel names specified). The right panel is zoomed in to better illustrate the fine-scale movements of NW22. The CPA between NW22 and the icebreaking vessel is represented by a red dot on both the narwhal and the vessel tracks. Daily ice concentrations are also provided.

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Figure 11: Closest point of approach (CPA) events of NW22 within 54.4 km of icebreaking operations and associated vessel traffic during the 2018 fall shoulder season (29 September - 17 October 2018; CPA events 25 and 26). The left panel shows the track of NW22 (thick line, color-coded for time) in relation to the icebreaker track (thin line, color- coded for time; average speed specified) and associated vessel tracks (black hatched lines; vessel names specified). The right panel is zoomed in to better illustrate the fine-scale movements of NW22. The CPA between NW22 and the icebreaking vessel is represented by a red dot on both the narwhal and the vessel tracks. Daily ice concentrations are also provided.

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3.3 Percent Time in Disturbance and Avoidance Zones Throughout the 19 day study period, NW22 remained within 54.4 km of a transiting icebreaker 47.4% of the time4 (Figure 12), corresponding with the range associated with acoustic disturbance (i.e., 120 dB) based on acoustic modeling (Figure 12). During the same period, NW22 remained within 13.4 km of a transiting icebreaker 8.7% of the time5, corresponding with the range associated with narwhal avoidance behaviour (i.e., 135 dB) as modeled for the same scenario (Richardson et al. 1995; Golder 2019a). NW22 interacted more closely with icebreaking operations toward the latter part of the fall shoulder season (Figure 13). Of note, NW22 became increasingly associated with transiting icebreakers and associated vessel traffic beginning on 08 October 2018, consistently spending approximately 12-24% of its total time within 13.4 km of the icebreaker which is the range associated with potential avoidance (i.e., 135 dB), as modeled by JASCO Applied Sciences (Quijano et al. 2019). Time reported within the modeled disturbance and avoidance zones is based on total data available within 100 km of the animal, as breaks in both the AIS and the GPS location data prevent analysis of the full extent of movements by NW22 in relation to transiting vessels.

4 Based on available data within 100 km from whale. 5 Based on available data within 100 km from whale.

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Figure 12: Distance (km) of NW22 from icebreaking operations and associated vessel traffic between 29 September – 17 October 2018. The 54.4 km distance associated with acoustic disturbance (i.e. 120 dB re: 1 µPa) is represented by the blue hatched line and the 13.4 km distance associated with avoidance (i.e. 135 dB re: 1 µPa) is represented by the orange hatched line.

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Figure 13: Relative percentage of time (%) that NW22 spent in the disturbance and avoidance zones of icebreaking operations (top plot). Number of hours that NW22 spent in the disturbance and avoidance zones of icebreaking operations, and total number of hours where data within 100 km from whale were available (bottom plot).

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3.4 Distance and Time Since Crossing of NW22 over Vessel Tracks NW22 made regular crossings to the bow and the stern of all vessel types during the 2018 fall shoulder season (Figure 14). However, NW22 did not cross behind the stern of icebreaking vessels or associated vessel traffic for a period of 4.5 hours following an active transit. This 4.5 h lag in entering a ship’s sternward track was not evident in relation to any other vessel type when reviewing the track crossings of all narwhal tagged during the full extent of the 2017 and 2018 shipping seasons (Figure 15).

Figure 14: Distance (km) and time since crossing (h) of NW22 over vessel tracks during the 2018 fall shoulder season (29 September - 17 October 2018).

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Figure 15: Distance (km) and time since crossing (h) over vessel tracks of all narwhal tagged during the full extent of the 2017 and 2018 shipping seasons.

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4.0 DISCUSSION Following is a high-level summary of key findings pertaining to narwhal behavioral responses to icebreaking operations and associated vessel traffic during the 2018 fall shoulder season based on the analysis of animal- borne tag data in relation to AIS ship-tracking data:  Exposure to icebreaking operations and associated vessel traffic did not cause either NW21 or NW22 to be immediately displaced from the RSA during the 2018 fall shoulder season. Both animals remained in the vicinity of icebreaking operations for multiple days before the MSV Botnica departed the RSA on 21 October 2018. Of note, the tag associated with NW21 ceased transmitting location data on 08 October 2018, at which point it is not known whether the animal remained in the RSA or departed. NW22 departed the RSA on 17 October 2018, after spending 19 days in the vicinity of icebreaking operations.  NW22 did not actively avoid icebreaking operations but rather appeared to interact more closely with the MSV Botnica and associated vessels as the 2018 fall shoulder season progressed. This finding may indicate possible habituation of the animal to icebreaking operations. It may also indicate that both the icebreaking vessel and animal were utilizing the path of least resistance (i.e. area with the least ice present) as the ice becomes increasingly dense later in the fall shoulder season. It is also possible that increasing ice concentration restricts movements by the animal, causing it to rely more heavily on the path created by icebreaking operations. However, this last scenario is not supported by the finding outlined in the following bullet point regarding narwhal use of vessel tracks. Further analysis is needed to adequately assess fine- scale movements of NW22 in relation to icebreaking operations and may be made available as part of the 2017/2018 integrated tag report, which will be released in Q1 of 2020.  NW22 did not cross behind the stern of icebreaking vessels or associated vessel traffic for a period of 4.5 hours following an active transit. As sound generated from vessels in open water is known to radiate asymmetrically, with sound levels from the stern aspect typically being highest (Arveson and Vendittis 2000; McKenna et al. 2012), this finding may signify the animal’s attempt to avoid the noisiest aspect of the vessel. However, the gap may also be due to data scarcity during the 2018 fall shoulder season (limited to one tagged animal). In addition, given the characteristics of sound that are generated from icebreaking operations and the way in which sound propagates under ice, the interpretation of the 4.5 h gap of crossing behind the stern of the vessel is not straightforward. Continued acoustic monitoring of Project-related icebreaking operations is therefore warranted to assess the sound levels radiated from the stern of individual vessels, including icebreakers.  No obvious “freeze” response by narwhal to icebreaking operations as reported by Finley et al. (1990) was observed by NW22 during the 2018 fall shoulder season. However, it is acknowledged that brief, fine scale behavioral changes by narwhal may not be captured at the resolution provided by the animal-borne GPS tags.  Distances selected to assess the time that NW22 resided within the zones associated with acoustic disturbance (i.e., 54.4 km) and avoidance (i.e., 13.4 km) of icebreaking operations and associated vessel traffic are based on the most conservative modeling scenarios presented by JASCO Applied Sciences (i.e., vessels transiting through 10/10 ice concentration, actively breaking ice; Quijano et al. 2019). It is evident from the daily satellite imagery, however, that ice conditions throughout the RSA were not 10/10 concentration for the full extent of the 2018 fall shoulder season (see Figures A-1 to A-19 in Appendix A).

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Furthermore, a preliminary review of acoustic data collected during the 2019 spring shipping season in Eclipse Sound (Golder 2019b) suggests that estimated exposure periods incorporated into acoustic modeling were overly conservative by a factor of approximately two to three when compared to measured exposure periods for both disturbance and avoidance onset. Therefore, the percentage of time reported that NW22 was exposed to sound levels associated with disturbance (i.e., 120 dB re: 1 µPa 47.4% of the time) and avoidance (i.e., 135 dB re: 1 µPa 8.7% of the time) is likely an overestimate.

In summary, the narwhal-vessel interactions presented above suggest that Project-related icebreaking operations do not cause narwhal to be immediately displaced from the area, but that narwhal may actively avoid the sternward track of icebreaking vessels for a period of 4.5 hours. These results are based on a very limited dataset (a single animal over the course of 19 days), and further data collection and analysis is required to assess whether this trend is due to chance alone or whether it represents a real avoidance behaviour. NW22 interacted more closely with Project-related icebreaking operations as the 2018 fall shoulder season progressed and did not demonstrate any “freeze” response as reported by Finley et al. (1990). NW22 was exposed to sound levels associated with disturbance (i.e., 120 dB re: 1 µPa) for 47.4% of the fall shoulder season and to sound levels associated with avoidance (i.e., 135 dB re: 1 µPa) for 8.7% of the fall shoulder season, though a preliminary comparison of modeled vs. actual acoustic data collected during the 2019 spring shipping season (Golder 2019b) suggests that this is likely an overestimate. This technical memorandum presents the preliminary results of a more comprehensive analysis that will be made available as part of the 2017/2018 integrated tagging report. The integrated tagging report will be provided in draft form to the Marine Environmental Working Group in Q1 of 2020.

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5.0 CLOSURE We trust the above meets your present requirements. If you have any questions or require additional information, please contact the undersigned.

Golder Associates Ltd.

Ainsley Allen, MSc Phil Rouget, MSc, RPBio Marine Biologist Senior Marine Biologist

Evan Jones, MASc, PEng Associate

AA/PR/asd

Attachment 1: Daily Locations of Narwhal in relation to Vessel Traffic and Ice Conditions ( 29 September - 17 October 2018)

o:\final\2016\3 proj\1663724 baff_marinemammalsurvey_ont\1663724-162-tm-rev0\1663724-162-tm-rev0-2018 tagging 15oct_19.docx

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6.0 REFERENCES Arveson, P. T., and D.J. Vendittis. 2000. Radiated noise characteristics of a modern cargo ship. The Journal of the Acoustical Society of America 107(1): 118–129.

Cosens, S.E. and L.P. Dueck. 1993. Icebreaker noise in Lancaster Sound, N.W.T., Canada: implications for marine mammal behavior. Marine Mammal Science 9(3): 285-300.

Dujon, M.A., R.T. Lindstrom, and G.C. Hays. 2014. The accuracy of Fastloc-GPS locations and implications for animal tracking. Methods in Ecology and Evolution 5: 1162-1169.

Finley, K.J., G.W. Miller, R.A. Davis, and C.R. Greene. 1990. Reactions of belugas, Delphinapterus leucas, and narwhals, Monodon monoceros, to ice-breaking ships in the Canadian high arctic. Canadian Bulletin of Fisheries and Aquatic Sciences 224: 97-117.

Golder Associates Ltd. (Golder). 2018. 2017 Narwhal Tagging Study – Technical Data Report. Mary River Project – Phase 2 Proposal. Report prepared for Baffinland Iron Mines Corporation, Oakville, Ontario. 170 pp.

Golder Associates Ltd. (Golder). 2019a. Assessment of Icebreaking Operations During Shipping Shoulder Seasons on Marine Biophysical Valued Ecosystem Components (VECs). Mary River Project – Phase 2 Proposal. Report prepared for Baffinland Iron Mines Corporation, Oakville, Ontario. 115 p.

Golder. 2019b. Marine Mammal Monitoring Programs – Preliminary Findings. Reference No. 1663724-161-TM- Rev0-3000. 11 October 2019. 45 p.

McKenna, M.F., D. Ross, S.M. Wiggins, and J.A. Hildebrand. 2012. Underwater radiated noise from modern commercial ships. The Journal of the Acoustical Society of America 131(1): 92-103.

R Core Team (2019). R: A language and environment for statistical computing. R Foundation for Statistical Computing, Vienna, Austria. URL https://www.R-project.org/.

Richardson, W.J., C.R. Greene Jr., J.S. Hanna, W.R. Koski, G.W. Miller, N.J. Patenaude, M.A. Smultea, R. Blaylock, R. Elliott, and B. Wiirsig. 1995. Acoustic Effects of Oil Production Activities on Bowhead and White Whales Visible During Spring Migration near Pt. Barrow, Alaska – 1991 and 1994 Phases: Sound Propagation and Whale Responses to Playback of Icebreaker Noise. Prepared by LGL Limited and Greeneridge Sciences Inc. for the U.S. Minerals Management Service. Herndon, VA. 570 pp.

Quijano, J.E., M.E. Austin, and Z. Alavizadeh. 2019. Underwater Noise Assessment for the Mary River Phase 2 Expansion Project: Icebreakers transiting along the proposed northern shipping corridor. Document 01757, Version 2.0. Technical report by JASCO Applied Sciences for Golder Associates Ltd.

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ATTACHMENT 1 Daily Locations of Narwhal in relation to Vessel Traffic and Ice Conditions (29 September - 17 October 2018)

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500000 550000 600000 650000 700000 LEGEND KEY MAP GREENLAND (! COMMUNITY PROJECT VESSEL SHIP TRACKS ICE CONCENTRATION REFERENCE(S) ICE CONCENTRICE ATIONOBTAINED FR OMCANADIAN SERICE GOVER VICE, NMENTOFCANADA. BULK (ORE) CARRIERS 1/10< !^ MILNEPOR T DAILYCHARICE T S–APPR OACHESTO RESOLUTE BAY.ACCESS EDNOVEMBER 2018. 23, GOLDENICE ! GEOGR APHICNAMES, POPULATED PLACE, AND PR OVINCIALBOUNDAR YDATA OBTAINED NARWHAL GPS LOCATIONS 1-3/10 ( RESOLUTE Baffin Bay FR OMGEOGR ATIS,©DEPAR T MENTOFNATUR RESOUR AL CESCANADA. ALLRIGHTS NOR DICOR ION 0 10 20 R ESER VED.WE ACK NOW LEDGETHE USE OFIMAGER YPR OVIDEDBY SER VICESFR OMNASA'S !( NW(MM02-760) 22 FAST LOCGPS LOCATION 4-6/10 (! POND INLET GLOBALIMAGER YBR OW SSER E VICESPAR(GIBS), TOFNASA'S EAR T HOBSER VINGSY S T EM NW21 (MM02-763) ARGOS LOCATIONS NOR DK AP 7-8/10 ENLAR GED DATAAND INFOR MATIONSY S T EM(EOS DIS). AR EA B AF F I N I SLA ND 1:600,000 K ILOMETR ES PR OJECTION:UTM ZONE DATUM: 17 NAD 83 !( CLASS(~ER1 R OR1500m)m500< < NSYAK UTIA 9-10/10 (! CLIENT PR OJECT IGLOOLIK ! !( CLASS(~ER2 R ORm)500m250< < GENERAL CARGO VESSELS ( BAFFINLANDIRON MINES COR POR ATION MAR YRIVER PR OJECTPHASE - PR2 OPOS AL B I ANS FR OM: MODIFIED BEEN HAS SIZE SHEET THE SHOW N, IS WHAT MATCH NOT DOES EMENT MEASUR THIS IF ATLANTICRAVEN NUNAVUT NARWHAL TRACKS 25mm (! NW(MM02-760) 22 FAST LOCGPS LOCATION MARMAMMAL INE REGIONAL ST UDYAR EA PANGNIRTUNG CONS ULTANT Y Y Y Y -MM-DD 2019-09-26 T ITLE NW(MM02-763) 21 AR GOSLOCATIONS (CLASS AND 2, 1) ES 3, CAPE DORSET(! (! DESIGNED MF DAILY LOCATIONS OF NARWHAL IN RELATION TO VESSEL (! IQALUIT BOT NICASHIP TR ACK (! TRAFFIC AND ICE CONDITIONS - FALL - RANKIN INLET PR EPAR ED AA SEPTEMBER 29, 2018 (UTC) MILNEINLET TOTE ROAD R EVIEW ED AA PR OJECTNO. CONTR OL R EV. FIGUR E NOMINALSHIPPING ROUTE Hudson Bay APPR OVED PR (! 1663724 30000-05 A PATH: I:\2016\1663724\Mapping\MX D\30000_EA_S upport_2019\1663724_30000_05_FigA1-19_Narwhal_DailyS hipTraffic_IceConc_Fall_R ev0.mxd PR INTED ON: 2019-09-26 AT: 11:48:43 AM 11:48:43 AT: 2019-09-26 ON: PR INTED ev0.mxd hipTraffic_IceConc_Fall_R upport_2019\1663724_30000_05_FigA1-19_Narwhal_DailyS D\30000_EA_S I:\2016\1663724\Mapping\MX PATH: QUEBEC A-1 0 500000 550000 BylotIsland 600000 650000 700000

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(! POND INLET Milne Inlet Eclipse Sound

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500000 550000 600000 650000 700000 LEGEND KEY MAP GREENLAND (! COMMUNITY NOMINALSHIPPING ROUTE ICE CONCENTRATION REFERENCE(S) ICE CONCENTRICE ATIONOBTAINED FR OMCANADIAN SERICE GOVER VICE, NMENTOFCANADA. < 1/10< !^ MILNEPOR T PR OJECTVESS SHIP EL TR ACKPR - EVIOUS DAYS2 DAILYCHARICE T S–APPR OACHESTO RESOLUTE BAY.ACCESS EDNOVEMBER 2018. 23, ! GEOGR APHICNAMES, POPULATED PLACE, AND PR OVINCIALBOUNDAR YDATA OBTAINED NARWHAL GPS LOCATIONS PROJECT VESSEL SHIP TRACKS 1-3/10 ( RESOLUTE Baffin Bay FR OMGEOGR ATIS,©DEPAR T MENTOFNATUR RESOUR AL CESCANADA. ALLRIGHTS 0 10 20 R ESER VED.WE ACK NOW LEDGETHE USE OFIMAGER YPR OVIDEDBY SER VICESFR OMNASA'S !( NW(MM02-760) 22 FAST LOCGPS LOCATION BULK (ORE) CARRIERS 4-6/10 (! POND INLET GLOBALIMAGER YBR OW SSER E VICESPAR(GIBS), TOFNASA'S EAR T HOBSER VINGSY S T EM NW21 (MM02-763) ARGOS LOCATIONS GOLDENICE 7-8/10 ENLAR GED DATAAND INFOR MATIONSY S T EM(EOS DIS). AR EA B AF F I N I SLA ND 1:600,000 K ILOMETR ES PR OJECTION:UTM ZONE DATUM: 17 NAD 83 !( CLASS(~ER1 R OR1500m)m500< < NOR DICOR ION 9-10/10 (! CLIENT PR OJECT IGLOOLIK ! !( CLASS(~ER2 R ORm)500m250< < NSYAK UTIA ( BAFFINLANDIRON MINES COR POR ATION MAR YRIVER PR OJECTPHASE - PR2 OPOS AL B I ANS FR OM: MODIFIED BEEN HAS SIZE SHEET THE SHOW N, IS WHAT MATCH NOT DOES EMENT MEASUR THIS IF NUNAVUT !( GENERAL CARGO VESSELS CLASS(~ER3 R ORm)250< 25mm (! ATLANTICRAVEN NARWHAL TRACKS PANGNIRTUNG CONS ULTANT Y Y Y Y -MM-DD 2019-09-26 T ITLE NW(MM02-760) 22 FAST LOCGPS LOCATION MARMAMMAL INE REGIONAL ST UDYAR EA CAPE DORSET(! (! DESIGNED MF DAILY LOCATIONS OF NARWHAL IN RELATION TO VESSEL (! IQALUIT NW(MM02-763) 21 AR GOSLOCATIONS (CLASS AND 2, 1) ES 3, (! TRAFFIC AND ICE CONDITIONS - FALL - RANKIN INLET PR EPAR ED AA SEPTEMBER 30, 2018 (UTC) BOT NICASHIP TR ACK R EVIEW ED AA PR OJECTNO. CONTR OL R EV. FIGUR E MILNEINLET TOTE ROAD Hudson Bay APPR OVED PR (! 1663724 30000-05 A PATH: I:\2016\1663724\Mapping\MX D\30000_EA_S upport_2019\1663724_30000_05_FigA1-19_Narwhal_DailyS hipTraffic_IceConc_Fall_R ev0.mxd PR INTED ON: 2019-09-26 AT: 11:49:43 AM 11:49:43 AT: 2019-09-26 ON: PR INTED ev0.mxd hipTraffic_IceConc_Fall_R upport_2019\1663724_30000_05_FigA1-19_Narwhal_DailyS D\30000_EA_S I:\2016\1663724\Mapping\MX PATH: QUEBEC A-2 0