Whitebook Hearing Responses from the Hearing Portal for London

Whitebook Hearing Responses from the Hearing Portal

for London Mining ISUA project

Prepared by London Mining

Version of 13th March 2013 1

Table of Contents

1. Hans Jørgen Løvstrøm ...... 4 2. Tom Pele Olsen ...... 6 3. NAPP (Lars P. Mathæussen og Johannes Heilman) ...... 8 4. Marc Defourneaux ...... 10 5. Flemming Hybholt ...... 12 6. Peter Oluf Holm Meyer ...... 16 7. Knud Seblon ...... 20 8. Departementet for Erhverv og Arbejdsmarked 18.10.12 ...... 23 9. Knud Seblon II ...... 26 10. GEUS ...... 27 11. Grønlands Nationalmuseum & Arkiv ...... 30 12. Departementet for Boliger, Infrastruktur og Trafik, Afdelingen for Infrastruktur, Klima og Energi ...... 33 13. ICC og WWF ...... 42 14. Flemming Hybholt ...... 69 15. Landslægeembedet ...... 76 16 TIMMIAQ ...... 81 17. Grønlands Arbejdsgiverforening ...... 89 18. Kommuneqarfik Sermersooq ...... 98 19. SIK ...... 117 20. Departementet for Sundhed ...... 124

21. Nuuk Fjords Venner ...... 149 22. Janus Kleist...... 155 23. Arbejdstilsynet ...... 160 24. KANUKOKA ...... 162 24 A. KANOKOKA (Bilag A – Qaasuitsup Kommunia) ...... 184 24 B. KANOKOKA (Bilag B – Qeqqata Kommunia) ...... 186 25. Birger Poppel ...... 187 26. Avataq ...... 202 28. Jacob Mathiassen ...... 211 29 Jakob Mathiassen II ...... 231 30. Departementet for Fiskeri, Fangs tog Landbrug (APNN) – Department of Fiskeries, Hunting and Farming ...... 232 31. Dep. for Indenrigsanliggender, Natur og Miljø (NNPAN) ...... 236 32. Peter Barfod ...... 251 33. Grønlands Politi ...... 254 34. DCE/GN comments to the EIA for the ISUA project ...... 261

List of Abbreviations

BMP Bureau of Minerals and Petroleum DCE Danish Centre for Environment and Energy EIA Environmental Impact assessment GN Greenland Institute of Natural Resources LM London Mining SIA Social Impact assessment

1. Hans Jørgen Løvstrøm

No. Question Response from London Mining Response from BMP and/or DCE/GN Amendment to EIA/SIA

1.1 I hereby forward my proposal: As Nuuk Fjord To select a port site is a significant engineering work DCE/GN: The proposal made by Hans None is beginning to get pack ice, I propose that the which involves many factors. SNC-Lavain, the Jørgen Løvstrøm would provide less ‘loading port’ moves to Fiskefjorden which engineering consultant, has put great effort into impact of the area around Qussuk. DCE/GN assesses that the suggested was used for navigation to the olivine mine localizing the most suitable site for port location for placement, with associated port. There is no pack ice in this fjord. the ISUA project and several options have been modifications of the road routes, will carefully considered. A port at Qussuk has been have similar negative effects on caribou Qussuk, Ilulialik and Aningaannaq should not found to be the best site because of (1) favorable ice population’s use of the area. The be used, because those places are important conditions in this part of the Godthåbsfjord proposed route goes parallel with to caribou. throughout the year, (2) easy access for large bulk caribou migration routes, while a road carriers through the wide and deep fjord, and (3) the to Fiskefjord will cross the routes. land at Qussuk is relatively level which facilitates the construction of the port facilities, and (4) lower costs for access road and pipeline constructions.

Furthermore, the EIA has shown that the impact on Caribou in the selected area is low.

In addition to many reasons that have been discussed, the Fiskefjord is very narrow. Safe navigation with large bulk carriers to the port site proposed by Hans Jørgen Løvstrøm will be very questionable.

1.2 It is proposed to build a pontoon bridge (big The engineering firm SNC Lavalin has studied very DCE/GN: No environmental aspect. None barges can be built into a bridge, and because carefully on all engineering issues on the project. Tasersuaq is fresh water, the material will not The current design concepts are concluded as the rust). most feasible ones. The proposed concept in this comment is technically not feasible to provide a safe (I’ve seen on TV, that the American military and reliable option. The geotechnical conditions can make pontoon bridges to transitions of were investigated carefully for all sites to ensure tanks fast). that the structures can be built that meet the design To build in the inland Qussuk (Narsarsuaq?) requirements. would be very difficult and expensive, because the soil is very soft (muddy).

2. Tom Pele Olsen

No. Question Response from London Mining Response from BMP and/or DCE/GN Amendment to EIA/SIA

2.1 What is the economic benefits of Isukasia - Revenues will start to appear from the start of DCE/GN: No environmental aspect . None Can you provide a comprehensive explanation construction works in the form of income tax - also of this? 32 billion is mentioned in revenue - from foreign staff. link: http://dk.nanoq.gl/Service/Hoeringsportal/Mi In addition, London Mining will pay dividend tax lj% C3% B8vurderinger/2012 / ~ / media / immediately after one year of operation and Naalakkersuisut / Raasto f / Hoeringsportal / corporation tax will be paid starting after 3 and 4 Exploitation Permit% 20London% years of operation after final amortisation of 20Mining/Borgerm% C3% B8de% investments. 201/Referat% 20Borger m% C3% B8de% At the same time, subcontractors to the project will 20I_dk.ashx) pay taxes of their profits. This applies to both

foreign and Greenlandic companies. This means that But it not shown in details how the revenue already the year after start of construction works will be paid, is it only after 30 years or already taxes will be paid by subcontractors. from 5/10 years? what is the annual revenue? Corporation and divident taxes are estimated based 'When the director of London Mining on the forecasted market prices of iron ore and presented, he mentioned that Greenland will estimated operating costs. have an income of 32 billion. However, we know from the olivinemine, which has announced that it will provide income for 80

years, that due to the world market this lasted only for 4 years. Can London Mining guarantee that Greenland will have 32 billion in revenue? '

2.2 The social conflicts: I can not read from your Comment is a matter for the Government of BMP: There will be no difference in how None conclusions how the different cultural values Greenland. foreign workers will be treated in the are being tackled, as crime and murder / legal system compaired with workers robbery / rape and other crimes – how will from Greenland. this be tackled in relation to international DCE/GN: No environmental aspect . workforce with a different cultural backgrounds/standards and how will theinternational workforce be punished. The current legal system practices in Greenland is intended for Greenlanders-how does this work for international workforce? Equally with the existing legalsystem?

3. NAPP (Lars P. Mathæussen og Johannes Heilman)

No. Question Response from London Mining Response from BMP and/or DCE/GN Amendment to EIA/SIA

3.1 The Godthåb Fiord is used daily by fishermen The project operations do not expect to create big DCE/GN: No environmental aspect. None and hunters, and when the mining is initiated, losses in fishing and hunting activities. In fact, the there will be a big loss in fishing and hunting presence of large amount of workers on site during profession. What is the plan for this loss? the construction and operations will most likely encourage these activities as LM is planning to engage directly with the local fishmen and hunters for fish and meat supplies. This plan is to be part of the IBA negotiations. A monitoring plan will be in place in order to study carefully the situation and, in case such losses are identified and proven with a solid scientific basis, possible compensation mechanisms would then be negotiated.

3.2 As known, the fishermen and hunters from It is not expected that the mining operations will BMP: Issues related to establishment of None Nuuk use the Godthåb Fiord on full time impact these areas significantly. A monitoring plan fonds etc. will be a part of the Impact basis, and when the mining is initiated the will be in place to study the facts and relevant action Benefit negotiations taken place in majority be lost, therefore we request, that plan will be determeined accordingly by the 2013. Naalakkersuisut will create a fund for those Government of Greenland and London Mining. who will lost in livelihood, so that the users DCE/GN: No environmental aspect.

can get replacement.

Our request cannot be rejected, because it’s in the UN determined, that one should do something about everyone, who is politically affected in his profession.

3.3 With this short explanation, we request that Comment noted. DCE/GN: No environmental aspect. None this work starts as soon as possible, and we would suggest that the work is initiated in cooperation with the organization KNAPK.

4. Marc Defourneaux

No. Question Response from London Mining Response from BMP and/or DCE/GN Amendment to EIA/SIA

4.1 Has there been a thorough archaeological The National Museum and Archives has surveyed the DCE/GN: No environmental aspect. None survey of all northern residents and Inuit sites project area in 2008, 2009, 2011 and 2012. The in the area? reports from the surveys are available from the museum. The conclusion of the surveys is that although many new archaeological sites were discovered, none of them will be disturbed by the Isua project. Furthermore, continuous collaboration with the Museum will be maintained during construction.

4.2 How will sewage water be treated? Will there All sewage water will be collected and treated in DCE/GN: Nothing to add. None be a wastewater plant? state-of-the art sewage plants fulfilling effluent criteria specified by the BMP.

4.3 Why will London Mining use fossil fuel and LM does not have the right to use the water in the BMP: There are no exact plans of None not renewable energy? project area for hydropower. In spite of this, LM visiting Sierre Leone, but the Greenland requested International Engineering firm SNC- Authorities are looking at mining Can Greenland send a delegation to Sierra Lavalin to study the hydropower alternatives for the experiences from other countries. Leone where London Mining has a project, to Isua project. This study is available to the Public. see how it works? DCE/GN: Nothing to add. The financial analyses show that the capital investment has a very significant impact to the project economics. An accurate financial analysis has to take all factors into the evaluation, including the project capital cost, operational cost, production rate, estimated near term and long term product 10

prices, financing conditions and freight arrangements etc. The financial indicators in the hydropower alternative study show the economics of the project not feasible under the construction of power dams and transmission lines. The simple calculation that is reported by this comment cannot reflect the real project economical condition. Based on the financial model developed by SNC Lavalin, the increased capital expenses combined with the estimated delay for the production will make the project not financially attractive.

LM’s project in Sierra Leone is located in a tropical environment and is currently extracting minerals from tailings from previous mining activities. This project is therefore not comparable to the Isua project at its current condition. However, LM welcomes visiting delegations from Greenland Government.

4.4 Will there be a referendum on the project? Government issue. BMP: There will be no referendum. None Greenland has Self-Government, and the people have democratically elected the members of Inatsisartut (Parliament), which again has elected Naalakker-suisut (Government). Wether the project should be approved or not, is decided by Naalakkersuisut.

5. Flemming Hybholt

No. Question Response from London Mining Response from BMP and/or DCE/GN Amendment to EIA/SIA

5.1 Please find enclosed a comment regarding the LM does not have the right to use the water in the DCE/GN: In this, as in several other None opportunities to use hydropower as the project area. In spite of this, LM requested the comments, the use of fossil fuel instead source of electricity to the mine project. International Engineering firm SNC-Lavalin to study of whole or partial utilisation of the the hydropower alternatives for the Isua project. hydropower potential in the area, is Investment in hydropower as the source of This study is available to the Public. This study criticised. energy to the ISUA iron mine instead of the concluded that the secure hydropower within the planned very expensive and polluting diesel DCE/GN agrees with this view, but must economic viability is 120 MW. generators. Operation costs of 1.8 billion DKK also point out that there has not been up front and interest. Investment in diesel A decision to use hydropower also involves financial prepared an EIA for the use of generators and oil storage 1.7 billion DKK. analyses. In that respect it should be noted that the hydropower resources. capital investment has a very significant impact to Value of electricity from hydropower 1.8 the project economics. An accurate financial analysis billion DKK. Gross investment of 3.5 billion has to take all factors into the evaluation, including DKK. Investment compared to diesel the project capital cost, operational cost, production production 1.8 billion DKK. NPV 11.5 billion rate, estimated near term and long term product DKK over 15 years with a discount rate of 8 %. prices, financing conditions and freight Reduction in emissions of CO2 at 450,000 tons arrangements etc. Simple calculation as reported by annually. This prevents almost a doubling of this comment cannot reflect the real project CO2 emissions in Greenland. economic condition.

Overall a very economically and Based on the financial model developed by SNC- environmentally very advantageous Lavalin, the increased capital expenses combined investment. The basis for the calculations is with the estimated delay for the production will the material on hydropower alternatives make the project not financially possible. The present CO2 emission from Greenland is 12

prepared by London Mining. estimated to around 0.63 million tons per year (average of 2002 – 09). The ISUA project will add 0.56 million tons per year in the operational phase using fossil fuel (diesel) – i.e. in total around 1.2 million tons per year (using the present emission from Greenland as basis).

These figures can be compared with annual CO2 emission from Denmark of approximately 50 million tons per year and with the global CO2 emission of around 31,800 million tons (2010 figures). The estimated emission from Greenland - including the Isua project - is thus 0.0038 % of the global emission.

Consequently, the emission share from Greenland is among the least CO2 emitting countries. Greenland was ranked no. 183 out of 217 countries (in 2010) and be ranked around no 172 when the ISUA project is accounted for.

5.2 During the public hearings, London Mining An engineering study has different accuracy levels. DCE/GN: Nothing to add. None stated that they are open for a supply of LM is not sure what engineering levels and hydropower to the project, but that they have development stages were used for other a number of reservations that need hydropower studies which were prepared by other clarification. consultants for other project.

It is London Mining’s view that it would be a problem to get access to the hydropower potential in Imarsuup Isua, as this potential has been committed to an aluminum melter project. This situation must of course be clarified by Naalakkersuisut. In this relation is 13 should be remarked that there are other sources of hydropower, which can ensure hydropower supply to the aluminum melter project.

London Mining is of the opinion that the hydropower potential of Imarsuup Isua only can supply 120 MW and hence will not ensure the total electricity need. However, the hydropower potential of the aluminum melter project is estimated to 175-200 MW, which have a nice margin to cover the total needs.

London Mining’s material calculates a construction period for hydropower to 7 years, which either leads to a three-year delay of the project, and thus a poor economy or the need for the establishment of a diesel power plant for use in the project’s first operating year, which naturally leads to an increase in net investment of up to 1.8 billion DKK. Hereby NPV gets reduced by the hydropower investment to 9.7 billion DKK.

When referring to the hydropower potential’s stage of development, and lessons learned from the construction of hydropower plants in Greenland (Ilulissat 2.5 years) and Iceland (Budarhals 95 MW, 3 years) there seems to be basis for a much shorter construction period than 7 years, and thus an opportunity to plan

14 mining project without establishment of diesel generators.

Based on the above, there seems to be good reason for a careful assessment of both economic and environmental nature in connection with an approval of this application from London Mining.

6. Peter Oluf Holm Meyer

No. Question Response from London Mining Response from BMP and/or DCE/GN Amendment to EIA/SIA

6.1 Consultation response regarding London As far as to the use of hydropower, see answer to BMP: comment regarding the COP 18 is None Mining’s - ISUA Iron Mine Project in Qugssuk question number 5.1. noted. at the bottom of Nuup kangerlua and next to the inland ice. However, it should be noted that London Mining DCE/GN: Nothing to add. does not have the right to use the hydropower Positive and responsible exploitation of our potential in the project area. In spite of this, LM mineral resources. requested the International Engineering firm SNC- Lavalin to study the hydropower alternatives for the It makes a positive impression on one as a Isua project. This study concluded that the secure citizen, that the Self Government with 'one hydropower is 120 MW. LM is not aware how Alcoa hand' for the last 20-30 years has established made their calculation of the hydropower resources. hydropower plants that supply much of the country with sustainable renewable energy which does not pollute, and continue to develop / build this form of energy to replace polluting diesel power stations around the country.

At the same time, we have the last 20-30 years heard from our responsible leaders, that sustainable renewable energy in the form of hydropower is the way forward, when the extraction of our mineral resources will contribute positively and responsibly to Greenland's future income, since our hydropower potential is so great in this

country.

Therefore, it creates a negative impression on one as a citizen, to be informed at the public meetings that Greenland will stand outside in the forthcoming international environmental conference COP18, organized by the UN. Based on the argumentation that now Greenland, with 'the other hand' would have the possibility to pollute the environment unlimited when large scale mining projects is to be realized in our scenic Greenland.

This is largely reflected in London Mining’s application, which states that the mine is planned to be operated by use of fossil fuels with polluting power stations, which is based on to London Mining's own studies showing that hydropower potential is too "small" in the area. This question was also put forward at the public consultation meetings and there is obvious doubt if this is correct, since other studies appear to show significantly higher hydropower potential.

6.2 London Mining informs an expected Reference is made to the answer to question DCE/GN recommend that specific None consumption of arctic diesel of 210 million number 5.1. environmental requirements are set for liters per year in the planned 15 years or the handling and use of fossil fuels in Isua project, which will ensure minimal more. As far as transportation and unloading of diesel for risk and impact on the environment -In order to be able to imagine the huge the project is concerned, it is correct that a special build tanker will supply the project with fuel roughly during operations and in case of spills. amount of what the diesel consumption will Unloading and loading must be done once a month. This tanker will be similar to the ones 17 be per year, and for the comparison of that supply other towns and settlement s in under satisfactory safe conditions and proportions, I found a press release from Greenland with fuel. However, in the case of the with robust systems that take into Nukissiorfiit concerning Ilulissat’s energy ISUA project arctic diesel has been specifically account the ice and weather conditions. Unloading and loading must meet high consumption for the production of the city's chosen. This fuel type has operational advantages in standards which ensure that the risk of electricity. cold climates and also environmental benefits accidents / spills are as small as possible The press release states that Ilulissat in 2013 compared to other types of gasoils and heavy fuels. and that the consequences of any spill should revert to hydropower and that the Arctic diesel oil has less content of Sulphur (S), lower are as small as possible. A plan for local diesel-powered electricity plant today emissions of soot and furthermore advantages in handling spills in case of accidents must consumes 6 million liters per year. case of spills (lower content of parafins. The be prepared and approved by the -Thus, London Mining will annually consumer unloading facility at Qussuq port will be constructed authorities. and pollute the environment equivalent to 35 to the highest standard and for example includes times the annual consumption in Ilulissat and pressure sensors that immediately stop the 3 times Ilulissat’s annual consumption per unloading in case of a leak. month. -This will, by the combustion pollute the environment with an unacceptable extent within our scenic area, while there will be an unacceptable risk to the environment in connection with the unloading of the fuel to the bottom of Qugssuk with tankers that can accommodate up to 30 million liters of diesel oil per time. According to the application will boarding happen 12 times a year / 1 time a month.

According to the country´s laws this contradiction with the text of the law that outline, that the best available (and least polluting) energy source should be used.

It would therefore be feasible if London

Mining and others, as far as economy and time schedule are concerned, are required to plan the mine project is close cooperation with the country’s authorities in such a way that the project are based on the available hydropower resources. This should be done without taken into account how long the mine project will run, because the hydropower plant will be beneficial to Greenland as an energy source that can be used by other, when the mine is closed.

6.3 Moreover, it is in any case desirable that the It is standard procedure for mine projects in DCE/GN: Nothing to add. None mining company are required to make Greenland that the mine company before any sufficient financial guarantees before the construction works can initiate to deposit according to the progress of construction an amount that construction, which the Self Government can equals the estimated closure cost of the constructed make use of if the clean-up does not happen facilities. The amount must be approved by the in an acceptable and satisfactory manner Greenland Government and will be adjusted if during exploitation and when the mine is changes subsequently are made to the mine project. being abandoned.

7. Knud Seblon

No. Question Response from London Mining Response from BMP and/or DCE/GN Amendment to EIA/SIA

7.1 I am a user of Nuuk fjord like many others. The same question was raised as part of the 3rd BMP: Discharge to the nature has to None We hear from a marine biologist during the public hearing meeting on 24 September 2012. follow international best practice and fourth consultation in Katuaq that other Please confer the detailed answer included as no. 4 the requirements in the government countries keep the dangerous chemicals of the reply from the meeting available on the BMP approvals has to be set after guidance separated from nature. They are not poured web portal. of DCE and GN. out and mixed with the nature. The same should happen here. Dangerous DCE/GN: The question is answered in the minutes of the third public meeting, chemicals should be kept away from Nuuk's lakes, rivers and fjords. Pure nature costs, but section. 4: ”On behalf of Naalakkersuisut has the DCE developed is worth every penny. ”Greenland Water Quality Guidelines (GWQG)” that gives the suggested maximum concentrations in ambient water. There are specific values for freshwater (rivers and lakes) and salt water (for example the fjord). The ambient water quality is defined from international eco-toxicologigal standards. Based on this the quality of the discharged water is defined. This includes a dilution factor. This is the normal international praksis. Some areas have natural heigh levels of metals.

Among the substances that will be discharged to the marine environment for which a GWQW value has been defined, only cobber and iron will exceed the values in the surrounding water. The dilution required for these metals to be below the GWQW is small and will be achieved close to the discharge point. There can also the small amounts of chemicals in the water. In particular the three reagents Xanthate, Flotigam og Magnafloc . When these reagents are discharged they can occur in toxic concentrations. However due to the local conditions including the tide, the dilution in the Taserâssuk bay which is bordered by one of the wharfs will quickly be meet. All requirements of the BMP will be meet outside the port area including Qugssuk.

All chemicals and products that are used in the process must be approved by Naalakkersuisut before they are used. Limit values will be defined for these chemicals in discharged water. These limits will follow EU standards. The limits will secure that there will be no toxic effects on the environment outside a dilution zone of 100 m. 21

Chemicals that can be accumulated in the environments or organisms will not be permitted. Similar requirements will be enforced for heavy metals outside the dilution zone.

It will be continuously controlled by the company and by the authorities that the limits are met. In addition the environmental monitoring will include the concentrations of metals and chemicals in water, sea-weed, fish, mussels and the sea floor. Monitoring of toxic effects on sea-weed, mussels and fish will also be carried out in the project area and a reference area.

8. Departementet for Erhverv og Arbejdsmarked 18.10.12

No. Question Response from London Mining Response from BMP and/or DCE/GN Amendment to EIA/SIA

8.1 Consultation responses from Dep.for business No response is required. DCE/GN: Nothing to add. None and labor regarding Social Impact Assessment (SIA) and Assessment of impacts on environment of the Isua iron ore project (EIA).

By the letter dated 16.august 2012, the BMP requests for consultation responses regarding reports EIA and SIA in the London Mining Greenland A / S's application for an exploitation license for an iron mining project in Nuuk.

8.2 Ministry of Industry and Labour has the Capacity development and education has high focus DCE/GN: No environmental aspect. None following comments on the Social Impact for London Mining, in order for London Mining to Assessment (SIA): recruit as many local qualified workers as possible.

The actions that London Mining will take and the 1. Generally, it is assessed that the project support London Mining will give to the education would help if the government coalition aims system will be part of the negotiation of the IBA. to create a more self-sustaining economy including by exploiting Greenland non-living resources, for example mining. It is expected to be done by a considerable job creation and thus improved tax bases primarily in the operational phase as well as corporate taxes 23 and fees.

It is positive that the project aims to employ as many local qualified candidates. It is also noted that the employment impact of the construction phase depends on how quickly local companies can be ready to meet the needs of the project during the construction phase.

This is exactly one area where the department has put initiatives, in the form of tutoring and educational activities for companies that might bid on the tasks associated with large- scale projects. It is also noted that there may be some conflict with other economic sectors if the competition for qualified staff means that other sectors will find it difficult to attract sufficient labor.

This situation should therefore be closely followed with a view to implementing measures to ensure an adequate supply of labor.

Finally, it is noted that the largest employment impact of the project will be linked to job creation during the operational phase.

It is in this context positive that it expects to

24 start recruiting labor from Greenland to training already in the construction phase.

The department has no comments on the Environmental Impact Assessment (EIA).

9. Knud Seblon II

No. Question Response from London Mining Response from BMP and/or DCE/GN Amendment to EIA/SIA

9.1 Other mining countries require that these The same question was raised as part of the 3rd DCE/GN: See comment to section 7.1. None chemicals are kept separate from nature. It is public hearing meeting on 24 September 2012. not discharged to fjords and mixed with Please confer the detailed answer included as no. 4 of the replies of the meeting. nature (animals and plants). The same should happen here. These chemicals must be filtered out and not poured directly into Nuuk's lakes, rivers and fjords. The chemicals must be removed from process water before discharging the used contaminated water further out to the fjord at the harbor. This natural cost but it is worth the money.

10. GEUS

No. Question Response from London Mining Response from BMP and/or DCE/GN Amendment to EIA/SIA

10.1 GEUS has received and reviewed the hearing No response is required. DCE/GN: Nothing to add. None report re. the Isua project.

Although SIA and EIA is not part of the core competencies related to mining GEUS has the following overall remarks to be highlighted as part of the hearin.

10.2 Will there be ensured a continuous Comment is a matter for the Government of BMP: The ore production will be None monitoring and control of production data Greenland . monitored based on the production from the mine? data given by the regularly reporting GEUS is keen to be involved in a further from LM. BMP has an agreement with dialogue on this issue In order to ensure the GEUS concerning evaluation of these best possible recording and storage of data. reports.

DCE / GN recommend ongoing monitoring, as proposed by GEUS. Monitoring of production data vilgive an opportunity early on to detect significant changes in the ore chemical composition. Changes in ore chemical composition could have environmental effects

10.3 It should also be ensured that in connection London Mining will follow the regulations established BMP: BMP has regular inspections of None with the exploitation activity, that at any time, by Greenland government. the mining activity and if necessary

there should be access to geological sampling consultants will be used. under § 2 stk.4 in the Act of Inatsisartut # 7 of 7 December 2009. DCE/GN: Nothing to add.

10.4 Currently, there is a work ongoing to preserve Comment is a matter for the Government of BMP: The geo-site mentioned is the None selected areas of the Isua resource to GeoSite. Greenland . locality where the oldest carbon in the GEUS calls in this relation to finalize this work world has been detected. This geo-site and that the area will be preserved before is outside the mining area but might be construction is initiated since otherwise it in the vicinity of the road and the would damage the sites during construction. pipeline. The geo-site will be kept as it is and will not be affected by the mining activity.

DCE/GN: Nothing to add.

10.5 The planned 105 km gravel road between the The 105 km access road will be privately owned by DCE/GN recommends that use of the None mining area and the port will open up for a London Mining. However, when possible, London road by other companies should also be unique infrastructure in an otherwise Mining may approve for others to use it for non- approved by BMP. This is important to secure that the possible environmental impassable area. It should therefore be commercial purposes. London Mining reserves the effects of cumulative impacts are secured that possible other exploration right to reject applications that are not assessed. companies will have access to use this environmentally acceptable, have safety concerns, infrastructure to transport equipment and impact London Mining’s operations or may violate material assuming it is safe and the legal rights of London Mining. environmentally acceptable. London Mining agrees with DCE that that approval by BMP is also required. In the case of such a demand, London Mining will expect that the third party user of the access road submit a comprehensive application for the purpose of the use, duration, safety aspects, traffic aspects and environmental aspects.

10.6 In order to assess the project in more detail Comment is a matter for the Government of BMP: BMP has rules and requirements None the ressource and production estimates used Greenland . for reporting, which will be sufficient in in the feasibility study are needed. GEUS this case. It is not a complicated ore and there is no reason for providing GEUS would like to receive copies of this with more detailed information information in order to assess which concerning the BFS and its estimations. requirements London Mining should be asked to meet regarding documentation and reporting in a production phase.

11. Grønlands Nationalmuseum & Arkiv

No. Question in English Response from London Mining Response from BMP and/or DCE/GN Amendment to EIA/SIA

Comments from the Greenland Museum - - (Grønlands Nationalmuseum & Arkiv) regarding the Environmental Impact assessment and Social Impact assessment which have been prepared in connection with London Mining Greenlands’s application for opening an iron mine near Nuuk.

11.1 Regarding section 0.8.2. page 36: We propose Comment accepted. DCE/GN: Nothing to add. Last part of that the last line “and moved if relevant” is the sentence removed since it doesn’t make sense to move ”will be an archeological find. moved if relevant” will be deleted.

11.2 Regarding section 5.4.3. Archeological finds: Comment accepted. DCE/GN: Nothing to add. Proposed pages 140, 141 and 142: wording will replace the We do not think the wording is good and fully current text. correct. We therefore propose the following text instead:

The inner parts of Godthåbsfjorden-area has been used by people through 4000 years. All the cultures which has lived in Westgreenland since 2000 f.Kr. have based their settlement 30 along the coast on also utilizing the inland population of Caribou.

Sources such as Aron from Kangeq describe how the caribou hunting in the inland took place in the middle of 1800. Groups of people travelled during the summer in boats and kayaks into the fiords and established camps in areas with good access to the inland. From there the people went further inland and established settlement, from where they went caribou hunting. A characteristic of the inland area where London Mining’s activities will take place, are numerous constructions with stonewalls. The hunters have returned to these houses for generations. There are also other signs of hunting activities. These signs are from hunting tours and hunting activities such as tent-rings, so-called huntersbeds (for individual sleepover), stone structures to hide behind during hunting etc.

Previously, there has only been carried out very few archeological surveys in the inland of the Godthåbsfjorde. In 2008, 2009 and 2011 Nunatta Katersugaasivia Allagaateqarfialu (Grønlands Nationalmuseum & Arkiv) carried out archeological surveys in the areas of the mine project, including the mine area, the roads and the pipeline and harbor area /

GMNA 2008, GMNA 2009, GMNA 2011/. The field work was supplemented with literature studies. An additional detailed study of the final allignment of the road between the port area and Crossing 1 (also called Maqqaq Qulleq) was finalized in September 2011 / GMNA 2011 /. These survies did not show any signs of archeological finds of significant importance. The survey of the remaining part of the alignment from Crossing 1 to processing plant was postponed due to bad weather in 2011 but carried out in 2012 by Greenland Nationalmuseum & Arkiv.

12. Departementet for Boliger, Infrastruktur og Trafik, Afdelingen for Infrastruktur, Klima og Energi

No. Question Response in London Mining Response from BMP and/or DCE/GN Amendment to EIA/SIA

12.1 Division Infrastructure, Climate and Energy consultation responses to London Mining application for exploitation license for the DCE/GN: Nothing to add. None Isua project. This consultation response includes comments from the Division of Infrastructure, Climate and Energy on the EIA (Orbicon A/S, 2012) of

the Isua Iron Mine Project. The comments relates to (1) greenhouse gas emissions, (2) alternative energy (hydropower) and (3) short-lived climate forces' (SLCF).

Preliminary general comments: London Mining is committed to build the mine at With reference to the Mineral Resources Act Isua to the highest standard. This implies using Best the EIA refer to a requirement the use of BEP Available Technique (BAT) and BEP. London Mining and BAT in project planning. As a consequence considers the various standards mentioned in the it would provide more transparency if it is EIA as benchmark for the mine industry and have described which standards are followed in consequently been proposed for the project. each case since the Greenlandic authorities US EPA emission standards for non-road diesel have not established standards for acceptable engines, for mine equipment and haul trucks, are environmental pollution levels. slightly stricter than EU standards. The US EPA Tier 4 It would be useful to specify why reference standards (2014) for engines 130 to 560 kW are has been made to U.S. environmental essentially identical to EU Stage IV standards, but authorities EPA standards in the section on slightly stricter for PM: 0.02 g/kWh vs. 0.025 in the EU standard. EPA has standards for engines > 560 33 dust and air pollution. For motor vehicles, the kW but EU does not. World Bank's IFC standards for emissions of air pollutants in large-scale projects in EU ambient air quality standards are used in dispersion modeling since they apply throughout developing countries (is used) and EU standards of protection of human health and Europe. Danish C-values for ambient concentrations vegetation. We recommend that in each case are normally applied in dispersion modeling using the OML model. OML could not be used due to the the highest standard is used, and that that any deviations from this will be further explained, complex terrain. The AERMOD model used does not provide the exact statistic required for evaluation of if this is the case. compliance with C-values, so only the EU ambient limit values could be tested for compliance.

World Bank/IFC emission standards for diesel power plants are referenced since the EU Large Combustion Plant Directive does not apply to diesel engines and emission limit values in Miljøstyrelsen’s Guidelines for Air Emissions (2001) do not apply to large diesel engines. Danish emission standards in Departmental Order no. 621 of 23/06/2005 could

apply, giving a lower NOX emission limit value. The air pollution dispersion modelling assumes World

Bank NOX emissions, which makes the dispersion

results for NO2 more conservative. The area of NO2 exceedance would be smaller if the Danish emission standards had been used when calculating power plant emissions.

Air qualiy assessment and assumptions for the modelling are detailed in Annex 4 of the EIA and summerized in section 7.1.8 of the main EIA report

12.2 Emissions of greenhouse gases The present CO2 emission from Greenland is DCE/GN: Nothing to add. None Department of Infrastructure, Climate and estimated to around 0.63 million tons per year Energy notes that greenhouse gas emissions (average of 2002 – 09). The Isua project will add 0.56 will result in an estimated increase of million tons per year in the operational phase using Greenland's annual greenhouse gas emissions fossil fuel (diesel) – i.e. in total around 1.2 million during the operational period by 89% tons per year (using the present emission from (excluding maritime emissions that are Greenland as basis). supposed to be significant). This will result in a total emission per capita of approx. 21 tons These figures can be compared with annual CO2 emission from Denmark of approximately 50 million of CO2, against the current per capita of approx. 11 tons (average from 2002-2009). tons per year and with the global CO2 emission of The increase will bring Greenland in line with around 31,800 million tons (2010 figures). The the 10-15 largest per capita CO2 emitters in estimated emission from Greenland - including the the world. For comparison, the EU's total per Isua project - is thus 0.0038 % of the global emission. capita emissions are 7.5 tons. In Saudi Consequently, the emission share from Greenland is Arabia’s it is 16.5 tons and in the United Arab among the least CO2 emitting countries. Greenland Emirates 24.9 tons. was ranked no. 183 out of 217 countries (in 2010) The method used (section 3.5) for the and be ranked around no 172 when the Isua project assessment of the impact on the environment is accounted for. of the mining activities in relation to any local or regional impact, and the model is therefore The recommendation of using hydropower is noted. not appropriate to describe a climatic See also the remarks in 12.3. significance. The project's climatic significance

must be considered high. Compared to the coalition agreement (of the Greenland Self Government) and the 2025- plan which claims to economic development must be accompanied by a general principle of sustainability, which also includes environmental and climate sustainability, it is

recommended that London Mining base its energy supply on the available hydropower potential. Other climate and energy benefits of this disposition are further specified in the following.

12.3 Hydropower and energy supply

In the EIA report hydropower is excluded as an As mentioned at the 2nd public hearing meeting in DCE/GN: Nothing to add. None alternative with reference to the long Nuuk on the 7th September 2012 London Mining construction period compared to the overall would be happy to replace, in part or whole, diesel mine life and because of the lower net present power with hydro power, if made available by value (NPV) of the project. It is also made others. But this requires that the hydropower dams clear that the potential is not readily available and transmission lines are constructed and financed since the resource may be allocated to other by a third party and the price of the power is projects. However, from the minutes from the commertially competitive. London Mining cannot 2nd public hearing meeting on the 7. build and operate a hydropower plant for the September 2012 London Mining made it clear reasons given in the answer to question number 5. that it is happy to shift from diesel power to hydropower “when this becomes available” (no page number given in the minutes). If this is the case, that LM wishes to build a hydropower plant during the operation phase if the possibility becomes available we suggest that the possibility of using hydropower is studies further and is included in the project design.

An option could be to use diesel during the construction phase and shift to hydropower

during operation.

A hydropower plant will lead to much reduced CO2 emissions and to much lower emissions of sod and other air pollutions according to the EIA report. If more industries could use the electricity from a hydropower plant and if the energy demand in Nuuk could be secured for the future it would be economically beneficial. The consequence would be a reduced carbon footprint or CO2 footprint.

12.4 Energy supply

It should be investigated if plans for the Comment is a matter for the Government of BMP: LM has investigated the None energy supply for energy demanding industrial Greenland . hydropower potential for the project. projects could be integrated with the energy The study is reported in Annex 9 of the supply plans for the region. An analysis of EIA report. This preliminary study of the possibilities that include the strategic plans of hydropower potential is part of the Nukissiorfiits for the future energy supply in material available for public hearing. In Nuuk points to the following issues that could the study focus is primarily on the hydro be taken into consideration when a final power potential of Imarsuup Tasia since decision is taken regarding the projects (Isua this site is the most promising in project) energy supply. connection with the Isua project. However, the hydro power potential of The Buksefjord hydropower plant which Imarsuup Tasia is reserved for Alcoa’s supplies Nuuk is expected to be enlarged aluminium project which means that between year 2020 and 2040 to meet the hydro power from Imarsuup Tasia for increasing needs in Nuuk, where the energy the time being is not an option for LM. consumption is increasing and is expected to reach 70 MW in 2030. The need (for more It is BMP’s the opinion that Departementet for Bolig, Infrastruktur 37 energy) can be met through the construction og Trafik (Department of Housing, of new plants and by increasing the water Infrastructure and Traffic) should resource by building tunnels to new initiate an additional study of the catchment areas. possibilities to integrate the energy supply of potential industrial projects Since London Mining (the Isua project) is not with the public energy supply. The study the only energy demanding large-scale should be coordinated with Nukissiorfiit project, which is investigating the and Asiaq. (hydropower) potential of the area and since the potential according to estimates by However, it is BMP’s view that Nukissiorfiits are available to meet the energy integrating industrial and public energy requirements of both potential energy supplies into one publicly owned requiring projects (the ALCOA project at company is a very risky model. The Maniitsoq and London Mining) and to secure expense for constructing a power plant the future energy supply in Nuuk we propose probably exceeds 10 million Danish kr. that an integrated solution is found in Such a large amount will make it a very cooperation with Nukissiorfiit, Asiaq and other risky project for a public company. partners (companies) with knowledge in this In Spring 2012 Inatsisartut decided not area. to become owner of an aluminium If some water potentials are not available for project (see point 112 in the minutes). the Isua project the Nukissiorfiits report points None of the members of Inatsisartut out that an alternative hydropower potential votes against this decision. Inatsisartuts of c. 65 MW is available in the Isua area. Erhvervsudvalg (Business Board) has expressed that “the board does not A further option would be to expand the believe that the financial situation hydropower plant at the Buksefjord to 160 permits even a partly ownership of a MW which would open for offering energy to project of this type”. for example the Isua project and secure future energy supply needs in Nuuk. This would Without an a agreement with a private require transmission cable between the company that has a very long running

Buksefjord hydropower plant via Nuuk to the period there is a danger that a public Isua area. Such an integrated plan would imply company could end up investing a large that Nuuk is connected to two supply amount and has no privat company to networks and that an emergency diesel plant buy the energy. It would be the will no longer be needed. Greenland Self Government – and ultimately the Greenland people – that At present there is only one transmission line would end up with the bill. to Nuuk, the one from the Buksefjord plant and in this situation Nukissiorfiit will have to expand the diesel powered emergence plant at Nuuk. An integrated solution will therefore have large befits for the society and for the supply security.

When the mine closes the hydropower plant can supply the industrial development in the area and supply power to Nuuk.

Nukissiorfiits’ possibility analyses also highlight the obvious economical benefits of using hydropower because of the much higher and fluctuating running costs associated with diesel.

12.5 Short Lived Climate Forcers (SLCF)

Burning of fossil fuel result in emission of SO2, Black carbon (BC) is a major component of soot BMP: LM is obliged to follow national The NOx, CO, soot (black carbon) and other air emitted by incomplete combustion of fuel. BC is the and international rules and regulations terminology pollutants (PM). Of particular relevance in an most efficient atmospheric particulate species at regarding shipping and pollution in of dust, black arctic context are the concentrations of soot. absorbing visible light. BC is an Arctic haze aerosol connection with shipping. In addition carbon and absorbing sunlight with a resultant strong warming Greenland Self Government can particulate formulate additional demands and rules Soot is a short lived climate forcers, SLCF effect in the atmosphere. BC influences cloud matters will

39 which in spite of its short life has a marked formation and reduces the reflectivity (albedo) of that must be followed if necessary. be cross impact on human induced global heating. snow and ice when it is deposited, accelerating checked Most soot is transported to the arctic from melting and earlier opening of sea ice. DCE/GN recommend monitoring between the countries far away. It should be noted that possible formation and spread of black English and that emissions of soot in the arctic has much BC is recognized as a significant short-lived climate carbon from the combustion of fossil Danish larger impact on the human induced heating forcer (SLCF) of particular significance for climate fuels in power plants, trucks, ships, etc. /Greenlandic change in the Arctic. It has a strong warming of arctic than emissions from other parts of translation. the world (AMAP, The Impact of Black Carbon potential (albedo feedback, direct atmospheric on Arctic Climate, 2011). When soot is warming) but also cooling potential (cloud interaction). emitted to the atmosphere and deposited on ice and snow it will absorb light from the sun and convert the energy to heath. This will BC also contributes to the adverse impacts on contribute significantly to global heating and human health of PM2.5 (Particulate matter with size less than 2.5 μm)The health impact of BC is integral local melting of snow and ice. Although soot in the atmosphere is short lived (1-4 weeks) its in PM2.5 limit values, which are based on the overall impact on regional climatic change is large health risk of fine particulate matter.

(around 30% according to UNEP) of the latest observed heating in the arctic. When soot is Most BC in the Arctic comes from emissions outside deposited on ice and snow (particularly the Arctic. reflective surfaces) its “life” (effect) is extended, since the soot accumulates on the Due to the relatively short lifetime of BC in the surface. The effect of soot on the climate (its atmosphere compared to other GHG (Greenhouse Gasses), and lack of standardized and practical ability to increase melting) is strongest in spring, when the energy from the sun is most quantitative models to estimate impact of the intensive and the snow- and ice cover is numerous mechanisms involved, it is not possible at this time to draw quantitative conclusions on the largest. Deposition of soot on for example the Inland ice will therefore lead to increased impact of BC from the Isua project on regional or global climate. melting.

A discussion of the consequences of soot

emissions should be included in the EIA.

The soot is mentioned in the EIA in connection The type of fuel used for shipping will follow the with shipping but the emissions from the main regulations. source burning of 210 million diesel annually at the project power plants should also be mentioned.

The discussion of dust, soot and other particles in the EIA is difficult to understand because the terminology used diverges.

It is noted with satisfaction that the project will use arctic diesel (AFD) for the power plants because of its good characteristics in an arctic environment. As far as shipping is concerned it is recommended to use other fuel types that heavy oil because of the emissions of pollutants associated with this type of fuel.

12.6 Other comments

In connection with Naalakkersuisuts reporting London Mining is committed to provide all required DCE/GN: Nothing to add. None to the UNFCCC (UN’s climate convention) it is data for Naalakkersuisut’s reporting to the UNFCCC. expected that data are provided by the company (London Mining) and its suppliers for Greenland’s report as is the case with other mineral projects in the country.

13. ICC og WWF

No. Question Response from London Mining Response from BMP and/or DCE/GN Amendment to EIA/SIA

13.1 Herewith common hearings responses from None - - ICC and WWF regarding EIA and SIA for the London Mining/Isua project are submitted.

13.2 As announced in September 2012, ICC None - None Greenland and WWF partnered to focus on the development of large-scale industry and public involvement in decisions. Therefore, we have prepared a joint response regarding London Mining/lsua project. Below are our comments to the published Environmental Impact Assessment (EIA) and Social Impact Assessment (SIA).

13.3 1. General comments

This hearing is the first of its kind for a This is a matter for the Greenland Government BMP: The public meetings including the None possible large-scale project in Greenland. ICC structure of the meetings will be Greenland and WWF have chosen to provide evaluated also with focus on the length a joint response to cover as much as possible of the public hearing phase. The of the comprehensive material. Even comments are noted and will be through joint effort, we have not been able considered in this process. to work through the entire hearing material. There are two separate hearings, a hearing on Environmental Impact Assessment (EIA) and a hearing on the Social Impact 42

Assessment (SIA). ICC Greenland and WWF DK therefore consider that the consultation should be extended for at least 3 weeks. During the hearing period there has been held four public meetings, where a number of relevant questions have been asked, and there has been a lot of waiting on some of the questions which could clarify some of the misunderstandings which may have arisen in the process.

Alongside this hearing, there have been other relevant hearings; two Strategic Environmental Assessment (SEA) for offshore oil license areas, changing the Mineral Resources Act, and the bill for building and construction projects of large scale projects. The latter two are direct prerequisites for London Mining iron mining project and it can thus be argued that this hearing should be after a possible adoption of the two bills. 13.4 2. Alternative energy sources-hydropower versus fossil fuel

BMP: Hydropower viewpoint is noted. The Government of Greenland has for more This is mainly a matter for the Greenland None According to the BMP guidelines for than a decade invested purposeful in the Government. It should, however, be noted that preparing an Environmental Impact development of green energy, especially London Mining does not have the right to use the Assessment (EIA) Report for mineral hydropower. And Naalakkersuisut states in water resource in the project area for hydro power exploitation in Greenland, energy the coalition agreement of 2009 that "a (this right belongs to other organizations). In spite of demands (energy sources and supply) 43

Greenland, which primarily derives its this, London Mining requested the International has to be described including a detailed energy from green energy is the Engineering firm SNC-Lavalin to study if hydropower description of the hydrology. If fundamental vision". could be used on an viable basis for the Isua project. hydropower due to economical or This study concluded that the secure hydropower technical reasons is not feasible, this The long-term investment in hydropower is potential is 120 MW. This is around 80% of the has to be documented. The good for both the economy and the power needed for the Isua project. A decision to use documentation makes it possible to environment. Hydropower replaces fossil hydropower also involves financial analyses. decide upon a complete material. fuels, limiting emissions of C02 and harmful particles into the air, and after a few years of Based on a financial model developed by SNC- The Greenland Government is operation the investment has paid for itself. Lavalin, the increased capital expenses combined supporting the companies in finding the with the production delays caused by the estimated best hydropower solution for all the Investments in renewable energy have been 7 years construction schedule for the hydropower relevant mineral projects. It is also a highlighted in the international negotiations dams and transmission lines will make the project requirement in the guidelines that under the Climate Convention. Thus back in not financially possible. hydropower has to be considered as 2009 Naalakkersuisut established that in the part of the project. The hydropower post-Kyoto period the emissions of C02 in potential has to be considered with civil society will be reduced by 5 per cent; respect to the already excisting that it will continue to invest in renewable hydropower scenario in the area. energy and the need to develop mining activities and major emitting facility in accordance with international standards and principles of sustainable development, DCE/GN: Nothing to add. including Best Available Techniques (BAT) and Best Environmental Practices (BEP) (see the President of Naalakkersuisut's letter to the then Minister for Climate and Energy Lykke Friis, November 24, 2009, with attachment of Greenlands obligations concerning reduction of greenhouse gas emissions in the period 2013-2020).

Seen in this light ICC and the WWF find it without vision that there now is an energy consuming iron ore project on the drawing board, where hydropower is not an integral part of the project.

 Renewable energy should be part of the solution. Establishment of hydropower will be in the

Greenlandic community interest, also because it will reduce the footprint of the project.

Annex 9 for the EIA report "Preliminary study of the possibilities of developing hydropower", according to SNC-Lavalin, who has prepared the report, a preliminary study and the results presented have been achieved as a result of a desk job, which further is based on incomplete data and information from previous studies. By introduction, it appears that the study is partly based on a limited set of hydrological field observation and topographical information available from the following studies and supported by hypotheses based on SNC-Lavalins experience from similar projects under similar conditions. It is also emphasized that the findings can only be validated by further investigation and a more detailed hydrological assessment and

45 field work.

 We believe that the importance of hydropower versus fossil fuel,

however, is too great and the consequences too many for the decision to be taken on an incomplete material.  There should be a detailed and

comprehensive study of the possibilities for integrating hydropower in London Mining Isua project. If it is estimated that the potential to use hydroelectric power

is present, it should be a requirement that the solution is chosen.

The potential of two hydropower plans to meet the energy needs of the operation of the mine in the Isua project is assessed in the report. It is concluded that a hydropower solution based on the Imarsuaq Scheme is the preferred solution to achieve the required installation capacity of 120 MW in the Isua project, but hydropower is not a real alternative. At least not because a construction period will be too long compared to operational period of the mine project.

Table 4.9 p 93 of the EIA report of August

2012 shows ratios for the different energy solutions. With the use of fossil fuels in Isua project, Greenland's annual CO2 emissions from fossil fuel increases with 47 per cent, while a project based on hydropower from Imarssuaq will lead to a limited increase in CO2 emissions of just 2 per cent. If the estimated investment for the construction and operation for 15 years is looked upon it amounts to about 4.7 billion USD for a solution based on fossil fuels. The investment in Imarssuaq hydropower plan estimated at approx. 1.3 billion USD. This is a difference of approx. 3.4 billion USD for water power alternative. This difference will further grow if the life of the project is extended to 20 or 30 years.

 In addition to reducing CO2

emissions and pollutant particles into the air, a hydroelectric plant could operate for decades and thus be of great value to the community in Greenland, also after mine end.

In the public debate, it has been argued that the area's hydropower potential is reserved for the Alcoa aluminum project at Maniitsoq. This situation is not for the benefit of the Greenlandic society and Naalakkersuisut should seek a clarification. Naalakkersuisut

should also develop visions for future industrial development in Greenland.

 Naalakkersuisut should develop an overall strategy for the development of large-scale industry based on renewable energy. It should be facing international companies and investors emphasize that green energy is part of the solution.

13.5 3. Caribou

The caribou will undoubtedly be more or less Comment noted for future detailed planning and BMP: Regulation related to monitoring, None disturbed by the Isua project and the various work on monitoring program in co-operation with reporting and an environmental phases, and disturbances cannot be avoided. the Greenland authorities. employee can be put into the final government approval. Some of the It is assented to the recommendation of the issues can also be a part of the Impact EIA report p. 154 and the proposal that an Benefit Agreement. environmental employee participate in the planning of the construction work to ensure DCE/GN expects to be included in the that the disruption of caribou is minimized company proposed cooperation on and at the same time that works be avoided planing the monitoring of project in specific areas in the calving time (15/5 - impacts on the reindeer population.

30/6 ).

 However, it should be a requirement that such a measure be taken, as it is a requirement to hire an environmental officer as proposed, together with a representative of the

hunters identified in cooperation

with KNAPK.

It is also recommended in the report that a Comment noted for future detailed planning and 3-4 - year monitoring program is established work on monitoring program in co-operation with with the primary objective to investigate the Greenland authorities. whether the build caribou-ramps work as intended and thus ensure that the animals can move freely between winter, calving and summer areas. It is important that ramps work as intended as the caribous otherwise become completely unable to move freely between areas north and south of the study area. The proposed monitoring program would further collect information and provide new knowledge about the Greenland caribou behavior, which could subsequently be used in conjunction with other projects.

 It should be a requirement for the Comment noted for future detailed planning and Isua project that such a monitoring work on monitoring program in co-operation with program is established, both for the the Greenland authorities. animals in the area, but also as a basis for knowledge and capacity building in Greenland.

 Caribou hunting in the study area will be forced into other areas. The monitoring program should also examine how hunting pressure on caribou will change and how the population of caribou react to such a

change. If hunting pressure is increased in smaller and more concentrated areas it should be ensured that the animals can withstand such pressure. Possibly with management actions to follow.

In connection with the disturbance of The selection of the proposed routing for the road- caribou population, we will mention the ICC pipeline corridor has balanced engineering as well as Greenland during the hearing regarding the environmental issues and concerns. During the expansion of London Mining's exploration process other routes were considered but were license in March 2012, has required a change rejected because they were either not technically of the alignment. Section 4.11.10 mentioned feasible or because they were feared to lead to briefly that a change in routing including to larger impact on wildlife. increase the path length, involve more extensive construction work and have greater adverse visual effects, these things mentioned without further explanation.

13.6 4. Whale Collision and noise from traffic Collision of humpback whales in The expected navigational speed of the ships as they DCE/GN recommends implementation None Godthåbsfjord can cause damage to the sail through the Godthåbsfjord system will be low of surveillance of whale responses to animal or, in the worst cases, death. It is and likely to be in the vicinity of the here mentioned maritime transport, and that in this described in Annex 3, Marine mammals and 10-11 knots. context, particular attention is paid to birds that ships from the Isua project will run the importance of ship speeds at low speed, thereby reducing the risk of collision with whales significantly. The risk of collision with whales is present whether sailing in the Godthåbsfjord or other places.

 It should be a requirement that the ships of the project sail with a max

speed of 10-11 knots in Godthåbsfjord in order to reduce the risk of collision with whales.

The Godthåbsfjord is an important feeding Comment noted for future detailed planning and area for humpback whales which enter each work on monitoring programme. year to the fjord. Noise from traffic can cause temporary displacements of humpback whales from these important habitats.

 We refer to comments from DCE / GNIR for EIA for Isua project of 13. August 2012, which propose the establishment of a monitoring program to determine the project's potential effects on whales in Godthåbsfjord.

13.7 5. Navigational Safety

The Annex Study of Navigational Safety The Navigational Safety Investigation is not part of BMP: Requirements on following the None (after Requirements and Guidelines from the the EIA, but was conducted as per Danish Maritime IMO guidelines and recommendations Danish Maritime Authority (DMA) per Authority (DMA) requirements and guidelines dated can be put into the final government January 10, 2011) to the EIA report aims to 10 January 2011. The Danish translation of the approvals. present a study of navigational safety in the Navigational Safety study has been checked again, Isua project. Such studies have since 2011 DCE/GN: Nothing to add. been a requirement set by an agreement and while some minor mistakes have been between the BMP and the Danish Maritime corrected, it is felt that the translation is true to the Authority. The report submitted to the original. public via Naalakkersuisut's hearing portal 51 on the website is stuffed with linguistic The conclusions of the NSI are in agreement with errors and you can ask whether it is a this comment; it is a recommendation of the NSI proofread report or on an unfinished version that local navigators experienced with navigation in by mistake has been posted on the website. Greenland polar waters will assist bulk-carriers in The report, however, form the basis for our hearings answer on Sailing Safety section their course along the fjord. hereunder.

The port of Taseraarssuk will likely be called There are only very few ice class large bulk carriers at of several different size classes of ships. and they are in the Handimax and Panamax Due to the high load factor at a single berth categories (smaller than 70,000 DWT). Such ships in the Isua project it is decided to build a are too small for the Isua project shipping second berth to handle import cargo. In the requirements. For the Isua project, the operation report's Table 7-5, page 36, appears tonnage plan and economics of the project are designed and dimensions for the types of bulk carriers based on Capesize (180,000 DWT) or larger (250,000 expected to be used in the Isua project. The DWT) type of bulk carriers. There are no known smallest ships are 65.000 deadweight carriers in these sizes that are ice classed. tonnages (DWT), with a length about 245 m, width 35 m and depth of 12 m, while the The shipping of the Isua iron ore concentrate will largest is at 250.000 DWT, 330m length, 57 likely be concentrated to qualified shipping m wide and 18 m in depth. The expected companies who own and/or operate chartered bulk number of calls per month will be between 9 carriers. At this point, London Mining has no and 11 ships. agreement with any shipping companies for exporting the iron ore concentrate and importing of Ships to serve in polar waters are consumables. recommended to follow the In ternational Maritime Organization (IMO) Guidelines for As to shipping companies that provide chartered navigation in polar waters (2009). The bulk carriers, it is required to follow as applicable Greenlandic waters are defined as polar. In the International Maritime Guidelines (IMO) – reports it can be read that bulk carriers to Guidelines for Ships Operating in Polar Waters, and lsua project will not be ice-classified. The to follow as well Greenland orders, applicable reason for this is that they are mostly will Danish maritime regulations, and other applicable 52 sail in polar waters which are not covered conventions related to navigation, environment, with ice. All other vessels, including fuel health and safety. ships and tugs, however, will be of an The navigational safety study indicated that there appropriate ice-class. Simultaneously IMO guidelines recommend that all vessels in ice- should be no problem with appropriate covered polar waters have at least one ice management assisted with the ice classed tugs and with low travel speed. navigator. The comments that the IMO guidelines are  IMO guidelines are recommendations not requirements are recommendations, not requirements acknowledged. However, they do contain a number (as stated in the EIA report), ICC of requirements that should be fulfilled if the Greenland and WWF believe it guidelines are to be considered followed. should be a requirement for Isua project that these recommendations According to DMI’s report Statistics of Ice Conditions are followed. This is also consistent in Northern Godthåbsfjord, dated January 2010, the with the intentions of using BAT. parts of the fjord than normally develop fast ice are  Will LM elaborate reasons why bulk not along the proposed shipping route. The calving carriers are not ice-classified, despite of glacial ice are mostly in the forms of growlers or that parts of the Godthåbsfjord bergy bits, slow speed, large sturdy ships, ice annually is coated in solid ice to a scouting. thickness of up to/60 cm and icebergs calves from nearby Ice thickness of up to 60 cm in Godthåbsfjord is glaciers? Does LM believe that it is limited to a short period only and to a very short safe to let bulk carriers that are not distance of a few kilometres along the route to the ice classified service Isua project? port. The conclusions for the shipping of Isua iron concentrate are based on a careful assessment of The vessels are expected to meet IMO ice conditions in Godthåbsfjord where London elements of the guidance lines which include Mining requested the service of the Danish navigation equipment, livestock and Meteorological Institute (DMI) for a study of ice environmental protection and preparedness. conditions in the northern part of Godthåbsfjord; London Mining also requested maritime specialists 53

from BFS Engineer SNC-Lavelin to review the data from GEUS and navigation information from Royal Arctic Lines. The key conclusions from these studies are presented as part of the Navigational safety Investigation and they are reported in connection with this comment: the studies “show the maximum extent of sea ice coverage, as determined by satellite imagery, is about 10 km of sea ice at the head of Qugssuk Bay. Under this condition, ships arriving/departing from Taseraarssuk port site would need to transit about 6 km of sea ice. In the context of ship operations, this sea ice condition would be of a limited duration, possibly 3 or 4 weeks”. The studies also conclude: “It is considered extremely unlikely that even a non ice class ship will suffer any damages when moving through first year ice of 50 to 60 cm, providing it is following appropriate ice navigation procedures”. The appropriate ice navigation procedures are also presented in the studies for the shipping of Isua iron concentrate, including ice class tug boats to assist bulk carriers navigation for the short occasional transit of 6 km in sea ice, presence on the bulk carrier of experienced navigators, ice monitoring systems and others.

13.8

There are no charts of the inner parts of The conclusions of the NSI are in agreement with - None Godthåbsfjord. Until planned hydrographical this comment: hydrographic surveys and nautical studies of Godthåbsfjord from Nuuk to maps need to be completed. This work is to be

Taseraarssuk is completed (expected to be carried out in a next step before operation of the performed by the Maritime Safety mine starts and under the guidance and Administration and Survey and Cadastre requirements of DMA and Danish Hydrographic Authority), the navigation to and from Nuuk agency. It is understood that the Danish depend on available maps and traditional Hydrographic Office -National Survey and Cadastre, maritime navigation techniques. The only Greenland has undertaken hydrographic survey map, used in the report on navigational work in part of the Godthabsfjord, between Nuuk to safety is chart 38541fra USGS National the Isua Port. It is also understood that Danish Agency and Mapping Agency, covering the Hydrographic Office is to prepare and issue nautical entrance to the Godthåbsfjord. charts for some areas of Godthabsfjord.

Unfortunately, it is not unusual for ships to Once this information is made available, it is the run aground in Greenland coastal areas. plan to review this information and then, to work Recently the passenger ship SarfaqIttuk ran with DMA and the Danish Hydrographic Office- aground just outside the port of Qaqortoq National Survey and Cadastre, Greenland in order to (d. 10/10). Godthåbsfjord has never before establish clearly those areas of Godthabsfjord where been serviced by such large vessels that are more hydrographic surveys need to be completed expected to operate the Isua project and by London Mining and to prepare additional nautical ships of this magnitude have never before charts where needed. Inputs and advices from been fully engaged by Taseraarsuuk. Danish Hydrographic Office and from Danish Maritime Authority will be needed in order to  It should be a requirement that there execute this work in compliance with the methods is an updated hydrographic survey of and scope expected by the Authorities. the fjord and relevant charts are available for use before ships begin During the construction period the size of ships to operate Isua project. servicing the constructions sites are expected to be significantly smaller than the large bulk carriers According to the report a middle fairway needed during mine operation. The DMA buoy 1-2 nautical miles from the port of requirements apply for navigation during operation. Taseraarsuuk should be established. This will Due to the length of the construction period, it is serve as boarding station for a pilot. It is not expected that such cartography and hydrographic

clear from the report on which route the surveying will be completed by the time production pilot will be on board and whether it is a begins, and larger bulk carriers can be expected. requirement that ships must have a pilot on The need of a local pilot, during which period for board. such a need and where, if such a need is required,  LM should indicate whether all (or the pilot should be on board will be assessed which) ships to and from the Isua carefully together with the Greenlandic authorities, project is expected to have a pilot on DMA and the shipping companies prior to the start board and on which route the pilot in of the operation. The relevant governmental this case is on board? regulations will be strictly followed.

13.9 The introduction of non-native species into The BWM has not yet been ratified by Greenland, DCE/GN: Nothing to add. None new marine areas in ships' ballast water is however it should be noted that the Government of one of the biggest ecological threats to the Greenland (BMP) as a reply to a similar question at world's oceans (p. 68). It is likely that in the the 3th public meeting made it clear that it will sensitive Arctic ecosystem, which the “require that ships to the mine follow the Godthåbsfjord is part of, the introduction of convention”. such alien species have disastrous ecological This is also reflected in the EIA report (sections consequences. 0.7.8, 6.2.6 and 7.2.9) and Annex 3 (section 6.3.9).  It should be a requirement for vessels calling at the port of Taseraarsuk that they follow the rules of the International Convention for the Control and Management of Ships' Ballast Water and sediments (BWM) to minimize the risk of introduction of non-native species.

13.10 The report Survey of navigational safety The Navigational Safety Investigation is not part of DCE/GN: Nothing to add. None mentions on page 72 that Orbicons report the EIA, but was conducted as per DMA on the assessment of risks, impacts and 56

mitigation measures of accidental spills of requirements and guidelines dated 10 January 2011. hydrocarbons is attached to the study of navigational safety as Annex H. A few However, Appendix H mentioned internally in the Navigational Safety Investigation is Annex 6 to the sentences below it appear that the main conclusions from Appendix H are reported main EIA, which is available for download on the in this report. It is not clear whether Annex hearing portal. H and Appendix H cowers the same document, even if this is to be assumed. This document is not attached to the report Delivery of artic diesel to Isua port will be by the on navigational safety, nor is it to be found same types of ships that currently navigate in in the Naalakkersuisut's consultation portal Greenland waters for supplying fuel to Greenland on the website. So important a document towns and settlements. should be publicly accessible and easy to

locate.

From section 10.5 'Assessment of risks and possible effects of hydrocarbon spills on because of shipping during the operational phase' it appears that significant amounts of fuel and chemicals will be transported to

Taseraarsuk each year in large tankers and other vessels. The report estimates that the risk of oil spills and chemical accidents is low. But if such an accident occurs the consequences for life in the fjord can be very severe and restoration of livelihoods can be long-term. The report mentions that the precautions and preventive measures should be implemented and that it is important to have effective contingency plans in place. Shipping and maritime regulations taken into

 What international and national consideration are noted in the EIA, section 2.3. regulations, does the LM take into

account? The following international agreements relevant to safety in Comment on OSPAR noted for future negotiations Greenland waters: SOLAS, MARPOL between LM and BMP/DMA. and the OSPAR Convention and the London Convention and OPRC 90. Although the OSPAR Convention is

not directly applicable to the west coast, then OSPAR standards and requirements are still considered good practice.  If a hydroelectric power station is See also answer in section 12.4. established in connection with the Isua project large quantities of fuel transported through the fjord will be minimized considerably, which we consider to be desirable and an aim to be pursued.

13.11 6. Fuels for ships Ship traffic to and from the lsua project will Issues regarding Heavy Fuel Oil (HFO), emissions and None result in increased emissions from fuel spills are treated in the EIA section 7.1.8, Annex 3, BMP: Requirements related to combustion in the Godthåbsfjord. Primary light/heavy fuel will be set in the final section 3.8, Annex 6, sections 5.1, 7 and 8.3 emissions are carbon black (fine soot government approvals. particles of carbon and other substances), The issue is covered in the EIA section 7.1.8, Annex NOx, S02, particles of organic matter and DCE/GN recommend that the company 6, section 7.1 C02. The particles are considered in the be required to use light fuel oil in report to cause a regional pollution rather The shipping of iron ore is an established large accordance with the Polar Code, which than a local pollution. industry in the world and London Mining’s is expected to be adopted by the

Analysis and conclusions in the report are operation will not be expected to be different with International Maritime Organization made on the basis of current Greenlandic the established model. Shipping in Greenland (IMO). and Danish regulations for shipping and waters will follow the regulations. include the assumption that heavy fuel oil will be used as fuel in ships. IMO has The shipping of the Isua iron ore concentrate will recently tightened the rules so that it is no likely be contracted to qualified shipping companies who own and/or operate chartered bulk carriers. At longer allowed to use the heavy fuel oil in Antarctica. Similar tightening of shipping in this point, London Mining has no agreement with the Arctic are on the way, which would any shipping companies for exporting the iron ore concentrate and for importing of consumables. The mean smaller amounts of the burning gases and thus less impact on the environment. qualified shipping companies that operate in Polar This will also reduce the release of soot from Waters are aware of the applicable rules and any burning, something which the Arctic guidelines such as the International Maritime Guidelines (IMO) Guidelines for Ships Operating in Council recently has identified as an Polar Waters, as well Greenland orders, applicable important area to reduce. Danish maritime regulations, and other applicable  The light fuel oil should take conventions related to navigation, environment, precedence over the heavy as fuel health & safety. These shipping companies are for ships Isua project, by which expected to comply with legal requirements. Greenland is pioneer in the Arctic for

this approach. This should also apply to third-party vessels associated with the project.

13.12 7. Waste water treatment and chemical spills BMP has established guidelines for preparing an BMP: Discharge to the nature has to None Minimum levels of chemicals and water Environmental Impact Assessment (EIA), in which follow international best practice and treatment should follow the European are presented the GWQG (Greenland Water Quality the requirements in the government standards, or even stricter requirements, as Guidelines). These are based on standards from approvals has to be set after guidance these are operated in a vulnerable Arctic several sources, including the EU, USA and Canada. of DCE and GN. environment. An environment which may 59

have more difficulty recovering from stress Following the comments by DCE/GINR, it is planned and disasters than is the case for other in the EIA that eco-toxicity testing will be conducted environments. ICC Greenland and WWF and the monitoring plan presented in the EIA already endorses DCE / GINR 's comments on eco- covers the recommendations in this toxicological tests on effluent pipeline and tailings, including continuous measurements comment.Comment noted for future detailed and the requirement for complete details on planning and work on maintenance routines and the content of reagents and chemicals. surveys.

It is mentioned in the material that pipelines will be equipped with temperature-and pressure-sensitive control systems to detect leakage. Experience with similar systems in Alaska is mentioned, but experience from ICC Alaska says that technical systems as these are not infallible and those emissions have gone unnoticed due to the lack of physical checks. ICC Greenland and WWF recommend that the pipelines be checked at regular intervals regardless of whether control systems report irregularities or not.

13.13 8. Contingency

Contingency plans must of course follow the Comment noted for future work on detailed - None prescribed national and international contingency planning. standards and recommendations. In addition, contingency plans must follow the principles of openness and transparency with the bare minimum of information crossed out, so plans can be evaluated by independent third parties. Denmark has

joined the Aarhus Convention, and although Greenland so far is excepted, ICC Greenland and WWF recommend that the Convention is followed as good practice.

13.14 9. Closure

It is very important to focus on A closure plan is prepared by London Mining for the DCE/GN: Nothing to add environmental, social and economic impacts ISUA project. The closure plan has followed the of a mine closure. While investment may general practice in northern regions and is aiming at bear some temporary economic to return, as close as practical, the conditions to the consequences, the environment and society original conditions. The expected management of would bear permanent consequences. the mine personnel at closure will be discussed in Internationally, there are differences in the the IBA.However, when the mine is closed, it is requirements for decommissioning inevitable that there will be losses of jobs and procedures, but when, as here, "best revenues. practices" are aimed at one should meet the most stringent existing rules, for example, Ecuador requires plans for water purification, revegetation, treatment of residues and management of flora and fauna (Garcia, D.H. 2008. Overview of International Mine Closure Guidelines. American Institute of Professional Geologistys, s 1-9)*.

While explaining the mitigating measures during decommissioning in relation to the environment, an account of mitigating measures in relation to economic and societal consequences of a shutdown is lacking for example by job losses within a

short period of time, and loss of income.

13.15 Consultation response on. London Mining / Isua project in the light of SIA Report Grontmij A / S, July 2012

13.16 General Comments

The report Social Impact Assessment for lsua The format of the report is following the BMP BMP: Within the nearest future the None iron ore projects for London Mining guidelines. BMP will be working on an updated SIA Greenland A / S provides a comprehensive guideline. It has to be emphasized that description of the Greenlandic society with a the BMP guideline is a guideline and focus on Nuuk and Kapisillit. Generally, it is a not a law text. very comprehensive report that describes many different aspects of the Greenlandic DCE/GN: No environmental aspect. society, including population composition, education, working life but also describes civil society.

The SIA report is written in a language that is easily understandable but one could have worked more with the structure of the report to promote readability. The reports proportion is 327 pages, but you have to get to page 118 before you are presented with the first real analysis of the project's social sustainability. And as reader you have to get to page 191 before a plan for managing the impact of the project is presented. The initial description of the Greenlandic society could have the shortened considerably and could

be added to the report as appendices.

The report provides a picture of many aspects of the Greenlandic society, but is marred by an unclear and varying use of terminology and spellings. In addition, the report have a few faults , which should have been addressed by the audit of the report in June 2012.

The following are comments on a range of sections of the VSB report.

13.17 4. SIA methodology

The method behind the study is presented in The comment will be taken into account. Further DCE/GN: No environmental aspect. The section just 4 pages where the focus is on describing information will be provided on the methodology on the the collection of the data underlying the and criteria used for evaluating and assessing methodlogy report. For the reader it is not clear how the impacts. will be analysis is performed and how to arrive at expanded. the conclusions presented in Section 6

13.18 5. Social and economic background conditions

Purpose of this section is to give a broad The comment on the small number of ambiguities DCE/GN: No environmental aspect. The introduction to the community, including and errors will be taken into account. comment on demographics, economy and society the small building. The section contains a large number of amount of information and one could have ambiguities easily have shortened the section slightly and errors and attached some of the figures in an will be taken 63 appendix to the report. Throughout the into section, there are a small number of account. ambiguities and errors one should have directed the review in the summer of 2012.

 The description of the legislative and executive powers is unclear and there is no consistency in the use of terminology. After Self-Government

Act the legilative power is

Inatsisartut and the executive Naalakkersuisut, but text refers to both "government" and "government chairman".

 In the same section is an overview of

civil society organizations. This lack Nuup Kangerluata Ikinngutai / Nuuk fjord Friends, that is very active in the debate on just London Mining

project.

 In the section on public health in Greenland is stated, in a section on crime and violence (section 5.7.3.4),

inaccurate information on organization of the judicial system in Greenland. According to the Court Administration the justice system in

Greenland consists of 18 circuit The two last courts, the Court of Greenland and paragraphs Greenland High Court. in section

 Section about the sale of fish and 5.8.3 will be capture by the board is written rewriting in

before January 2011. The text order to should be reviewed prior to emphasizes publication. the The two last paragraphs in section 5.8.3 will be challenges The SIA report also contains a section on the rewritten in order to emphasizes the challenges for for Greenlandic people's relations with the Greenland in relation to training and qualification of Greenland in international community (5.8.3). The section the labor force in Greenland, which the Greenlandic relation to focuses on a very relevant issue-reliance on politicians bring into focus. training and external labor and the consequences this has qualification for both wage levels, capacity building etc. In of the labor the SIA report this is described a little force in simplistic, as a struggle against the influx of Greenland, foreign labor. Thus you get expressed that which the the Greenlandic society wants to close itself Greenlandic from the surrounding world. Rather than a politicians battle there is talk about a challenge in bring into relation to training and qualification of the focus. labor force in Greenland, which the Greenlandic politicians bring into focus.

13.19 6. Social sustainability assessment A IBA will be negotiated and agreed between Economy and employment. Greenland Government, Kommuneqarfik DCE/GN: No environmental aspect. Recomendati Sermersooq and London Mining. In the IBA, the ons on The area of economy and employment are coordination details of the employment, recruitment and one of the areas where the VSB report with KNAPK indicates that the project will have major retention strategy will be established. will be benefits and opportunities for the Impact on traditional livelihoods: incorporated Greenlandic society. in the SIA. The concern of local hunters and society in general 65

During the construction phase is expected was seriously taken into account during the that less than 10 per cent will get jobs assessment. The areas used for caribou hunting, directly related to the project, while the fishing arctic char, picking of berries and seal Indicators of impacts on operational phase operates with a spread of hunting, has been identified and mapped for both 20-55 per cent local labor. The section commercial and recreational hunters (the majority traditional contains suggestions for how London Mining of them not expected to be directly impacted by the livelihood and can maximize the use of local labor. Much project), including amount of produce, number of emphasis is placed on initiatives to visits a year, how much is used for self consumption associated strengthen recruitment to the company, but and how much is sold, etc. 49 commercial hunters wellbeing of hunters and also develop strategies for retaining (36% of total), 208 recreational hunters (22% of their employees. total) and 24 households in Kapisilliit (100%) were interviewed. All these factors were taken into households For the Greenlandic society, it is essential to account, as well as the concerns expressed. It has to will be try and maximize the use of local labor, but incorporated be noted that the assessment is also based on the just as much to care to invite Greenland expected low impact on caribous according to the to the enterprises to participate in part enterprises EIA. Therefore deviations on the expected impact in monitoring of the project. A number of proposals are wildlife will also have consequences for traditional plan. outlined in the report, but it is crucial that livelihoods and monitoring is essential for identify you make measurable requirements to do so changes and corrective measures. also. Recommendation on Involvement of KNAPK in monitoring of wildlife will be incorporated in the The impact on traditional livelihoods in both benefit and impact plan and the monitoring plan. construction and operational phases is Indicators of impact on well-being of hunters and assessed in SSA report as low. The household economy related to traditional livelihood assessment is based on the assumption that will be integrated on the monitoring plan. commercial and recreational hunters will search for new areas where there are fewer disturbances of wildlife. Yet the local hunters express major concern for the consequences

of iron mine for their use of the area. It is a relevant concern, as no security is that the profits of the new hunting areas will be the same as in the area that is now disturbed by the project. And there is no assessment of the long-term consequences of disturbances of the hunt.

It is crucial to establish a thorough monitoring of wildlife in the area, and that fishermen and hunters are invited to participate as much as possible in this work.

13.20 Public services and development plans.

If realized, it will according to the VSB report Impact on Public services and development plans DCE/GN: No environmental aspect. None create a significant pressure on public was assessed, among others, during a workshop on services in Nuuk, including increased consequences of demographic change, with the pressure on the administration, an increased participation of local authorities of various areas and need for housing and the need to expand local social and health experts. The result of the capacity for handling the waste. In workshop indicate that negative impacts of cooperation with the Municipality of increased immigration (permanent residents in Sermersooq one should also look at Nuuk) would only start to be experienced with wastewater issues, including the capacity of about 50-75 families and 100 single workers. The the existing sewer system as well as most critical aspect is related to availability and opportunities to establish wastewater potential pressure on price of housing. Impact of 150 treatment before it is discharge into the new households in Nuuk regarding wastewater and fjord and bay. waste was not evaluated. Demand of daycare centers and school was not identified as a critical In addition, it is noted that SSA report's issue by local experts. On the other hand, business section on public services and development opportunities related to private day care and

67 plans do not address the expected impacts international schooling were identified as business of the project on the city's day-care centers, opportunities. schools, etc. However, the Isua Mine is a remote site and a privately operated site. It is located about 150 km from Nuuk and there is no public transportation between Nuuk and the site. During construction phase, all foreigners workers will stay at the camps (either at the mine site or at the harbour). Very limited demand for housing is expected during this period, mainly management staff.

The same applies for operations: the vast majority of workers are expected to work on the basis of rotations, this is being transported back and forward to their place of residence, (for example 3 weeks in, 2 weeks off) within Greenland or outside. A worker at Isua does not expect or is required to be based in Nuuk. It may nevertheless be possible that some would choose to move to Nuuk, both direct workers or because of business opportunities. International workers with children in school age may prefer to have residence in cities with international schools outside Greenland.

14. Flemming Hybholt

No. Question Response from London Mining Response from BMP and/or DCE/GN Amendment to EIA/SIA

14.1 The rationale behind hydropower for Isua mine project - None There is a great need for electricity and Regarding London Mining’s response to suggestions adequate hydropower resources available. about hydropower, see answer to question number According to available scenario descriptions 5.1. and 5.2. there are very large economic advantages of Furthermore, additional explanations are presented the use of hydropower, since the alternative in answers to questions raised at the 3rd public is a new diesel generator plant. hearing meeting on 24th September (cf. answer no.

7-9; 15: 31-34). The scenario descriptions must of course eventually be replaced by thorough and documented financial calculations.

14.2 Basis None Please confer response to question 5.1 and 5.2. The electricity demand seems to be - uncertain according to the brief summary of the "Bankable Feasibility Study" of February 2012 as a correction to a more detailed material in the "Scoping Study Report" of February 2011. An initial assessment based on a total cost of $ 46 per. tons of concentrate corresponds to electricity costs

of $ 24 per. ton, resulting in a total consumption of 100 kWh / ton or a total of 1.5 billion. Kwh.

In the dossier is expected an electricity consumption of 1.1 billion kwh.

Issues related to CO2 emissions must also be part of the EIA. A consumption of 1.1 billion kwh hydropower will save the environment from emissions of 550,000 tons of CO2 per year.

The economics related to electricity supply can be derived from the economic conditions and general knowledge about the cost of electricity. The investment in a hydropower plant at Imarsuup Isua incl. transmission lines with a capacity of approx. 150 mw is estimated at 2.5 billion DKK. The investment in diesel power plants of 150 mw is estimated at 1 billion DKK. In addition, there will be investments to in fuel systems and tanks of 100 million $ which equals to 0.5 billion DKK.

14.3 Hydropower potential None Please confer response to question 5.1 and 5.2 In the area between Nuuk and Sisimiut there -

hydropower potential which is enough to 70

supply an aluminum smelter project and the Isua project. The most detailed material about the hydropower potentials in the area is probably at Greenland Development, supplemented with material in Nukissiorfiit.

The hydropower supplied to Isua mining project must be expected also to be able to act as back-up for a coming aluminum smelter project which is critically depended on power to shot down in case of a if the primary supply drops out to avoid damage to the plant and consequent following significant costs.

For Isua mining project a drop out of electricity supply will only cause production losses, which is in the order of 20 million. DKK per. days.

14.4 Ownership and financing BMP: There are substantial financial None Please confer response to question 5.1 and 5.2. expenditures related to a hydropower It would probably be most convenient to facility. The suggestion is though noted. combine the electricity supply to the Isua project and aluminum smelter in Manitsoq.

In this way no specific hydropower plant should be allocated to the Isua project.

Supply for Isua will conveniently be established as a first phase of the overall system and based on Imarsuup Isua. The economic scope will be of the same magnitude, also in a situation where the aluminum smelter is not established.

The funding must be based on a very large contribution from the Isua mine - equivalent to the saved capital costs for the mine, which can be estimated to at 1 billion. DKK. In addition, it will be reasonable with a down payment, six months before the start of production, the electricity in the order of 0.5 billion. DKK corresponding to the investment in oil stock for diesel generators. In addition, a project loan of 4 -6 years based on payments from the mining company - an estimated 1 billion DKK.

The project loan can be based on a number of lenders, for example, Nordic Investment

Bank, the European Investment Bank, export credit linked to stock supplies, and of course the Greenland banks. Alternatively, project loan provided by the mining company.

It must be considered appropriate that the hydropower plant is owned by the Self Government, and run by a special project

company under the daily management of Nukissiorfiit.

14.5 Billing Practice for electricity Please confer response to question 5.1 and 5.2 With a significant economic framework - None available there is a need for a billing practice for the electricity.

It appears reasonable that the main added value is for the Self Government with the following profile:

• The price (for electricity) can be directly related to the price of oil. This makes the mining company neutral.

• There is no significant problem regarding CO2 quota, which will be beneficial for all parties.

The agreement could include compensations for the mine company during the construction phase.

• The price can be related to steel price to a certain extent.

• There may be a compensation for the possibility of supply disruption related to 73

failure of supply to aluminum melts.

• If the mine project is delayed because of the delay in the establishment of the power supply this can be offset in the electricity price.

• There may be negotiated an overall discount of electricity price.

14.6 Scenarios for electricity use after mine Please confer response to question 5.1 and 5.2 - None closure

Since it is assumed that the life of the mine is significantly shorter than the hydropower plant life there is a need to find uses for the power after mine closure regardless of the plant will be fully paid.

An ammonia production at the Isua port, in Nuuk or in Manitsoq is an option but other scenarios should also be prepared.

14.7 Consequences

The above considerations, as well as recitals Please confer response to question 5.1 and 5.2. - None in my previous responses, may initially, result in a feasibility study prepared in cooperation between BMP and London

Mining. This study should explore the most advantageous economic performance of the overall project using hydro-based electricity for the project.

It should also be pointed out that the use of hydropower for electricity by the mine project involves a much higher value of each kwh, viz. 1.60 DKK per kwh than using an aluminum smelter approximately 0.10 DKK per kwh.

15. Landslægeembedet

No. Question Response from London Mining Response from BMP and/or DCE/GN Amendment to EIA/SIA

15.1 The Health Service has received the hearing According to the Guidelines for Social Impact DCE/GN: No environmental aspect None of VSB/SIA report for Isua iron mining Assessments for mining projects in Greenland the company has to describe health issues concerning if project and finds that the report raises a the project will change the current health status in number of questions. the project area.

It is the Health Service’s task to monitor the health of the population. We do not find that the report's description of the impact on public health is sufficient in its current form, in order to make it possible to provide a comprehensive response. However, the report gives rise to the following observations:

15.2 Effects on public health and quality of life Details on the content of the medical tests (pre- DCE/GN: No environmental aspect None In relation to the expected impacts on public employment medical check and annual medical health, the report states the risk of an examination as stated in 6.5.3 Health Services) to be increase in the incidence of sexually agreed with the Health Authorities. transmitted diseases, unwanted pregnancies

and abortions, HIV and tuberculosis. Alcohol and drug abuse is not considered to pose a major problem, as there will be a ban on

drugs in the camp, which in practice may prove difficult to enforce.

The actions which are likely to be effected to prevent are: health screenings, information campaigns in the camp as well as the limitations of the distance from the camp to Nuuk and the accessibility of the city except for occasional nights in transit in Nuuk.

These measures are relevant and may be sufficient to the extent that it actually manages to avoid the camp personnel to have access to Nuuk population on a larger scale. If it is shown that the workers are still going to be a long-term transit in Nuuk (due to weather conditions, technical problems, ice in the fjord, etc.) or staying on vacation / holidays, there may be need for further action. It is crucial that this development will be closely monitored.

Our Health Service would like to see a concrete description of the contents of the medical examinations envisaged.

15.3 Carrier Modes of resistant bacteria All employees will undergo a pre-employment DCE/GN: No environmental aspect None One factor not mentioned in the report, the medical check and annual medical examination as

77 incidence of new and resistant bacteria, stated in 6.5.3 Health Services. which represent a growing and very serious problem in many parts of the world, including in China. Bacteria that Greenland has so far been largely spared.

For example, Chinese personnel could be carriers of a number of new and in Greenland unknown resistant bacterial strains that besides creating serious problems for the individual, could pose a risk of infection to both the general public and to other patients in the study and treatment in health care. Such contagion can lead to increased morbidity, mortality for vulnerable / sick people, and lead to high costs for treatment, contact tracing, preventive measures, increased human resources, cancellation of patient care, etc.

For example, the need to close a ward because of the spread of resistant bacterial strains could paralyze the hospital and incur significant costs, as witnessed by the individual cases of MRSA (methicillin resistant Staphylococcus aureus), which has so far been found in Greenland. It is clear that the risk increases with the number of immigrants and the number of personal contacts with the public and the health care system. This will to some extent be 78

prevented by implementing vaccination and screening for entry in Greenland. One must be aware that every visit to the country of origin in contact with family / friends, etc. could be a renewed risk situation in relation to carrier state of resistant bacteria. Therefore, it may be necessary to consider launching screening of foreign personnel in contact with the health care system.

Measures and conclusion: 15.4 In order to achieve the desired effect in relation to the protection of public health, The details of the content of the monitoring plan for DCE/GN: No environmental aspect None the proposed health studies contain both the public health aspects to be agreed with the study infectious disease and carrier states. Health Authorities. The screening of carrier states must be organized by the disease patterns and resistant bacteria found in the areas laborer comes from.

It will be essential to ensure effective monitoring and reporting of both infectious disease carrying modes. The development must necessarily be monitored throughout the chain of risk factors from the development of disease and resistance patterns in the home country, the development of disease and carrier states in the camp and in the general population. This 79 monitoring should be done in close cooperation between the company and health authorities.

16 TIMMIAQ

No. Question Response from London Mining Response from BMP and/or DCE/GN Amendment to EIA/SIA 16.1 First of all, Timmiaq note that this is a This is a matter for the Grenland authorities. BMP: The environmental area related None comprehensive consultation material which to mining is regulated in accordance forms the basis for London Mining with best internationsl standard. Greenland NS 'application for an exploitation National Center of Environment and license for an iron mine project in Nuuk. Energy (DCE), and Greenland Institute of natural Resources are independent It is therefore important for Timmiaq to consultants guaranteering this. point out the importance of the precautionary principle enforced for this project. We do not want another “Maamorilik” where ignorance, we hate to use the term deliberately environmental pollution - has led to pollution of the bay, so the local population 20 years after mine closure still cannot collect clams and other animals in the area. 16.2 Comprehensive geochemical testing have shown BMP: Discharge to the nature has to Timmiaq is concerned about London that the depositing of materials from the mine in a follow international best practice and None Mining’s plan to deposit excess ore and deep depression of a lake (glacial lake with naturally the requirements in the government chemicals from the production of iron in turbid waters, no fish habitat and low biodiversity) approvals has to be set after guidance lakes near the mine. Much of this residue near the process plant will not lead to pollution of of DCE and GN. discharged into lakes will be the toxic sulfur. the fjord with chemicals, metals or other substances, Furthermore, it emerged during the public including phosphorus. Continuous monitoring of the hearings that Australia has experience with discharge from the lake will take place. the chemicals that London Mining plans to use for separating sulfur from the ore. In Australia it is advised not to discharge these chemicals in nature. With reference to the 81

precautionary principle Naalakkersuisut is requested to prohibit this, since you cannot know what secondary damage effects this can have on an Arctic environment such as the Greenlandic.

16.3 It is not practical to have the pipeline transporting BMP: The BMP are well aware of None Timmiaq has noticed that London Mining iron concentrate to be a closed system (the process possible dust issues based on for intends to transport ore in pipelines. plant and port area are separated by 105 km). The example knowledge from mining in Timmiaq is not convinced that the excess water from the slurry will be dewatered and before Nalunaq and Seqi. The regulation water from the transport in the short or long being discharged to the fjord the water will stay in a related to dust issues will be focusing term does not pose an environmental risk to retention pond for 10 days for any suspended on the issues raised in the question. flora and fauna in Godthåbsfjord. We will, material to settle. When the water is subsequently therefore, based on the precautionary discharged to the fjord it will meet the water DCE/GN: Nothing to add. principle recommend that the excess water quantity requirements and will not contain is not discharged into the fjord, but recycled substances that are harmful for the environment. to furrow the ore forward. Timmiaq therefore propose that the pipeline be designed as a closed system where water is pumped back and re-used. Furthermore must the loading of the ships take place in a way that prevents dust to spread to avoid pollution. 16.4 None Timmiaq notice that the slurry subsequently This is a matter for the Greenland authorities. BMP: There are international rules will be transported away in the large tank related to ballast tanks. Requirements ships. Because these tankers arrive without related to ballast tanks in the cargo to Greenland, they will have to empty government approvals will be based on the ballast tanks in Nuuk Fjord. This will these international rules and can even represent a great danger of alien invasive be more strict than these rules. It is species and to permit this would be possible to follow the maritime related irresponsible. As a minimum, the conventions even if these are not yet 82

international environmental rules that apply ratified. Requirements related to ballast to Antarctica, should also apply in Greenland tanks including replacement of water and in the northern Arctic. will therefore be regulated in the government approvals. Knowing that international work on common rules against contamination by emptying DCE/GN: Reference is made to answer ballast tanks currently takes place Timmiaq 7.1. still strongly recommend that, until there is evidence that Ballast Directive is a safe environmental regulations, it is required that the ships do not carry water from other ecosystems and empty their tanks in Greenland waters or waters where the current head towards Greenland waters. It must be a minimum requirement that ships from foreign continents arriving to Greenlandic waters imposed under way to replace the water in their ballast tanks every other day, so that the local flora and fauna are not affected by total strangers species. Ships in ballast tanks include water not originating from Arctic waters to be denied admission in Greenlandic waters.

16.5 This is a matter for the Government of Greenland BMP: The Greenland Government will None Also make sure that the fuel used in ships' and the general practice in the shipping industry. not allow use of heavy fuel in inland engine on the many freight and ore waters. transport is not the polluting heavy fuel. Burning of heavy oil is extremely toxic, and DCE/GN: Reference is made to answer you do not know the environmental impact 7.1 and 13.11. of this pollution in the Arctic. Since it is

technically possible to sail with easier and less polluting fuel the Self-Government as a precautionary principle, should require that all navigation in Arctic waters only use light fuel. Naalakkersuisut should in general work on that in cooperation with our neighboring countries and make it a general requirement that navigation in the Arctic only happens with the least polluting fuels. 16.6 LM will ensure compliance with the strictest DCE/GN: Nothing to add. None Generally, Timmiaq is concerned by the regulation in connection with shipping in the fjord to increased transport in the fjord and the minimize the risk of accidents, including oil spill. environmental risks arising from such a large port on the bottom of Godthåbsfjord, as envisaged. Timmiaq fear that the port facility could lead to incalculable consequences for the ecology of the inlet system. In particular, we are concerned about Nipissat Sound. The sound is currently designated as an IBA (Important Bird Area) and it is a candidate to be Greenland's next Ramsar site. 16.7 The entire Nipissat Sound is a natural area This is a matter for the Greenland authorities. BMP: Rules related to shipping and None with large numbers of waders during However it should be noted that staff at the mine is possible related special status zones will not allowed to leave the mine area during their be set in the government approvals. migration periods. It is probably Greenland’s working period , for example to visit the mentioned most important staging ground for waders. islands. DCE/GN is aware of the importance of The area also provides food for large Nipissat Sound. The area will be at risk numbers of eider, king eider and other ducks of exposure, if accidents happen in the in the winter. The sound makes it the most mouth of Godthåbsfjord, but will not be unique and important area for birds affected by the daily throughout Godthåbsfjord. operations.Consideration to the area will be handeled through the regulation

and emergency preparedness of 84

Timmiaq has on several occasions observed shipping.” up to 700 individuals of ringed plover on the shallow mud flats in the sound, like other waders as turnstone, purple sandpiper, dunlin; knot is seen in considerably numbers. Rare North American species are also observed annually. Guillemots, thousands of eider, king eider and other ducks feed in the sound.

Nipissat Sound with its shallow mudflats especially sensitive to even small oil spills and other pollutions. With increased traffic of oil tankers and other cargo ships, the potential for contamination of this unique sound increases. An accident of greater or lesser extent or careless discharge of ballast tanks could result in substantial and irreparable damage to the shallow areas and the flora and fauna.

Similarly, it must be assumed that the discharge of sewage and other pollution from buildings in connection with the mine, and the shipping and port activity will flow into the strait and result in increased pollution to the detriment of the entire ecosystem of the Sound.

Such contamination will also impact the black guillemots, eider, king eider, lump sucker etc. are commercially exploited by hunters in Nuuk, and thus have an impact on an already pressured industry.

Timmiaq also notes the following of specific relevance to the birds in the affected area:

In the immediate vicinity of the port area in Qugssuk are a number of smaller islands with a nice stock of a number of breeding gull species, possibly Arctic tern and eider. These islands must ensure a zone of sailing and prohibited during the breeding period.

16.8 It must be examined whether the "tailings" The analyses that have been carried out show that DCE/GN: Reference to answer 7.1 None or other discharged materials could affect pollutants from the mine will not be discharged into mussel beds in the northern part of the fjord. To document that the environment is not Godthåbsfjord. These mussel beds have a being polluted a monitoring program will be significant importance as a food source for a implemented. The program will be designed in large part of the Greenland wintering cooperation with the authorities. The monitoring population of eiders from Greenland and will include mussels near the port area. The results Canada. Including whether there can be no will be compared with data from mussels collected accumulation of such. heavy metals in three different years before mine start. mussels and subsequent eider ducks and humans / predators. See also response to question no. 4 in the minutes from the 3rd public hearing meetings .

16.9 In connection with the construction of London Mining will ensure that disturbance of birds, DCE/GN: Nothing to add. None various port facilities and other installations, and in particular bird colonies, is minimized during ensure passport late the measures so that construction and operation of the mine (cf the EIA, there is no disturbance, for example. section 6.2.2 LM will furthermore ensure that 86

helicopter traffic, navigation etc., of the existing regulation by the Greenlandic authorities, significant bird cliffs that are in the inner for example that helicopters must keep well clear of part of Godthåbsfjord and particularly by bird colonies, are followed. Ilulialik's mouth. 16.10 There should be examination of how and A draft monitoring plan is included in the EIA section DCE/GN has prepared a document where large populations of geese (Canada 10. The plan will be further elaborated before mine summarizing the proposed monitoring None geese and white-fronted geese), which starts operating in co-operation with the Greenland programs. The document includes raster spring and / or fall on the low-lying authorities. This will most likely also include surveys monitoring of geese. Narssarsuaq area. Including whether there of staging geese. It should be noted that mine staff should be restrictions on traffic in the area will not be allowed to leave the mine area at any north of the road at certain times of the time, except for the scheduled rotations to return year. A study of this issue may want. made home. by flyrekognoscering in May and September.

16.11 The level of impact on birds (geese, etc.) The monitoring program mentioned under 16.10 will DCE/GN: Nothing to add. from blasts at the open pit should be also monitor potential disturbance from blasting. None examined so that any harmful effect can be London Mining is aware that during a short period in eliminated. spring the mine area is potentially an important staging area for the endangered Greenland White- fronted goose.

16.12 Finally, Timmiaq encourage Naalakkersuisut Hydropower is not an option to ISUA project. Please DCE/GN: Nothing to add. None to the interests of the environment imposed see responses to question no 5.1; 5.2; 12.3 and 14. on London Mining, using hydropower rather than a CO2-polluting diesel power plant. The financial analyses were carried out by SNC There have during the civil hearings have Lavalin, an internationally recognized large expressed doubts about London Mining engineering firm. calculations of costs - costs and profitability through the use of hydroelectric power rather than diesel power. It is Timmiaqs believe that with regard to the precautionary principle must always be required to serve at least polluting technology used, ride possible.

16.13 Timmiaq must finally ask Naalakkersuisut to This is a matter for the Greenland government. BMP: This entered into force on January Ingen environmental and natural assessments of 1st 2013 mining projects now and in the future are None not treated in BMP and should be shifted to treatment in the Ministry of Nature and Environment, now Ministry of Domestic Affairs, Nature and Environment.

17. Grønlands Arbejdsgiverforening

No. Question Response from London Mining Response from BMP and/or DCE/GN Amendment to EIA/SIA 17.1

Refered to the invitation on 16 August 2012 No response is required. - None of the responses to the Social Impact Assessment (SIA) and Environment Impact Assessment (EIA) in the London Mining Greenland's application for an exploitation license for iron mining project at lsukasia, Nuuk.

1: General

Greenland’s Employers' Association (GA) main point is that the process of designing the upcoming Impact Benefit Agreement (IBA) is to ensure that the greatest possible value returns to Greenland.

The purpose should be to provide an effective, socially and economically sustainable value added in the country. It must be in the form of a long-term capacity building in the local economy, so companies will be able to take on an increasing number of tasks within the mining sector in general.

The purpose will be achieved through maximum involvement of local businesses and their employees in the tasks to be solved in connection with both facilities and operating iron mine.

It requires that in IBA'en formulation of clear and precise requirements for London Mining that the local is the first choice for jobs and sub-contracting, and that London Mining is imposed a proactive responsibility so the requirements and objectives, set in IBA'en, gets achieved.

GA would strongly encourage the industry and other relevant stakeholders now get involved in collaboration in the formulation of these requirements to the IBA, and that around this process establishes a clear cooperation and decision-making structure. Otherwise fears GA serious that economic growth and supply of skills and local jobs-as the great iron mining project is to cause, doesn’t become a reality or only to a very limited extent.

Greenland’s Employers' Association (GA) has based on its consultation response to the SIA comissioned this drafted report: 'Raw materials and sustainable economic growth' (Copenhagen Economics, October 11, 2012).

17.2

GA agrees with the report's conclusions and recommendations, and will at least by Comment is a matter for the Government of BMP: The issues will be a part of the None reference to the Canadian experience Greenland . Impact Benefit Agreement highlight Best Practice-experiences learned: negotiations.

1. Got a good started: In the first place, among others, that "lmpact benefit Agreements ... has to describe the positive effects the project has on the area besides the public revenue. More specifically must the benefit plan include setting strict goals for the extent of local workers among others, apprenticeships, skill upgrading courses, funding education, research and development and the use of subcontractors. The IBA should basically ensure that local people have first priority. If a local jobseeker meets a vacancy qualification, he has to be hired at the expense of non-local job seekers, who are also well qualified. "

GA recommends that now, in collaboration with relevant stakeholders, take steps to establish a benefit plan, which together coordinate and prioritize social demand for iron mining project in order to achieve maximum impact in negotiations. 91

17.3 Second follow-up: "Follow-up on such IBA- Comment is a matter for the Government of BMP: The issues will be a part of the None goals and ongoing dialogue with relevant Greenland . Impact Benefit Agreement stakeholders about various challenges that negotiations. arise and coming new initiatives. It is quite complex in Canada, where stakeholders are among the Aboriginal groups, unions, employer associations, etc. at a very local level (often it is the Aboriginal groups that own the resources the mining company wants to use, see Land Claims Agreement), on the territorial government level and at the federal government level. "

GA recommends that now in cooperation with relevant stakeholders established an effective monitoring mechanism / organization that can supervise the fulfillment of the objectives and requirements that come into the benefit plan.

17.4 Third, a well-functioning system of Comment is a matter for the Government of BMP: The issues will be a part of the None enforcement: "this ensures that Greenland . Impact Benefit Agreement discrepancies between everything from negotiations. economic to cultural and environmental agreements can quickly be solved efficiently. Within the oil extraction has in Canada been set up a regulator (C-NLOPB2) to monitor and enforce agreements, including the IBA and environmental and safety obligations. C- NLOPB acts as a link between the federal government and provincial government. In 92

the event of breaches of agreements or obligations, can the C-NLOPB respond using proceedings, stoppages or at worst even retreatment of agreement."

GA recommends that in relation to the iron mining project established a Greenlandic enforcement system with the same overall purpose.

"Based on such a structure is the content of the IBA key to a good start. Below shows the Canadian experience that two factors largely control how successful the community is in negotiations with the mining company. Both conditions agree on the objectives and the ability to stand together and speak with one voice. "

17.5 2. Proactive outsourcing Comment is a matter for the Government of BMP: The issues will be a part of the None The report also highlights that one thing is Greenland . Impact Benefit Agreement that the IBA specify the extent of negotiations. outsourcing from mining company to the local economy. Another thing is, "... that the outsourcing sits in a permanent strengthening and upgrading of business requires a more proactive outsourcing strategy from mining companies. An example of such an approach from the Diavik mine. The company appealed a proactive approach to outsourcing, which ensured a high degree of outsourcing and helped local businesses to spot subcontracting opportunities ... " 93

GA recommends that the requirement for proactive outsourcing in elevant extent gets integrated in the IBA for iron mining project. 17.6 3. Strong bonds Comment is a matter for the Government of BMP: The issues will be a part of the None From the Canadian experience is highlighted Greenland . Impact Benefit Agreement in the report that "Mining companies negotiations. operate in local communities for several decades. This long-term presence can be used to strengthen the bonds between the mining company and the community."

"For this purpose can the tangible and measurable corporate and social responsibility (CSR) objectives be a good tool. Employer's Association for mining companies in Canada (Mining Association of Canada (MAC)) launched in 2004 six TSM principles reflecting mining companies' behavior in the field. .. "

GA recommends that precisely the efforts to promote CSR in Greenland - including led by CSR Greenland - also naturally need to be extended to include the new industries that now are on their way to Greenland in the development of the mining sector. These requirements should also be formulated in the design of the IBA. 17.7 II: Specific comments on the SIA

Greenland’s Employers' Association (GA) has Noted and these are issues in the IBA discussions. - None gone through London Mining's recommendations for tasks to be offered. Here are used the terms 'local', 'mixture' or 94

'international'.

The GA's opinion that the tasks that can be raised locally, has to be offered locally under the current Greenlandic rules for the provision of construction tasks (AP 95) or other known contractual basis, if it is not about construction works.

GA recommends that London Mining's definition of "mixture" is changed, so that tasks both can be offered to a joint venture between local and international companies, and that also must be able to divide tasks so that parts of the tasks are offered locally, and that other parts are offered internationally.

17.8 To ensure that the Greenlandic companies Comment is a matter for the Government of BMP: Noted. None and the Greenlandic workers get such a large Greenland . proportion as they can lift, it is important that both the Greenland Employers' Association and SIK are closely involved in the negotiations on the IBA. See also the general recommendations in section I: 1 – 3 17.9 It is the GA's opinion that the Greenlandic This is a matter to be discussed and negotiated in - Will make companies can be involved in a significantly the IBA. some larger proportion of the tasks than what changes in London Mining recommend. the table.

GA's recommendation for what is offered locally respectively mixed or international, is 95

shown in the table below.

GA has made the assessment on the basis of the opportunities for competition in local offering.

Cf. Table Details Descriptions below

17.10 Ill: Concrete comments to the EIA BMP: Expenditures related to extra CO2 None emissions will be paid by the polluter It is not clear from the EIA, who should pay Comment is a matter for the Government of (company). In Denmark's ratification of the for the extra CO2 emissions. It should be Greenland . Protocol, Greenland will be given a apparent from the EIA, who bears the cost territorial exemption, which means that thereof. Greenland does not bind to the high GA is of course available for any questions reduction commitments. and clarifications on this consultation.

Details Descriptions:

Potentielle London År GA·s aftaler Minings Indstilling Boring lnternationalt 2012 Blanding Logistik support Blanding Fra 2012 Blanding Tilsyn på stedet Internationalt 2012 lnternationalt Undersøgelse Internationalt 2012 Internationalt Helikopterstøtte Lokalt Fra 2012 Lokalt Pakke for civilt lnternationalt 2012 Lokalt/blanding byggeri Anlægsleire Blanding 2012 Lokalt Havnens Blanding 2012 Lokalt

Genereller servicelagerplads på Lokalt Fra 2012 Lokalt

pladsen Lufttransport Blanding Fra 2012 Blanding

Generel pakke Internationalt 2013-2015 Internationalt

forGeneral fabrik pakke lnternationalt 2013-2015 Lokalt

forPermanente civilt byggeri Blanding 2013-2015 Lokalt lejre Pre-stripping af Blanding 2013-2015 Lokalt/blanding mine

1 Se bl.a. Kapitel 4: Læringen fra Canada i 'Råstoffer og bæredygtig økonomisk vækst, Copenhagen Economics, 11.oktober 2012, Grønlands Arbejdsgiverforening'. 2 Canada-Newfoundland and Labrador Offshore Petroleum Board (CNI.OPB). 3 Råstofdirektoratet (2012), s.46 4 Råstofdirektoratet (2012), s.40

18. Kommuneqarfik Sermersooq

No. Question Response from London Mining Response from BMP and/or DCE/GN Amendment to EIA/SIA 18.0 Kommuneqarfik Sermersooq is grateful for General introduction – no response is required - None the opportunity to contribute to this consultation and would like to take this opportunity to point out that it is the hope of the municipality that an exploitation license can be granted for London Mining’s iron mining project at Isukasia. It is the municipality's general assessment that there are no social or environmental issues in the material presented for public consultation that cannot be solved in a satisfactory way in connection with the construction and operation of the mine as described in the consultation documents.

Kommuneqarfik Sermersooq is therefore positive to the new opportunities the described project can bring to the society. This include a rising income generation, increased societal proceeds to the development of welfare, building experience in mining, development of new education, job and career opportunities and the creation of jobs and the resulting opportunities for tasks to other Greenlandic

companies.

A project of this scale is not without risk and requires of course a serious assessment of both the social and the environmental impact. A project of this scale cannot avoid creating some friction and concerns about impacts on the environment, preparedness and risk of accidents, impacts on the local community and its ability to absorb them. Further is Kommuneqarfik Sermersooq aware of issues related to use of outside labor and its potential for labor organizing and acceptable wages and working conditions. On the latter issues reference is made to Kommuneqarfik Sermersooq comments regarding the consultation on "Act of Inatsisartut No. xx of xx. xxx 2012 on construction works at large scale projects ".

Isua iron mining project can in a number of ways be considered from a national precedent perspective, and thus it is essential for Kommuneqarfik Sermersooq that the project will be carefully assessed, that it has been through an extensive information and consultation process. It should be essential for both the company and BMP that all stakeholders have an opportunity to be heard in the consultation process. 18.1 Social sustainability (SIA)

It is a clear aim in Kommuneqarfik Statement by Kommuneqarfik Sermersooq. BMP: Many of the issues mentioned will None Sermersooq strategy on raw materials that be addressed in the IBA process. 99 local workers and companies are to ensure the best possible conditions for active participation and development of skills in relation to a mining / large scale project. Therefore, Kommuneqarfik Sermersooq, both has this focus in this consultation and in the coming Impact Benefit Agreement (IBA). Kommuneqarfik Sermersooq notes that the revenue from taxes duties from such a business project is of course important, but equally wants Kommuneqarfik Sermersooq the project will contributor in the secondary effects such as capacity building and development of local workers and enterprises with use of international experience. This is achieved through close dialogue with education institutions, vocational educations and similar institutions (see descriptions in Annex 3 to the EIA).

"The Mining Act provides the opportunity for that the Greenlandic economy is given priority to tasks related to the exploration and exploitation of mineral resources, if companies are competitive in terms of prices and quality. Kommuneqarfik Sermersooq wants to support the development of skills at company level in order to meet the demands of t BMP and industry, by creating 100 a framework conditions for the development of local businesses. "

Kommuneqarfik Sermersooq want to emphasize the importance of the developing the relevant sectors in the existing Greenlandic business in parallel with a project like this. Through dialogue with industry stakeholders Kommuneqarfik Sermersooq suggests that there will be establishes a clear and concrete strategy for how Greenlandic companies are been prepared and engaged in the iron mining project.

There are several relevant bodies (both national and regional) through which London Mining has the opportunity to seek cooperation, in order to identify and implement business development initiatives. In collaboration with eg. Sermersooq Business Council, Sulisitsisut and Rambøll Greenland A / S. The sooner this dialogue and, not least, the next steps are fleshed out and realized, the quicker the Greenlandic companies have the opportunity to enhance their competitiveness and chances to win assignments.

101

"It is crucial to address the areas of knowledge and skills in the local economy. This could be carried out by encouraging the conclusion of strategic alliances, consortia, development of quality control and certification systems, etc. "

A particularly important consideration is to ensure great attention to which if the assignment that will be offered to local companies. This can imply for a need for special flexibility in relation to spilt-up of large contracts so they become more available for local companies. Kommuneqarfik Sermersooq is aware that it may be desirable for London Mining to engage with few companies to larger contracts, in these cases, large foreign contractors also weighed on their ability to enter into strategic alliances with local companies. Kommuneqarfik Sermersooq is convinced that there will be a number of benefits for London Mining by giving priority to cooperation with local companies, including local knowledge such as local weather conditions, valuable experience with the local ground and underground, and a deep knowledge of the legislation and environment and relations to the business in Greenland, etc. 102

"The development of mineral resource requires a coherent strategy in the areas of business development, labor marked, facilities and environment. Kommuneqarfik Sermersooq assesses on-going the need for alignment of management and cooperation between the various agencies. "

18.2 Within the areas where municipality is the London Mining will provide additional detailed - None authority, Kommuneqarfik Sermersooq will information to Kommuneqarfik Sermersooq on the ensure a smooth handling of project start- organisation and which services are expected from up, construction and subsequent operation. the municipality during the whole process For this to be realized, it is necessary that the Kommuneqarfik Sermersooq is organized dedicated to this task. At the same time, it is necessary for Kommuneqarfik Sermersooq to receive more information on how London Mining will organize themselves, as well as additional information about in what ways and to what extent London Mining expects to draw on municipal services. 18.3 Waste management. This applies to in waste management, especially in a phase before London Mining Comment noted for future detailed planning of BMP: Requirements related to waste None will set up their own waste disposal facilities. waste disposal during construction phase. If it should management will be set in the In this specific regard, Kommuneqarfik become applicable, London Mining will take the government approvals. It is the full responsibility of London Mining to Sermersooq wish a deeper knowledge of initiative to discuss this further with Kommuneqarfik London Mining expectations of quantities remove waste and pay for the costs Sermersooq in order to make the planning in and types of waste to be handled by the related to this. municipality. When there is a request to accordance with the plans of the municipality. draw on Kommuneqarfik Sermersooq DCE/GN: Nothing to add.

services for handling and disposal of waste, it is the starting point for the municipality 103

that this must be based on agreements See also answer no. 11 from the 3rd Public Hearing between the municipality and the company meeting (24. September 2012). on commercial terms. It is essential for Kommuneqarfik Sermersooq to highlight that in a exploitation license it should be clear that the municipality has no obligations regarding waste disposal from the company and the municipality's possible involvement in waste disposal for business can be done on commercial terms.

Re. waste management for the company reference to the SIA Report page 96-97 and page 163, and the EIA Report on pages 26- 27, pages 79-81, pages 149-150 and pages 175-176.

18.4 Jobs and needs for housing in Nuuk. Additional, Kommuneqarfik Sermersooq would like to gain deeper insight into The amount of persons (50 – 100) is stated for the None whether London Mining, now and in the mine life (operation). - future, expect an expansion of facilities and number of employees physically located in Nuuk, for example with regard to the establishment of headquarters and However, this will not be the case during the administrative functions. If London Mining construction. expects a higher growth in this connection, it would be appropriate for all parties that Kommuneqarfik Sermersooq are advised in due time. This may, for example relate to If it will be the case, London Mining will take the land allotment and approval of construction initiative to discuss this further with Kommuneqarfik projects, construction of staff housing, Sermersooq in order to make the planning in childcare places and schooling for the 104

children of employees and other issues of accordance with the plans of the municipality. local government units.

Regarding expansion of its activities in Nuuk see SIA page 138, which include between 50- 100 people with long-term living in Nuuk. 18.5 In addition, Kommuneqarfik Sermersooq London Mining will cooperate with the different - None wish as a general principle, the departments of the municipality during the planning, establishment of cooperation with the for both construction and operation phases. relevant parts of the municipality administrations, in order for the administrations to be able to participate in the project's construction and operation as appropriate as possible, from the reasons administrations have to carry out. In this respect, Kommuneqarfik Sermersooq would like to discuss proposals from the company on action plans for cooperation with local labor and business administration as well as with Sermersooq Business Council. This will be of benefit from all sides in the engagement of local enterprises and labor, as well as the necessary education, training and development of skills.

18.6 Airstrip None It appears from the material that London Mining will not initially plan to build an Comment noted for future detailed planning and airstrip in the license area, for aircraft of the discussions between the relevant parties. type Dash 8 or similar. Thus, the air transportation of passengers and freight had to go through Nuuk Airport. Kommuneqarfik Sermersooq does this prove that the 105

transportation needs for London Mining through Nuuk Airport push for an extension of the airport and extension of the airstrip, therefore, Kommuneqarfik Sermersooq proposes to initiate concrete discussions on the extension of Nuuk Airport between the relevant parties, including London Mining. 18.7 In general, the above factors are considered London Mining will cooperate with the municipality. - None as examples of considerations that will be relevant if an exploitation license will be granted and the construction of the project have to start: Kommuneqarfik Sermersooq need a clear understanding of how London Mining intends to organize themselves in order for Kommuneqarfik Sermersooq can make the necessary preparations. Kommuneqarfik Sermersooq is looking forward to a direct dialogue with London Mining and BMP on these points, see also the recommended collaboration between the company and the municipality on page 164 of the SIA.

"Workers of the Municipality of Sermersooq must be qualified and com-petent in relation to mining industry. Basic skills such as language and safety education, common core courses and similar should be encouraged. "

Construction and operation of the iron mine will require significant inflow of skilled and unskilled workers from various sectors of construction, including construction, mechanical installations, erection of steel 106

structures, electrical installations, concrete work, automation and control, etc. This will be both a challenge and - in case of success - a strengthening of the Greenlandic labor marked. During the period up to and under the start of the project a significant upgrading of the Greenlandic labor will have to take place, so that a number of the employees could come from the Greenlandic workforce. This may also lead to such an extent that the well-functioning employees from their current assignments will apply for the iron mine, and thereby result in the existing positions in for example Nuuk be open for new employees.

This may provide an opportunity to people who were previously unemployed, can undergo training and skills development to be included as permanent employees of the Greenlandic local environments. It should be a common goal of the establishment of the of the mine, that previously unemployed are upgraded and included in permanent employment as a result of the mine establishment. 18.8 At the same time, discussions should take London Mining will participate in these discussions. - None place between the Company, BMP and municipality on how to measures and mitigate the adverse effects on the local labor market in Nuuk. This is to avoid a shortage of skilled labor in Nuuk in certain sectors and to avoid local overheating in the economy.

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18.9 Specific comments on SIA. The organisation On page 69-70: Kommuneqarfik Sermersooq Actions will be taken. - of has implemented organizational changes Kommune- and the report's description of the organization and the organization is no qarfik longer valid. New and updated material can Sermersooq be transmitted by contact with the mayor’s will be secretariat. updated on p 69-70 (DK version) 18.10 On page 135: The submitted contract Comments noted and will be dealt with in the IBA - None packages are considered unambitious for the negotiations. Greenlandic industry in order to maximize their participation in the project. This may be the case in categories such as "Construction Camps", "Ports storage area", "General package for civil construction", "Permanent camps" and "Pre-stripping of mine." This issue is expected to be subject to further processing in determining the terms in the license and in a IBA negotiation process. 18.11 On page 142-143: Section 6.1.4.2. describes London Mining is in contact with the business - None a number of possible positive effects of council. It is not expected the ISUA will have tourism in Nuuk area, based on an increased negative impacts on tourism. In fact, it will help the local demand of tourism activities as a result developmetn of such industry. The majority of of the establishment of the mine. The workers will be living and working in their camps. company should be ask specifically to obtain Sermersooq Business Council's assessment of whether there also may be negative effects on tourism of the mine construction, for example with regard to cruise tourism to Nuuk. If it is the case, that there may be

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potential negative effects on tourism, apart from competition for accommodation capacity, this should be identified and there should be suggested possible mitigating measures. 18.12 On page 162: In the material is mentioned as London Mining will share detailed plans on the - None an example the logistics of person via Nuuk. logistics of personnel with the municipality. Kommuneqarfik Sermersooq would like to hear more about the plans for those cases where a large amount of employees potentially could "strand" in Nuuk due to weather or other delays. Especially the plan of management this situtaion, and whether it is expected that Kommuneqarfik Sermersooq will have a role in these situation. 18.13 On page 168 and 169: Kommuneqarfik London Mining will discuss this further the - None Sermersooq is aware of the listed risks of municipality. social conflicts during the construction phase and operation phase respectively. It should be expected of London Mining, that London Mining continuously monitors the social interaction between the community and the employees on the project and take the necessary precautions if adverse situations should arise, see also on page 171-173 for the proposed mitigations measures. Kommuneqarfik Sermersooq hopes that the inter-relationships between project staff and the local community will be further discussion with the municipality, both to minimize risks and, if possible, to create opportunities for positive social interaction between the community and the staff of the project. 109

18.14 For logistics of goods, stated at for example London Mining will advise the Municipality. - None at page 163, the Kommuneqarfik Sermersooq notes that the municipality wants notification in due time, if there is a need for building and industrial areas in Nuuk - this can play a significant role in the municipality's existing land and planning strategy. 18.15 Kommuneqarfik Sermersooq welcomes the No response is required. - None draft monitoring plan, as found on page 210- 211. A thorough and continuous monitoring will be an essential tool in cooperation with the municipality and other stakeholders. 18.16 Environmental impacts. None

"Kommuneqarfik Sermersooq want the The statement by Kommuneqarfik Sermersooq is - exploitation of raw materials from the noted Greenlandic nature is on a sustainable basis, and with utmost respect for the sensitive Arctic environment and the local population. The people of Greenland have traditionally lived by nature. Fishing and hunting are still a big part of the culture and an essential part of the Greenlandic diet. There are important breeding and resting places for birds, fish and animals, which must be taken utmost account of projects in the open country. " Overall, Kommuneqarfik Sermersooq expects that the strictest possible measures to protect the environment will be taken. Both with regard to the choice of technical solutions and in the choice of materials and in the ongoing monitoring and reporting 18.17 Contingency Kommuneqarfik Sermersooq lacks detailed 110

information on contingency plans related to Comment noted for future detailed planning and BMP: Contingency and emergency None the environmental risks of the project, work on contingency planning. related issues will be regulated in the including shipping to and from Nuuk port rd government approvals. and the port facility at Taseraarsuk. The See also answer no. 3 from the 3 Public Hearing expected involvement of Kommuneqarfik meeting (24. September 2012). Sermersooq in area of contingency plans and in license is not finally described. Kommuneqarfik expect that the "emergency" is elaborated separately in terms of the license.

It should be stipulated that the company is financially and operationally responsible for both anti-pollution preparedness in all areas, including mining area, pipeline, port facilities and transport within the limits of the municipality. The extent of Kommuneqarfik Sermersooq’s operational preparedness is extremely limited and the municipality will not have opportunities to be engaged in these type of task. Emergency planning and pollution control discussed in EIA include in Section 7.4 (page 241-248) and in Annex sixth.

18.18 Shipping. Regarding shipping Kommuneqarfik Sermersooq expects that the conditions of Comment noted for future detailed planning and None the exploitation permit will include the negotiations with BMP and DMA. conditions for shipping in connection with DCE/GN: Ships associated with the Isua the project. Including conditions on the use project must, like vessels participating of fuel, taking into account the potential in oil exploration in Greenland waters, rd damage to the environment in pollution See also answer no. 1, 2, 3 from the 3 Public

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cases, conditions on ships' design and Hearing meeting (24. September 2012) not use heavy fuel. (see 13.11). construction suitable for sailing in icy waters, conditions on emergency board to combat oil pollution conditions on the use of pilot for navigation in the baseline and conditions on the management of ballast water so that there is no risk of contamination of the marine environment with foreign substances and organisms from ships' ballast water. It should be noted that both approaching the coast of Nuup Kangerlua and by sailing into the fiord is a significant risk to both grounding, collision with ice or other vessels. 18.19 Furthermore, and in line with the document Comment noted. None "DCE / GNIR comments on EIA for Isua project, Section 9", in the EIA there seems to DCE/GN: Nothing to add. be insufficient evidence of effects on marine mammals, fish and birds of underwater See answer no. 38 from the 3rd Public Hearing noise from the increased and heavy ship meeting (24. September 2012) traffic in Nuup Kangerlua with large ships. Kommuneqarfik Sermersooq endorses DCE / Pinngortitaleriffiks comments and to request that the company be required to follow DCE / Pinngortitaleriffiks recommendations.

"Kommuneqarfik Sermersooq want the rd authorities to set high standards for limiting See answer no. 4 from the 3 Public Hearing emissions and accumulation of harmful meeting (24. September 2012) substances in the exploration and exploitation of raw materials." 18.20 Pollution Risks. Annually, there will be discharged about 7.4 million m3 process water (waste water) from The statement by Kommuneqarfik Sermersooq is BMP: There will be requirements in the None dewatering of suspended iron concentrate noted. government approvals. There will be for Taseraarsuk bay containing residues of exact temperature limits related to the 112

process chemicals, nutrients nitrogen and discharged water. phosphorus, and in addition, the discharged water is significantly warmer than the DCE/GN: Reference to 7.1. surrounding water temperature. This locally significant wastewater discharge and potential environmental impact should be monitored carefully, as well as there should be set acceptable levels for hazardous

substances in wastewater discharge.

In the material, it is clear that there will be discharged with the process chemicals to See also answer no. 4 from the 3rd Public Hearing both the fresh water reservoir and the meeting (24. September 2012) marine environments. Since there is a BMP: There will be requirements in the possibility of a potentially harmful effect on government approvals.

the environment from the process used chemicals, it is desirable that the discharge of these minimized. It should be examined with reference to best available techniques on the desired used chemicals can either be avoided, replaced by less hazardous chemicals or completely removed during cleaning in the process. In any case, Kommuneqarfik Sermersooq requests introduction of limits and monitoring programs for discharges of hazardous None substances and require adequate techniques for the mitigation of environmental impacts. 18.21 Significant amounts of dust and particles are expected to be released into the BMP: There will be requirements in the environment in relation to the project. Best The statement by Kommuneqarfik Sermersooq is government approvals. None available technology to reduce emissions noted. should be used in the project. DCE/GN: Reference to answer 7.1. Kommuneqarfik Sermersooq expects that one will be very aware of this. Additionally, 113

Kommuneqarfik Sermersooq recommend emissions of soot particles to minimized. 18.22 Caribou.

Regarding the influence of the population of The statement by Kommuneqarfik Sermersooq is BMP: There will be requirements in the None government approvals. caribou in the area, BMP are requested to noted.

ensure that the negative effects of the DCE/GN recommend that use of the population will be avoided as much as sites up to the concession area by the possible. Particularly BMP is requested to caribou population is monitored. On consider specific rules for the activities in this basis, the needs for specific rules the area during the period in May and June for road traffic in the caribou calving when the rolls calve. period will be prepared 18.23 During use of raw materials this has to be The statement by Kommuneqarfik Sermersooq is BMP: The Greenland Government is None sought with the use of the purest possible noted. supporting the companies in finding the and most energy-saving technology to limit best hydropower solution for all the emissions of greenhouse gases. relevant mineral projects. It is also a In assessing the different mining projects in requirement in the guidelines that the municipality, the Kommuneqarfik hydropower has to be considered as Sermersooq will maintain principles of the part of the project. The hydropower Mineral Resources Act to use potential has to be considered with environmentally friendly technology and a respect to the already excisting high level of protection of the environment, hydropower scenario in the area. A nature and human health ". scenario with hydropower at a later stage in the process is also considered. Unfortunately, Kommuneqarfik Sermersooq

has noted that the company analysis does DCE/GN: Nothing to add. not support the possibility of developing

hydropower as part of the overall project. Please refer to the financial and temporal perspectives, at the same time while the available water resources will not only be able to support 100% of the energy needs.

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Kommuneqarfik Sermersooq must ask the Selfgovernment to consider the possibility

of establishing hydropower supply for this and possible other industrial projects, and The statement by Kommuneqarfik Sermersooq is demand the use of environmentally friendly noted technology and energy such as use of hydropower, to the extent that it can be implemented economically and practically. From the point of view of the municipalityshould one on not prevent the possibility of hydropower supply to the Isua project, even if a relevant hydropower alternative may be established at a later stage and a different owner and operator.

Kommuneqarfik Sermersooq notes that the expected emission of greenhouse gases from diesel-based power plants in the Isua project, in large numbers is equal to the total national emissions of greenhouse gases in Greenland today. This is a dramatic increase in our emissions of greenhouse gases and at the same time a relatively small contribution to the emission of greenhouse gases worldwide.

18.24 Other comments

"Kommuneqarfik Sermersooq want to be an The comments and statements by Kommuneqarfik None

115 active party in collaboration with businesses Sermersooq are noted and the Self Government of Greenland in the formulation of agreements on the implementation of the various mining projects, known as IBA, Impact Benefit Agreement, which establishes a framework for the parties' efforts such as education, use of Greenlandic companies and labor."

If the project is realized Kommuneqarfik Sermersooq would like to see the opportunity to develop a positive and engaging collaboration with London Mining and further with the many visiting workers. Kommuneqarfik Sermersooq want to help develop a good working relationship between the municipality, the local population and the company, including the creation of a good interaction between the residents of the community and the project's external employees.

Additionally, Kommuneqarfik Sermersooq would like to participate in solving other tasks of environmental or social nature, which can contribute to that the project will develop in a good balance with its surroundings, to the extent that it falls within the municipality's capacity, responsibility and competence.

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19. SIK

No. Question Response from London Mining Response from BMP and/or DCE/GN Amendment to EIA/SIA 19.1

Consultation responses in relation to consultation on London Mining's application The involvement of stakeholders in the SIA Processe BMP: It is always an assessment how None for an exploitation license for iron mining was carried out in accordance with the BMP the hearing process related to the project lsukasia in Godthåbsfjord at Nuuk. Guidelines and agreed with BMP. different mine projects should be

approached. In the LM case all relevant SIK has the following comments, which we in After London Mining obtains the license to operate, hearing materials have been published subsequent, chronologically will follow the London Mining is planning additional public on the national Nanoq.gl hearing portal topics that are set for the following: meetings focusing on recruitment of local employees. available for all residents in Greenland. The public review meetings was

focused in Nuuk, as the project is When in the presentation begins with Social Impact Assessment (SIA) will SIK already located in the Nuuk area. here to point out that we do not understand why all of Greenland have not been involved The SIK comments are noted as basis in the consultation process, as there is a for an evaluation of the process. national project that will come to impact throughout society. There is an insufficient basis for assessment by focusing only on a consultative process in Nuuk. The precondition for setting up and allow large- scale projects in Greenland, not least anchored in our entire society. SIK think London Mining Greenland here have neglected to involve citizens outside Nuuk. 19.2 SIK will also indicate here that the given Comment is a matter for the Government of BMP: Comment related to the given None consultation period has been too short in Greenland consultation period is noted and will be 117

view of the complex elements of the project considered in the evaluation process. consultation material that later is to form a durable solution and thus provide the basis for a final decision basis.

The current report material (SIA and EIA) submitted by London Mining represents total 613 pages. In addition documents that makes up 1046 pages.

The material, which latest was revised in July this year, must be submitted as a final consultation per today. The deadline for this consultation has been 8 weeks. In retrospect, it is SIK’s opinion that there has been a case of a too short hearing deadline sow the extensive material. 19.3 EXTERNAL LABOUR? THE CONSTRUCTION PHASE? - SIK particularly notes the whole handling of The ISUA project is a large construction project with None the issue of hiring outside labor. London short completion period. All workers must be skilled Mining writes in its report, that there is to be and able to perform from day one of their duties, for recruited from 1500 to 3000 skilled workers all positions. It is not expected to have large amount from outside the construction phase. SIK of on site training in construction techniques as it therefore questions what the difference between the definition of a skilled and non- will jeopardize the project in costs and schedule. skilled is? By the review of BMP's own However, all construction workers will undergo description of working conditions and job Health and safety training, environmental opportunities in the mining sector, SIK note protection training, and cultural sessions. Other that more than the half of the workforce in specific requirement will be determined in the IBA. construction work does not necessarily classified as skilled workers, but rather as manual workers who are trained on the site concerned.

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In the present material, it however not The estimated percentage of labour hours by the appears how many residents who would be locals are estimated and presented in the SIA report. identified to employ. Based on this information, the SIK must conclude that we cannot currently expect the employment of local labor during the construction phase. The workforce during the construction as well as the operation phases will only be skilled workforce. In relation to the current high unemployment here in Greenland, the SIK fail to see what steps have been taken to combat unemployment related to this project. On this background asks SIK therefore: How much of the outside workforce can rightly be filled by unskilled Greenlandic workers?

19.4 Will Naalakkersuisut launch unemployment- Comment is a matter for the Government of BMP: It is a focus area for the None fighting initiatives by hiring local workers Greenland . Greenland Government to have local during the construction phase? workers involved in the construction phase. This will also be one of the main topics at the IBA negoatiation meetings.

The Greenland Government has already And what has Naalakkersuisut initiated to initiated a number of activities in order encourage the upgrading of the available to upgrade the available workforce to workforce in the meantime? the upcoming tasks. Among others the initiative run by RAMBØL GRØNLAND by upgrading local companies to take part in the construction and production 119

phases has been launced. In addition to this the PKU funds (Development of Therefor the question of what conditions Personal Competences) administered Naalakkersuisut will attach to the project by the Department of Industry and around the aforementioned conditions? Labour Marked have already to a certain extend funded initiatives directed at supporting the mineral resources sector.

Issues related to education, involvement of local business` and involvement of local workforce will be a part of the IBA negoatiations.

It is a requirement that the public involvement is as big as possible but the requirements also have to be realistic.

19.5 The company also states that the effects of the direct local jobs during the construction It meant the availability of the skilled local work - None phase are dependent on whether the local forces. labor is available. SIK asks here, what is meant by this cryptic text which we frankly do not understand? And what explains the fact that London Mining write about what is locally available while attention is drawn to that the impact can be felt at the national level for a period of 3 years?

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19.6 OPERATIONAL PHASE?

With regard to the operational phase SIK will At the start of the operation, it is expected that no BMP: Immediately this does not seem None indicate that it is of utmost importance that local labour will be able to handle the technical as a high number, but this is one of the we get a complete and realistic picture of positions for most of the plants and equipment. It things that will be dealt with in the IBA how many residents, who will be recruited? was assumed that the Greenlandic workforces will negotiations. In the first 5 years of operation London be mainly working in the port operation, logistic and Mining expects, employment of 20% of the local. What is the reason for this service areas. The local people must be trained assumption? London Mining indicates that gradually to take other technical positions. even in the first 5 years allegedly can hire up Therefore, foreign experienced and qualified to136 residents. Complies with those 136 operators s will be needed at the beginning. souls up to Naalakkersuisut’s ambitions and expectations? Also during the operational phase, we are introduced to concepts such as Chinese operators and Chinese supervisors. Is the use of Chinese technology as a pretext to use Chinese labor? 19.7 SOCIAL DUMPING?

One of SIK’s central core issues is in relation The minimum wage of foreign construction workers - to the establishment of large-scale projects are defined in the large scale project Act. London None (thus London Mining) in this country are Mining will follow the law. The international understandably how compensation should contractors will bid the project with their take place? SIK has throughout the progress expectations on the salaries, however, will be so far insisted that the salary of outside labor naturally must follow the agreements required to fulfill the minimum wage requirement agreed by the parties on the Greenlandic by the government. It is impossible to request labor marked. This question has already everyone to bid with the same salary scale as it will given occasion to much discussion both at defeat the purpose of international bidding. home and outside Greenland’s borders.

Moreover outstanding question concerning the right to vacation, overtime payment,

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coverage of disease etc.

It is of course an indispensable requirement from SIK that the country’s agreements are carefully monitored as precedent on the other Greenlandic labor would otherwise develop into 'Klondike’-like conditions in this country, which in no way can serve to ensure that the desire to maintain a welfare state for all remains.

19.8 TAXES & FEES?

Based on this present presentation from Comment is a matter for the Government of BMP: The expected revenue from None London Mining it shows that when speaking Greenland taxation of the project depends on a of corporation tax and charges we are number of variable factors. talking about 28 billion DKK over 15 years Naalakkersuisut in cooperation with (under 2 billion DKK annually). In addition, external consultants is currently income of employees of 3.8 billion DKK over updating the economic expectations, a 15 year period (250 million annually). SIK including the revenue from taxation. would like hear if the total amount given to end up in the Treasury, corresponds to the There is no special arrangement expectations Naalakkersuisut have regarding the company’s taxable imagined? income. This can be seen from London Mining ISUA VSB page 11:” the SIK understand of the presentation on corporation tax for the Isua project will corporation tax that Naalakkersuisut intends to provide lsukasia project a special scheme, be calculated by Naalakkersuisut”. since the taxable income is determined

because of the earnings, as stated in the Naalakkersuisut has not imposed the statutory annual report? company royalties or resource tax. London Mining also states - while they refer Naalakkersuisut base its direct revenue 122

to the Law on Mineral Resources that on corporation tax and profit tax which royalties or other extraction fees will not be will give Greenland a share of the profit available for lsua project. Tax on profits and which to a higher extent than generated by extraction will be taken in the royalties will increase the revenue if the use of Naalakkersuisut. Should this interpretation be understood as that there price of the product increases. still, in the technical sense, will be charged Royalties are typically a tax on the royalties? And if so, has Naalakkersuisut turnover in which the company has to then taken into account to make room for a pay even if the production makes a resource tax? profit. By imposing royalties the risk of the investment increases and thereby the incentive to invest in new projects which could generate more income to Greenland.

19.9 APPRENTICES? Noted and will be defined and covered in the IBA. The paper shows that the Company - None proposes to between 30 and 50 apprenticeship positions at the start of the operational phase. SIK will here call Naalakkersuisut to stipulate that London Mining as a minimum undertake to quantify on how many young people they will train. An agreement may be specified in an IBA agreement.

SIK encourages by extension also to the London Mining meet demands for job training and qualification of all potential candidates for employment in the mine.

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20. Departementet for Sundhed

No. Question Response from London Mining Response from BMP and/or DCE/GN Amendment to EIA/SIA 20.1 Subject: Hearing of assessment of environmental impacts (EIA) for lsua iron BMP: Comment is noted mining project Comment is a matter for the Government of None Greenland Department of Health thank you for hearing of the EIA for Isua iron mineprojeket.

General Isua project is probably the first large-scale mining project in Greenland. It provides natural high demands on both completeness and level of detail in the EIA report for the project. This applies not least because this

WM statement will probably fa knock-on effect on future WM statements.

Follow-up responses This requires a great demands also to follow-up from the hearing responses. There are currently plans that the responses will be collected in a White Paper, but it is not entirely clear from EIA, what happens next. As an example, of the overall project which is not outlined in Figure 3.1. does not provide the answer.

Proposal: incorporation of hearing responses are visible through the process,

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inserting one phase after EIA called "incorporation of hearing responses and additional studies" and that this phase generally clarified the requirement for the EIA.

20.2 Analyzes of the combined effects LM and its environmental consultant agree that in DCE/GN agree that the temperature is None The report describes to a great extent the addition to an assessment of significant individual only expected to be increased in a separate impacts, but do not discuss the project components, an overall assessment must limited area. It is recommended to combined impacts. For the impact on the also be presented. The total effects of the Isua monitor the extent of the problem and marine environment, the combined effects projects are presented in the “Conclusions of the on that basis decide on the need for are important. An example here is that both EIA” page 38-41. regulations. discharged freshwater in the inlet system, which is warmer than the fjord water, and The water effluent system at the Port area is that this water may contain substances that designed such that to respect a maximum are harmful to the environmental, while the temperature during summer time of 10 C in the combined impact of these effects on how effluent discharged to the fjord, as per Canadian the substances that are harmful to the recommended limit for the temperature of effluent. environment are spread further in fjord In addition, at all other times in the fall and winter system is not illuminated months, the temperature of the effluent at the port Proposal: That likely combined impacts are area was simulated to be lower than 10C. The documented, discussed in comment in this question 20.2 has already been the report / white paper and if necessary accounted for as part of a recommendation by DCE. mitigated. Following its review of the EIA, DCE recommended to change the location of the discharge point at the Port area. In order to further maximize the mixing of the low temperature effluent, DCE recommended to locate the discharge point at a deeper water depth

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area exposed to tidal and wind mixing. This recommendation by DCE was followed and the discharge point at the port area was relocated accordingly. This has been presented in the revised EIA which was issued for the purpose of Public Hearings. In addition, the delimitation at 10 °C of discharge water temperature for discharge of the effluent is adopted from the Water management policies, guidelines and provincial water quality objectives of the Ministry of Environment and Energy, Ontario, Canada, and is based on numerous water chemistry parameters. The subject is also elaborated in the EIA Annex 7, sections 4.5.2 and 5.4.

20.3

Analyses of cumulative effects In normal EIA usage, and in the Danish EIA guidelines DCE/GN: Nothing to add. None It is also characteristic that the report issued by the Danish Ministry of Environment analyzes and describes the immediate cumulative effects are defined as impacts from other effects, while a lesser extent describes the existing projects or plants and/or approved projects cumulative effects over the mine life. For the and plans. (cf. Vejl nr. 9339 “Vejledning om VVM I assessment of environmental impacts is of planloven”). great importance whether the substances accumulate. This applies around the environmental importance of emissions of LM and its environmental consultant are aware of hazardous substances used in the process or BMP’s requirement to take into account the discharge of metals to the fjord system. cumulative effects of other projects in the same area. However, the Isua iron ore project is the only Proposal: That the cumulative effects scheme that has reached a stage where the described and discussed in the white paper construction works have been defined and an and possibly the need for corrective actions application to start construction has been submitted

126 are identified. to the Greenlandic authorities for approval. It is therefore not possible to assess specific potential cumulative effects of other projects, such as the Alcoa, since no detailed plans are available or approved.

The effects mentioned in the question are understood to refer to effects of the mine, accumulating over lifespan of the mine. These are shown in the modeling of concentrations of various projected parameters. The concentration of metals and residual reagents in the tailings pond is for example presented in the EIA, section 7.1.12 and in Annex 7, section 5.3. For metals it should be compared to the high ambient levels found to be present during baseline investigations, and the high flow volumes of glacial melt water. For the residual reagents, the EIA has presented the results of the geochemistry test program which shows that the residual reagents left in the effluent (without dilution) are below the detection limits or near the detection limit. The modelfor simulating the fate of the residual reagents below or near the detection limits takes into account natural degradation, and as the reagents are not considered to be persistent or bioaccumulating the accumulating effects are considered to be a direct result of the concentration at a given time.

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See also answer no. 4 to the question raised under the 3rd Public Hearing.

20.4 Using the limit values The EIA does not stipulate the PNEC (potential no DCE/GN: Reference to 7.1. None For example, some process additives used effect concentrations), values of various toxic values as limits values. In order to avoid compounds, as this is to be finally declared by BMP higher concentrations of accumulation and in collaboration with DCE/GNIR on the basis of to safety reasons, one will, at least in the ecotoxicological testing and dilution ratio to be case of a ride on the load of the human / determined. animal use higher levels significantly below the toxic values. The use of acute toxic limits in the EIA is used for There should elaborate on how the choice of illustrative purposes to compare with the modeled limit values is made. and evaluated concentrations mentioned in the Proposal: Assessment behind the choice of report. limit values should be visible and discussed in the EIA.

20.5

Specifically to the EIA: In Figure 3.2 it is not clear what the numbers In Figure 3.2 the number following an “Ω,” is shown BMP: Requirements can be set in the in the figure / table refer to (annexes?) None government approvals. by example in the legend to refer to annex numbers.

Specifically to individual areas DCE/GN reccomend that oil spills are handled in the emergency contingency Oil spills plan. Oil spills immediately assessed as potentially As mentioned in the EIA section 7.1.8 and Annex 6, the most serious pollution risk. Proposal: It is section 7.1, the use of heavy fuel oil (HFO) has because of risk of oil pollution in the inlet already been banned in Antarctica and calls are for a system ensured that it identified the possible future ban in the Arctic as well, although no importance of the ships' fuel type has a date is known for such a future ban.Many ships 128

potential contamination of the inlet system sailing in Greenland waters today use HFO’s by accident or to require that ships to and however, and any specific demands in relation to from the mine using the fuel with the the Isua project are a matter for the Greenland smallest load of waste. Government.

20.6

Discharges of fresh water that is warmer The volume of freshwater that is discharged from DCE/GN assess that the effects will be The one inlet water the retention pond to , Taserâssuk Bay, is 7.4 million local. insignificant The project will be discharged to freshwater m3/year. impact of (7.4 mio.ml /year) into the fjord system warm This roughly equates to 20,315 m3 every 24 hours. discharge which is warmer than the fjord system. It is 2 will be not clearly stated in the report; which The area of Taserâssuk Bay is 20 ha (= 200,000 m ), meaning that if the entire 24 hour volume of added to the impact this would expected to have on the EIA discharged water were distributed evenly over the local flora and fauna. bay it would be a layer about 10 cm thick compared

to a depth of water of hundreds of meters in short Proposal: It will be made clearer in the distances from the port area. EIA/Whitebook, the significance of the Tides and winds flush most of the water volume in discharge of warmer fresh water has on the local flora and fauna and to the proposed and out of the bay several times a day. See also mitigation measures are described and their Annex 7, sections 4.5.1, 4.5.2, 5.4.1 and 5.4.2 and impact assessed. see question 20.2 above.

20.7 DCE/GN: Nitrogen is not adequately The What consequences will the nitrogen Comparisons to temperate waterways and runoff addressed in the EIA. There are for nitrogen emissions have ? from agricultural land are meant to give an idea of instance large amounts of nitrogen in balance 129

The Nitrogen impacts of the water the relative sizes of the modelled nitrogen blasting materials that is discharged to presented environment is indicated as low compared to quantities. However, as the biota of Western the tailings lake and thus further in the the load of nitrogen in temperate regions. It Greenland is different from temperate regions it can downstream to lakes and rivers. Calls response is it shown if this comparison is relevant and also beneficial to compare the nitrogen loading for further treatment of nitrogen by LM will be it does not indicate what a nitrogen load of caused by the Isua project to local natural and / Orbicon. included in this magnitude could mean for flora and manmade sources. the EIA fauna locally As stated, the estimated nitrogen load to local section Proposal: To be documented whether the waterways from use of ANFO explosives and 7.1.12 and in comparison is relevant and that the local reagent residues has been calculated in the EIA to Annex 7 condition is make clear. be ~280 t/year. Due to low temperatures and low section productivity in local fresh water systems, it is 5.3.2. assumed that none of this nitrogen is transformed in the fresh water aquatic environment. The nitrogen will eventually, after years of retention time in lakes along the water course, reach the Godthaabsfjord. For comparison, baseline measurements in May 2011 of Total-N in lakes along this water course (Lakes: 792, 750, 693 Imarssuaq and Taserssuaq) were in the range 0.1-0.3 mg/l. Values in this range have also been reported for many other lakes in the area /Jensen, 2012 and Jensen and Rasch, 2011/. Assuming these values to be representative for the yearly average, the nitrogen transport from the Kugssua River is (7000*106 m3/year x 0,2 g/m3) = ~1400 t/year. If the total catchment to the Godthaabsfjord is assumed to be ~3 times larger than the Kugssua River catchment area, the nitrogen load from the catchment area to the fjord is expected to be around 4000 t/year. Other sources of nitrogen are treated sewage from Nuuk, which (with ~16,000 pax and 5,5 kg N/pe/year) = ~90 t/year, and deposition of atmospheric nitrogen directly on the surface of the fjord (surface area = 2000 km2 and deposition rate 0,2 kg N/ha/year = 20 kg N/km2/year) = ~40 t/year. 130

Compared to all other sources of nitrogen to the Godthaabsfjord (total: 4000+90+40=4130 t/year), the 280 t/year input from Isua would account for a very small proportion of the total nitrogen load to the fjord.

It should also be noted that the Godthaabsfjord also contains nitrogen from inflows of coastal seawater

in the form of dissolved N2 gas, nitrate, nitrite, ammonia and organic forms. The total volume of the fjord is 525 km3 and the water in the deep basins have an average residence time of 1-2 years /Mortensen et al., 2011/. This means the yearly exchange is in the order (525*109 m3/ 2 years) = 262*109 m3y-1. Measurements of nitrate/nitrite in deeper layers of the adjacent Kobbefjord during the MarineBasis Programme under NERO 2010 indicated high nutrient levels in particularly deeper waters, with a maximum of 12.3 µM (=0.17 mg/l). This means that up to 262*109 m3y-1* 1.7*10- 7tons/m3 = ~45000 t/year nitrogen moves through the Godthaabsfjord as a result of exchange with surrounding coastal waters. Considering the direct inputs of nitrogen from the catchment area and anthropogenic sources, as well at the large reservoir of oceanic nitrogen circling through the fjordsystem, it is assessed that the input of nitrogen from the Isua project will not have significant impact on the global nitrogen balance in the fjord.

20.8 The Greenland Water Quality Guidelines for mining DCE/GN: Nothing to add. None Long-term effects of copper and iron activities (GWQG) are specified in the guidelines for 131

emissions? EIA by BMP. The values are for ambient, not The concentration of both of these effluent, concentrations. Ambient concentrations substances are by discharge to the fjord shall not be confused with effluent concentrations. system above the indicative limit values, but As the Kugssua River is by no means the only glacial it is stated that there will be a dilution within melt water influenced river entering the a short distance from place of discharge. This Godthåbsfjord, the amount of iron and copper is not fully documented, and it is not naturally entering the fjord every year is considered analyzed or discussed the significance of this many orders of magnitude larger than the input release will have over the mine life. from the retention pond. Proposal: It proved that there is a rapid A near field dilution of 1.5 times for copper and less mixing and the importance of the cumulative than 5 times for iron to reach the values of the emissions over the mine life is clarified. GWQG can easily be obtained in very short distances from the discharge point. It should also be noted that in for instance the glacial melt water influenced lakes, which feed the Kugssua River, baseline measurements of dissolved copper and iron have recorded that concentrations are up about 1 µg/l and up to about 100 µg/l respectively. While slightly lower in concentration than the water leaving the retention pond (up to about 3 µg/l and 140 µg/l respectively), the Kugssua River has a yearly outflow about 1000 times larger than the retention pond. See also Answer no. 4 in Public Hearing meeting no. 3. 20.9 The numbers quoted in the question are resultant of DCE/GN: Nothing to add. None The combined and cumulative effect of a factual misunderstanding. The table quoted environmental impact of process reports maximum monthly quantities and average substances yearly quantities. Therefore, it is planned that the It is in total expected to be imported 6,056 actual quantity of total reagents used over the tons of chemicals for production per month lifespan of the mine is around a third of the amount mine life of 15 years; it will be a total of stated in the question. 1,090,080 tons. Elimination of substance of As to all other aspects regarding the reagents, the harm to the environment in this answers are given in 20.3 above. 132 concentration will necessarily have an environmental impact. But how big will this be?

According to Annex 6 it this with regard to the following products:

See table in the following section “details descriptions”

[The table refered to can be seen in the EIA Annex 6]

The quantities of some of these substances will depend on the production, and there may be need to use of other than the products than the mentioned in production and other chemical substances may be contained in the products, which are selected to be used.

Especially for substances xanthate and amines, it will be necessary to ensure dilution before any release to the fjord system to reach concentrations below the toxic dose for Daphnia.

Proposal: That the report / white paper is made visible and discussed which effects the discharge of process substances will have

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over the mine life including combined and cumulative effects and that the same will apply if there will be other compounds other than these substances, such as process.

20.10

Where are the pollutants from the process As the ADCP&CTD probe used for baseline DCE/GN awaiting ”Amendments” in the Amendment going? measurements in Qugssuk Fjord were deployed for final EIA. to be made The EIA does not present studies of flow nearly a year, the total net flow rate is not all the to EIA, section conditions in the fjord, only in the Qugssuk indicative of the current conditions. Currents of 0.2 - 5.1.7 and Bay, where there was found a slow net flow 0.6 m/s were frequently recorded in Qugssuk and Annex 7, rate, large variations in salinity and are reported elsewhere in the fjord by Mortensen et section 4.5 oscileating currents in the bay with the al 2011 (Heat sources for glacial melt in a sub-Arctic presenting tidewater, but also very limited mixing of fjord (Godthåbsfjord) in contact with the Greenland the these water masses at the bottom and on 15 Ice Sheet) The circulatory system of the circulatory m depth. This means that there could be an Godthåbsfjord is, however, quite complex. At neap regime in Godthåbs- accumulation of pollutants in some layers, tides it can be characterized as a wave fjord, and at fjord. depending on their temperature and salinity. spring tide as a tidal jet fjord. Over the course of the year four different types of circulation systems are thought to occur. In summer estuarine circulation There is no evidence of what this may mean occurs with a top layer of 5 meters deep fresh water for the distribution of pollutants in the fjord runs out of the fjord, and compensation current in system. It is not documented in the report, the layer down to 15 m depth run inwards. how quickly fjord water is changed or the In areas of the fjord next to glacial intrusions, sub extent to which it moves back and forth in glacial circulation occurs when freshwater enters the bay with the tidewater. It therefore the fjord at depth rises to the upper layers and gives cannot be documented. The extent to which rise to vigorous mixing and entrainment of ambient pollutants will be washed into the sea, will waters. remain in the inlet system, or on the due flow conditions will be further concentrated In winter dense coastal inflows occur in deeper

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in some areas of the fjord system. parts of fjord and raise isopycnals accordingly.

Intermediate baroclinic circulation in outer parts of Proposal: It is necessary through additional fjord can occur year round, when tidal mixing of studies to document that contaminants do fresh water and saltwater cause horizontal density not accumulate in the fjord system. gradients, which give inward currents in upper layers and outward currents in lower layers.

In the basin waters, found in the deeper layers

between sills, the residency times are expected to be 1-2 years. (Mortensen et al 2011.)

On this basis, it is considered that the circulatory system in the Godthåbsfjord is quite dynamic, and given the naturally large amounts of metals washed out into the fjord by glacial melt water influenced rivers, such as Kugssua, the contribution of the effluent from the retention pond at the port area is marginal. Also refer to the answers in 20.3 above

20.11 As mentioned in the EIA, sections 0.6.4, 4.4.6 and DCE/GN: Nothing to add. None Waste Management 4.8.1, the waste incinerator will be state-of-the-art Isua will build its own incinerator. This will and will have an over-capacity in relation to the require monitoring of the impact and expected workload. pollution. A detailed monitoring plan proposal is included in the EIA and will be further detailed by the Proposal: There should be control of appropriate authorities. emissions from waste incineration included in the monitoring plan. Ongoing analysis of the content of the slags from incineration should be performed prior

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to deposition in lake 750.

20.12 Regarding: Hearing of the SIA for lsua iron ore project for London Mining Greenland AIS BMP: In an upcoming update of the Section 5.5 BMP guidelines it will be considered Education The Department of Health thank you for whether these areas should be a part of will be hearing of SIA report for lsua iron mining the requirements in the SIA. updated. project.

General information about the project lsua mine project will probably be

Greenland's first large-scale project. The

project is located at the bottom of Godthåbsfjord up of the ice cap. It consists

of a transport port, a 105 km long pipeline to a processing plant - where there is a road

and pipelines with water and waste water and a real mine site. In addition, the mask is The figures being built an airstrip for small fixed-wing aircraft. The ironore will after crushing, in section concentration and damming be transported 5.2.8 as liquid through the pipeline to the port Mortality where it will be stored in solid form until and death shipment. rate will be

updated. It will be during the construction phase

almost exclusively employ Chinese labor at peak times up to 3,300 workers at a time,

while in the operational phase will be employed around 800 people, with the increase in the amount of local and Western employees in the 15 year operation phase. The Chinese workers are expected to work 10 hours a day for 6 days a week. Local / 136

Western employees are expected to have whole week off outside the camp.

Generally regarding the SIA. This SIA is written based on the BMP's guidance on "Guidelines for Social Impact Assessments." It is an important document towards a realization of the project.

Consequently, it should be correct in every detail, when it will be available for the public consultation. It is therefore Section 5.5 Education will be updated. unfortunate that the SIA is not fully up to date with the latest conditions on eg education, regarding laws, and contains a number of errors that could have been avoided if the relevant parties had received SIA in pre-hearing before distribution to the public. The figures in section 5.2.8 Mortality and death rate A more thoughtful of these fail, that will be updated. indicates that it is clear that 2 out of 3 deaths are men. No one is immortal and birth rates for boys and girls are quite similar. It may only be a one time lag.

The SIA does not cover all elements around the social effects of the project. The SIA is, as it stands, not suificient about the project's effects on the community funded sectors such as health, education and social sectors and not for the sectors such as police and judiciary (still under Denmark).

Suggested solution: BMP states in its guideline about SIA that a pre-hearing of the 137

factual circumstances described in the SIA should be performed. BMP ensures that assessments of the impact of the project on the sectors which are financed by the society is included in the SIA and through change in the guidance sets out requirements for such an assessment included in future SIA. 20.13 From "fly in - fly out" design for transport In section 6.5 Health (6.5.2.7 Health management) is - Update the via Nuuk and health instruction in Nuuk stated that “Onsite medical facilities for both the section to It is natural that projects and their design construction and operational phases will be clarify the changes over time, but it is important that equipped and staffed to aid employee’s with minor potential the project will contact the informants and less serious ailments. In the event of serious impacts within relevant sectors of society, if changes illness or injury, depending on the situation, the occur in project design that may be of employee will be transported by either air or sea to interest to them. the nearest healthcare facility in Nuuk.”

When the Department of Health at first It is important to understand that a mine can not heard about lsua projektet was when the provide a full service medical facility. The local project locally would establish a mini hospital is expected to provide emergency services hospital with a number of doctors and to the serious conditions. London Mining and its nurses like an airstrip was to be built where mine staff and the sick were transported employees are paying taxes and should have the directly into / out of Greenland. Such an right to use the emergency services. organization has little impact on the health situation in Greenland, as the minor effect London Mining will in cooperation with the Health on the capacity of health care and the risk of Auhtorities develop clear criteria and conditions for mutual contamination between population use of local health services and asses the need for and mine staff is minimal. supplementary capacity (see 6.5.3 Health Service (SIA Report)). It has now opted out this organization so that mine staff will transported via Nuuk and will now only be an emergency room / lazeret without doctor and can only take care of minor injuries and provide limited 138

diagnostics.

This is changes of central importance to the Greenlandic health as it affects treatment in health care in Nuuk and public health. SIA has not analyzed the impact on health service of the local population and public health by these changes.

Suggested solution: BMP requires that when significant changes to the project relevant parties should be involved again and heard again. This is already a standard procedure.

20.14 The importance of the lsua project with No response is required. - None regard to health control and public health The Department of Health believes that all who live and work in Greenland has the right to control the health care only by their needs for services and not for example on the basis of home country, but also the control of people from outsiders such as mining personnel must not be at the expense of the possibility of providing health service to local people.

The current plans for Isua has or may have importance of

1) treatment, 2) health economy 3) public health including the spread of communicable / infectious diseases. 139

20.15 Treatment capacity in Nuuk The population in Nuuk is serviced by health BMP: The Government of Greenland is None service from Queen Ingrid Health (DIS) for Comment is a matter for the Government of already in contact with the Ministry of outpatient and emergency services and the Greenland. Health regarding some of these issues. Queen Ingrid's Hospital (DIH) for admissions Health issues can also be a part of the and specialist operation. DIH is also the IBA negotiations or the final country hospital for Greenland. DIH has government approvals. already capacity problems and overcrowding and will without expansion of capacity of bed have difficulties to serve a further local population of up to 3,300 people. DIS designed with a capacity to serve the current

local population. Due to the expected

increased number of evacuations there can

be a need for training of health care personnel. New infectious diseases (see below) may cause extra needs for isolation wards, which again creates a big demands on care and affect the ability to treat other patients.

Suggested solution: London Mining London Mining will in cooperation with the Health Greenland conferred upon the basis of other Auhtorities develop clear criteria and conditions for similar projects to analyze and estimate the use of local health services and asses the need for need for services from the Greenland health, supplementary capacity (see section 6.5.3 Health capacity requirements to meet these and Service(SIA Report)) the risk of transmission of new and multi- resistant bacteria to Greenland. This must be done in cooperation with the Self- Government including the Department of Health.

20.16 The impact of the economics of health care None 140

system All employees will have a private health insurance as In other parts of Greenland, which serves stated in section 6.5.3 Health Services. 3000 people has the health care system care 2-3 doctors, nurses, other specialists, All employees will undergo a pre-employment support personnel, etc. In total, the cost of medical check and annual medical examination as this is between 23 and 25 million DDK yearly stated in 6.5.3 Health Services. is not included in the capital expenditures or costs of operation for operation of DIH or in Denmark.

Mine personnel in the working-age population can in comparison with normal population expected to have less acute and chronic morbidity, but considerably more working related disorders / injuries.

Suggested solution: London Mining Greenland is required to set up insurance for all employees, covering all types of treatments and services from the Greenland health care system. In addition, mine staff have to have a health care test before entering (see also below).

20.17 Impacts on the public health in Greenland The population of Greenland is now exposed Section 6.5.4 Public Health and quality of life - None to a relatively significant social stress, which describes the impact on public health and quality of is a consequence of the rapid development life during construction and operation. The of society. This has resulted in huge social assessment including aspects as prostitutions, STIs, inequalities and vulnerable groups in society. alcohol and substance abuse. Construction of mines has among indigenous populations in other countries has both positive and negative impact. The negative has for example been prostitution, abuse, tensions in society and greater social 141

inequality. This is all aspects which have a big impact on public health, which is missing in the SIA.

Proposal for analysis and monitoring of these changes.

Suggested solution: London Mining Greenland contributes financially to making Comments noted and will be dealt with in the IBA a baseline population survey in Greenland in discussions. 2014 with oversampling in Nuuk area.

A similar survey should be performed regularly, such as every 4 years during the mine life.

The project's long-term monitoring of health indicators should be extended to include relevant indicators from survey of the public health (befolkningsundersøgelseme). 20.18 Impact on communicable / infectious diseases All employees will undergo a pre-employment - None Today, the Greenlandic health care service medical check and annual medical examination as and our Medical officer of health for stated in 6.5.3 Health Services. Greenland do a lot in order to prevent the spread of diseases to the Greenlandic population through surveillance, early detection, vaccination and treatment, including requirements relating to such health care staff before employment in Greenland are tested for carrier status of certain bacteria.

A big immigration of mine personnel to

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Greenland will have a risk of spread of new bacteria and / or resistant bacteria to Greenland. Infection with such resistant bacteria may have catastrophic impact on the health of the population and health care. Preventive measures are necessary to prevent this.

Suggested solution: All mine personnel should be tested for communicable diseases and carrier states and vaccination equipment as recommended by our Medical Officer of Health for Greenland prior to arrival to Greenland. In addition regular testing for infectious diseases during their stay and a regular rnonitoring and reporting of infectious diseases in collaboration with the health authorities. If accumulation of infectious diseases happens in the camp this should immediate be reporting to health authorities and the Medical Officer of Health for Greenland (National Health Service).

20.19 Recruitment and private healthcare It is set in the SIA that it is expected that the Section 6.1.4 in SIA “Conflicts and synergies with - None project will create or expand private health other economic sectors” include a discussion of the services. competition of qualified workers including competition with the public sector. The Greenlandic health care today has

143

difficulty in recruiting staff in almost all professions (doctors, nurses, physiotherapists, etc.). Whether an expanded private health overall will be positive or negative for the population depends on where staff are recruited. If they recruited among health personnel or if there is no one in the capacity of the private offers that correspond to the increased demand, then the net effect of the local population is expected to be negative.

Suggested solution: Monitoring of capacity in private health services and recruitment for these. It is the wish of the Department of Health that wages and employment conditions follows the general agreement in Greenland.

20.20 Public health actions Update the The SIA indicates that there will be Comments are welcome and a monitoring plan will - monitoring preventive and remedial health and be developed. plan to add lifestyle campaigns. Furthermore, that the the lifestyle monitoring conditions in the camp create good plans. opportunities to tackle issues with regard to diet, lifestyle and drug abuse. These are good initiatives, but the department believes that campaigns are not enough.

144

Suggested solution: It is expected that the project will ensure health care management including an ongoing monitoring of lifestyle and targeted intervention, as well as targeted ensuring of abstinence in the project.

20.21 Preparedness of the project's health care Comments are welcome and LM will develop the - None The camp's health service will according to suggested plans. the SIA be able to cover minor damage and minor health problems. The Department of Health's position is that the today outlined capacity does not correspond to risks of disease and serious accidents, which creates the need for quick and effective treatment.

Today, the project rely on a unified system of transportation per boat with possible additional use of helicopter flights. Both of these will be problematic in bad weather. All aspects should be assessed and a ROS (risk and vulnerability) analysis of the project should be carried out.

Suggested solution: A ROS analysis should be carried out of the needs of health which should be included in the planning of the project’s contingency. In addition, a continuous monitoring of areas defined as risk and vulnerability should be include ensuring monitoring and ensuring ongoing 145

statistics on accidents and diseases among workers at the project and that such information is submitted to BMP and partners such as the Department of Health. It should be required that the staff has the necessary training so that they can assess and treat serious injuries / illnesses and treat them throughout the period before transfer can be effected. The project should, on the basis of ROS analysis and knowledge from other projects - enter into a dialogue with the Department of Health with regard to Health service with regard to need for health service in order to balance expectations about local health services. The project should conclude a cooperation agreement on health service with the Department of Health.

20.22 Need for services from public agencies and institutions As stated above the SIA does not rely on any The comment is taken into account. The pressure on BMP: The Greenland Selfrule has A sub public bodies and institutions, while there is the health sector should be included section 6.3 initiated a cross departemental section on an on-going claim by the licensees for Public services and development plans. working group where all ambiguities the pressure discounts in tax payments. Basically, the and questions of interpretation can be on the ideology behind a welfare system as the clarified public health Greenlandic is that it is liable. Thus, those service will who can pay through the tax system will be added to ensure those who cannot. Currently, it is not section 6.3 fully understood how the lsua project will Public draw on the resources of public services and authorities such as social services, health develop-

146

and education - and the areas which are ment plans. under Denmark. Part of the reason for this shortcoming is that there are still uncertainties about the interpretation of laws and regulations about such right to free health service, social services and certain other public services.

Suggested solution: The project must ensure that its impact on public services and the need for additional capacity in the public sector during construction and operation is fully clarified. BMP must initiate that all unclearness and questions of interpretation about what rights Isua employees from outside has to publicly funded services in Greenland. Any reduction in tax must await this clarification.

20.23 Monitoring of health personal and grievance Comment is a matter for the Government of BMP: requirements can be set in the None of healtcare personal in Greenland will be Greenland. government approvals or be a part of monitored by the Medical Officer of health the IBA negotiations. of Greenland to ensure the service lives up to good professional standards. The people have the opportunity to complain of health care, if they do not believe that it lives up to good professional standards. These rights are not guaranteed for current employees for at lsuaprojektet.

Suggested solution: Employees at the lsuaproject, in cooperation with relevant partners on Self-Government must be

147 guaranteed the same rights.

148

21. Nuuk Fjords Venner

No. Question Response from London Mining Response from BMP and/or DCE/GN Amendment to EIA/SIA 21.1

Nuuk Fjord’s Friends does not think that the Comment is a matter for the Greenland BMP: The hearing review process is None public consultation on London Mining has Government. continuously evaluated in order to been carried out correctly. improve this process. Comment referring to the process is noted. If the public EIA / SIA consultation had been carried out correctly the people should have been involved in the EIA / SIA process already in the scoping phase, where it is extremely important to involve the public to form the EIA. This should have happened 4-5 years ago, so since 2007-8. This has completely skipped from home government / self-government side.

Then the public should have been involved in various stages of the study of environmental impacts. This has also been completely overlooked by the home governments’ and self-governments’ side. This step is otherwise extremely important in the democratic process of public involvement.

149

When scoping and EIA study of environmental impacts is over, these should have been communicated to the public.

When those are over, there must be a review of the EIA study. This process was made in four phases in Nuuk and only in Nuuk, and the overall hearing lasted only 12 hours! There should only be used 12 hours to evaluate an EIA / SIA report of 8.000 pages.

21.2 The ideal EIA process should thus have been Comment is a matter for the Government of BMP: The hearing review process is made in the following phases: Greenland. continuously evaluated in order to None 1. Screening / EIA improve this process. Comment 2. Scoping / EIA referring to the process is noted 3. Study of environmental impacts / 4. Communication 5. Evaluation of the EIA-study 6. Project Approval / 7. Monitoring /

Thus, the public has been excluded in the first, second and third process and the public were not involved until the fifth process. It is simply outrageous that this can be done - it just shows the civil servants’ and politicians’ (Government) little interest in the participation of the population. In the 7 stages, people have only been involved in one process. It is unheard that this can be done and what will our government and politicians do about this? 150

21.3 In the Self Government's own guidelines on EIA is following to read: Comment is a matter for the Government of BMP: The hearing review process is Greenland. continuously evaluated in order to None About citizen involvement in BMP guideline improve this process. Comment for the preparation of EIA (EIA) referring to the process is noted (http://www.bmp.gl/images/stories/mineral s/EIA_guidelines_mining.pdf)

Public Hearing (Public consultation) (p. 8): "The public should be involved throughout the EIA process and be informed of the activities taking place while the mine is in operation. A public meeting at an early stage of the process to provide input to the EIA report is recommended as a minimum. A public meeting with relevant information on the EIA report and the input that has been, is also recommended as a minimum, before the report is submitted to the authorities."

21.4 White Paper (White Paper) (p. 8): "Clear rules and procedures in relation to Comment is a matter for the Government of BMP: The hearing review process is citizen involvement must be described in a Greenland. continuously evaluated in order to None white paper and must contain objections improve this process. Comment and comments to the project. The White referring to the process is noted Paper is a document containing public comments, or a summary of these. It shall also include the company’s comments to the received questions and suggestions for how these issues sought clarified and addressed in the EIA process, or an objective justification for why these will not be included in the report. The White Paper contains comments / questions and the company’s answers to these should be 151

available in a separate document. After the citizen involvement has taken place, the EIA report should be revised and comments / questions, as well as the company’s response to these, incorporated into the final version to be dealt authority. All objections, comments, etc. can be published. Publicity phase, the minimum period of six weeks. " Timeline for the EIA report 1. Public meeting to collect input to the EIA report. 2. List of proposed content of the EIA report has to be submitted to the RD. 3. RD assesses the content list. 4. A draft of the EIA report sent to the RD. 5. RD assesses EIA report draft. 6. The EIA report is sent to RD. 7. Public hearing / public meeting on the EIA report. 8. EIA report has to be published for public consultation. 9. Consultation responses from the public stage have to be assessed and EIA report revised. 10. The final EIA report submitted to the RD for approval of the mining project.

Nuuk Fjord’s Friends therefore believes that our Government is therefore violating its own rules on EIA process.

21.5 The signed person requested in 2008 on Comment is a matter for the Government of BMP: A Field Report is not a part of the None material for field report which at that time Greenland. EIA. A Field Report is a short technical already existed. But this was flatly rejected report listing for example a short 152

by mining directorate and where I just was description of the activities, material referred to London Mining - but this was temporally left in the field, personnel also rejected by the company. It is such employed and similar issues. A Field reports which should have been promoted Report form can be found on: in the above EIA process 3rd phase of the http://bmp.gl/minerals/application- EIA study of environmental impacts. This is and-reporting-forms just to demonstrate that our claim to the EIA phase has never been implemented.

21.6 We will refer to a report from Aarhus University on EIA and the public, which Comment is a matter for the Government of BMP: Noted. included are the following: Greenland. None DCE/GN: This is not an environmental "Democracy aspect. Public participation is based on the democratic ideal of the public to be present in the decision-making processes. Public participation tries to maintain the democratic ethics: political decisions must be public, democratic practice is revitalized through public participation, and this helps to ensure the citizens' interests. When the public is involved early and properly in the EIA process, citizens can influence both the planning process and on the final result. Public participation in EIA processes thus gives citizens a sense that they have an impact on their local community. This makes them responsible democratic citizens, and simply confirms democracy. It is even believed that public participation in EIA is not only desirable but simply necessary in a democratic society.

It is important for the process of the 153

planning that the negotiations between the client and all who have an interest in the case are held in a democratic and honest spirit. The client may attempt to minimize public participation as much as possible, based on the assumption that public participation will delay and thereby increase the cost of the project and create resistance in the population. But on the contrary can the negotiations with stakeholders can avert the opposition that otherwise might be overtaken by citizens who felt that their bourgeois democratic rights were ignored. "

21.7

Nuuk Fjord’s Friends believes that the Comment is a matter for the Government of BMP: It is the opinion of the BMP that None studies of EIA / SIA are incomplete and Greenland. the submitted EIA and SIA reports superficial prepared by Orbicon and including the hearing review comments Grontmij. added are in accordance with the requirements in The Minerals Act. The National Centre for Environment and Energy (DCE) is guiding the BMP in environmental and EIA related issues. If the DCE point out areas that require further investigaton, this will be a requirement.

DCE/GN assesses overall, that the EIA report gives a comprehensive picture of the project's environmental impacts.

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22. Janus Kleist

No. Question Response from London Mining Response from BMP and/or DCE/GN Amendment to EIA/SIA 22.1 On the London Mining web side the Comments noted. - None following regarding sustainability can be read:

"We are looking to the future and how we will live and work together with the communities and organisations around our operations now and in the years ahead. We recognise the importance of exploring fully all the options that will enable us to meet our long term responsibility for our resources and surroundings. This genuine commitment to sustainability is a key part of the way we will contribute, endure and prosper."½

In the "Act of Inatsisartut on Mineral Resources and Activities (Mining Act)" it says in § 1:

"By inatsisartutloven seek an appropriate exploitation of mineral resources and the use of subsoil for storage or purposes relating to mineral resource activities and regulation of matters of importance to mining activities and underground activities.

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Paragraph.2 By inatsisartutloven aim for the activities covered by the Act that they are performed securely in terms of safety, health, environment, resource utilization and social sustainability as well as appropriate and in accordance with, under similar circumstances, recognized international best practices. "

22.2

Finally, I understand that London Mining will At this stage it is stil unknown who will be the - None seek China Development Bank (CDB) to investor(s) that provide funding for the Isua project. become an investor in the Isua project. CDB However, practically all potential investors that write on their web pages would consider supporting a modern large-scale (http://www.cdb.com.cn/english/NewsInfo. mine project such as the Isua project, will make it a asp?NewsId=4161) on sustainable development: requirement that the project use state of the art technology, is implemented in the most “A Sustainable Development Initiative was environmentally friendly way and is socially issued today at the eighth Council meeting responsible. of the Shanghai Cooperation Organization (SCO) Interbank Association in Beijing, calling on member banks to strengthen financial cooperation and advance the cause of corporate social responsibility and "green" economic growth. The initiative represents a joint commitment by the six member banks of the SCO Interbank Association: China Development Bank (CDB), Kazakhstan Bank of

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Development, the Settlement and Savings Company of Kyrgyzstan, Amonatbonk of Tajikistan, Russia's Vnesheconombank, and the National Bank for Foreign Economic Activity of Uzbekistan.

On the basis of the SCO Charter and the SCO Interbank Association Cooperative Agreement, the initiative requires member banks to strengthen cooperation in the field of sustainable development. Member banks are urged to:

1.Develop financing mechanisms and methods of sustainable development that reflect the diverse conditions and needs of each SCO member state.

2.Utilize financing support to promote cooperation on large projects that spur regional development in the economy, society, and environment.

3.Provide priority support for industry, agriculture, environment, public services, and infrastructure (including the transportation, building/construction, and energy sectors).

4.Maintain close cooperation in the field of energy, with the goal of securing sustainable energy resources.

5.Strengthen financial cooperation in support of underdeveloped regions, remote 157

populations, and SMEs.

6.Fully recognize the importance of the "green economy" in the quest for sustainable development, especially in terms of economic rebalancing, climate change, and public well-being.

7.Adhere to international protocols and norms governing corporate social responsibility, establish effective CSR management systems, and contribute to the field by sharing experience and know- how. 8.Affirm that sustainable development is the common aspiration and responsibility of all nations, and requires the broad, deep participation of government, civil society, and the private sector. Clients and stakeholders are called upon to join together in meeting this task and make new contributions to sustainable development.

22.3

With the above in mind, I wish with this It should be recalled that London Mining does not BMP: Noted. None letter to London Mining and Greenland Self have the right to use the water resources in the Government to stress the importance of project area. In spite of this London Mining has using hydropower for the Isua project or a requested the International Engineering firm SNC- combination of a (small) diesel generator (if Lavalin to study the feasibility of hydropower for absolutely necessary) and hydropower. the Isua project. The conclusion is that hydropower If CDB wants to be a serious, credible and is not feasible (see the answer in 5.1 ). long-term investor in Greenland and the Arctic, it should be possible to emphasize to 158 them that their investment should be a lengthy and as sustainableas possible and that they therefore cannot expect a quick return, but instead must expect a longer and more sustainable returns through the use of hydropower.

If Alcoa takes their plans off the table the

Self Government should open a door for London Mining to immediately begin to build a hydropower plant for the Isua project.

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23. Arbejdstilsynet

No. Question Response from London Mining Response from BMP and/or DCE/GN Amendment to EIA/SIA 23.1 Under the legal framework (s 31 -33) may it Comment will be taken into account Additional be considered to refer to several relevant - regulation regulations within the Working Environment will be Act. For example: a review of occupational added under injuries and work-related accidents, rest periods and rest days, asbestos, the working occupational and safety educations. environment Furthermore, it should be considered to add act. the rules as young people under 18 years can not work at mines.

23.2 None On page 128 is outlined electrical work London Mining will follow the Greenlandic Act, and - schedule that does not comply with the OSH rely on Government advise in the matter of work Act, rest periods in Greenland. After the shedules based on rotations. Working Environment Act § 41 employees must be given a weekly day off. Therefore it can not be plan with 3 shifts based on 12 hours a day, 7 days a week for 6 weeks and then 3 weeks off. It is possible that an agreement can be established to work 12 days in a row and then have 2 days off.

23.3 The section on training (p 154) lacks the Education education on safety training for safety - for safety representatives. Greenland Self-government Comment will be taken into account representativ supports the introduction of a special es on safety training for coordinators of health and training will safety work in construction. be added. 160

23.4 In relation to the chemistry field (p 1 75) is stated an information system on hazardous materials at work and suppliers manual. The Comment will be taken into account - Comment attention should be given to the will be requirement of an employer manual. included

23.5 In relation to workers' obligations it is states that it is the employee's responsibility to ensure that they are equipped with all Comment will be taken into account - Comment necessary personal protective equipment will be and they are responsible for the provision of included personal protective equipment (p 175). Attention may be drawn to the Greenland act on working environment and the requirements to the employer.

23.6 In the final table with list of impacts, etc. indicates (s 205) that: "The risk of accidents - at work are linked primary to the employees Comment will be taken into account Comment behavior / attitude to their work" and will be existing mitigation measures are listed included (Greenland Working Environment Act) and proposed measures such as implementation of safety and health plans. Experience shows that other aspects than the workers relation to safety is often the underlying cause of accidents, such as lack of instruction or lack of maintenance of equipment.

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24. KANUKOKA

No. Question Response from London Mining Response from BMP and/or DCE/GN Amendment to SIA/EIA 24.0 KANUKOKA appreciate the submitted No comments required from London Mining to the - consultation material regarding London introduction. None Mining’s application for exploitation of iron presence at Isua in the bottom of Godthåbsfjord. The material includes as prescribed in the Mineral Resources Act an assessment of the environmental impact of the project (EIA) and an assessment of the project's social sustainability (SIA). The material and the ongoing consultation process which gives rise to a number of general comments, as presented initially. Then the contents of the respectively EIA and SIA statements are commented separately.

The response was prepared by the Local Joint Mining Group and KANUKOKA. KANUKOKA and the municipalities generally welcome the economic progress such a mining project is likely to have for the municipalities. The project is expected to have an overall positive effect on the local economy. This is caused by the mine itself but also due to the development of the local business community which is expected to increase in activity and thus have a positive effect on employment. Such a large mining project will boost the development of new 162 economic activities in Greenland.

It is expected that Kommuneqarfik Sermersooq will have increased operating expenses because of the large project. It would therefore be appropriate that the municipality receives a share of the gross tax, as agreed between Naalakkersuisut and KANUKOKA.

General Comments Public meetings - consultation process Both BMP and London Mining have made BMP: Public meetings and allocated great efforts to inform the public about the time for the consultation process will project, and KANUKOKA welcomes the be evaluated continuously in order to initiative to engage an independent have this process more stream lined facilitator to organize the public meetings. and improved. The arrangement of the meetings is debatable, but BMP should generally be applauded for trying out different methods for involving the public. Despite the many initiatives the population has generally expressed great dissatisfaction with the consultation process. There is obviously a need to make it clearer to people how they can have influence during the hearing process. It is important that this process is thoroughly evaluated and the criticism raised is taken serious and that the way the hearing process is carried out is modified on the basis of the experience that has been gained. KANUKOKA is happy to contribute to this process.

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A major point of criticism has been the length of the consultation process. KANUKOKAs believes that in connection with future large- scale projects more time should be allocated for the consultation process, which obviously will include large and complex documents.

It is totally reprehensible that some BMP: To the best knowledge of the technical annex to the EIA report has not BMP the relevant reports have been been publicly available from the start of the available from the public library in consultation process. This should after Nuuk. KANUKOKAs view automatically lead to an extension of the consultation period.

Specifically, KANUKOKA suggests that the non-technical summaries are made more accessible. This could for example be done by making them available at municipality and village offices, libraries and other public places, along with a number of key reports with Annex for review / borrowing.

24.1 - Notes to SIA report Comments are noted. This will be an important topic None KANUKOKA believes that the education plan in the upcoming IBA negotiations. should be more targeted and more ambitious. The proposed number of apprentices is too low, especially in the beginning. There is a need for a major effort in order for the chances to be proper for the local workforce to be qualified for the new tasks early in the extraction phase and thus be more active in the mine. We also need better description of the efforts regarding 164

upgrading linguistic skills for apprentices.

KANUKOKA expect that the large-scale This will be an important topic in the IBA. project will to a large extent be able to attract labor and suppliers from the rest of Greenland. During mitigation measures, actions that promote the role of the Greenlandic businesses as subcontractors for the project should be implemented throughout Greenland. Furthermore, information campaigns should also be directed towards Piareersarfiit and Labour Offices in the rest of the country on the needed skills of the employees. For each section: 24.2 To 1.2.2. Page 28 of The material shows that Sisimiut is the - 327: In Comment will be taken into account. southernmost place in Greenland where it is Sisimiut, it is legal to keep dogs. This is not true as there possible to are other limitations on the East Coast. have dogs (the southernmost area in West Greenland, where it is legal).

24.3 To 2.2.1. ‘Sikkerhed til The material says "Safety at Sea Act # 882". søs’ is the The correct term is Maritime Safety Act No. Comment will be taken into account. - correct 882. Danish term.

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24.4 Ancient relics, finds, monuments, buildings Comment will be taken into account. - Reference are not regulated by the Nature Protection will be made Act but by the Act of Inatsisartut # 11 of 19 to Act of May 2010 on the conservation and other Inatsisartut # heritage protection of cultural relics. 11 of 19 May 2010 24.5 Nature Protection Act is from 2003 and not Comment will be taken into account. - Reference as stated in 2007. will be made to 2003. 24.6 It is noted that the field rules of the BMP are Comment will be taken into account. DCE/GN: Nothing to add. The field not mentioned in the list of guidelines rules will be relevant to the project. added to the list in chapter 2. Policy, Legal and administrative framework 24.7 To 3.2. After mining operations, the remaining materials DCE/GN: Nothing to add. None The description is lacking what will be left include tailings and waste rocks. The tailings will be out during the process (sorted ore (tailings), safely deposited in a glacier lake with a permanent water, etc.) from "grinding" until loading water cover and the waste rock will be stockpiled in ships, and possibly further treatment of a designated area. No long term environmental what has been left out. issues are identified for both facilities. These are discussed in detail in the EIA report. 24.8 To 5.3.2. To 5.3.2. "Social and It is noted that there are two minor errors in Comment will be taken into account - Human Life" the list of KANUKOKA's work. In one place it and says "Social Affairs and Health" and the "Technology second "Building Construction and and the Environment". The correct names are "Social Environment and Human Life" and "Technology and the ".

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Environment". 24.9 In § 5.5 There are some serious factual faults on page 87-90: The comment will be taken into account - It will be As it appears, that the vocational education clarified that only run regular training. Maritime School in the Paamiut (maritime safety) and Language vocational Center is forgotten in the statement. education - All trade schools runs also offers further/supplementary training and courses further/supp for mainly unskilled PKU and AMA lementary - There is no mention of education. further/supplementary training as a Furthermore, common core and mine courses, but only will the arctic engineer. Maritime - A prerequisite for participating in the and the training at the mining school is good English Language skills. The Language school in Sisimiut runs schools be language courses, including mining and off added to the shore English. list. Among the unskilled workers in Greenland there are many who have participated in one or more further/supplementary training courses. This acquired knowledge can through the ‘Realkompetenceprojektet (a public project on competences) be turned into regular competences. 24.10 To 6.2.2. KANUKOKA believes that the establishment - None of a training center will be a good approach No response is required in the project and should be established as early as possible.

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To 6.7.3. and 7.1. The use of It seems misleading that in 6.7.3. some the term “no impact categories is written "no action Comment will be taken into account - action required", but in 7.1. A list of measures required” proposed within the same impact category. will be explained We also need a brief justification for each further and impact category which is not mitigated. why some impact categories will not be mitigated on project level. 24.11 To 7.1. Proposal by KANUKOKA recommends that under the Comment will be taken into account. - KANOKOKA section "Occupation (directly under the will be added construction phase)" to be added "Proposed to section action": 7.1 - To promote the use of local labor trained local foremen of the so-called trainee programs - To prepare for the project massive linguistic upgrading English courses to be established by the Language School. Comments on the EIA report

The Assessment of Environmental Impact 24.12 (EIA report) consists, in addition to the main - None report, of a number of Annexes and a non- No response required technical summary. The Annexes are not commented separately, but the information in the relevant Annexes is included in the assessment of the individual elements in the main report.

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24.13 Non-Technical Summary The language and the content of the non- technical summary appear admirably clear The general comment on the Non-technical DCE/GN: Nothing to add. The non and thorough, with good explanations that summary acknowledged technical with very few exceptions, and are adapted summary to a non-technical audience. section 0.1

amended Concrete information on quantities and A summary has by nature to be short and concise. ingredients are missing with regard to This means that only the most essential information with discharges to sea and freshwater is included. For this reason we have not included information environment as examples. quantities and ingredients in this part of the EIA. re. ‘non- western’ The map and image material which is Maps and pictures are deliberately not included in workers referred to should be inserted directly into order to keep the summary short and concise. the non-technical summary, so the summary However, we agree that key maps and images can stand alone and be read independently of the main report. Although it is not a should be included if the summary should be used as formal requirement, it would be a good idea a stand-alone document. For the time being the (as well?) to make the non-technical summary is included in the main report. summary available as a separate document. Again, this approach was not taken to keep the There should be made references to specific summary as short as possible. The table of contents sections in the main report where you can will guide the reader to the relevant sections. find detailed information on each topic. Regarding the conditions for ‘non-western’ workers In section 0.1., the next to last paragraph, will be amended to the existing text in the EIA based the working conditions of "Greenlandic" and on information from the SIA report. "Western" employees are mentioned. Conditions for "non-Western" should also be provided to give a real picture of the situation as non-Western employees will form a significant part of the workforce also in the operational phase.

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24.14 The main report The main report begins with a description of - None the project design, which generally gives a comprehensive overview of the project elements and design.

Section 4.4.7 p.81 At the initial public meetings organized by All vessels bound for the project port in London Mining, some citizens asked to the Godthåbsfjord must comply with a set of effect of the expected large wake waves navigational safety procedures set out by the generated by the passage of the large Greenland authorities. This includes the speed vessels that's going to serve the mine. allowed in the fjord which will be in the order of 10 Concern was expressed on whether there knots. Such low speed should eliminate any could lead to dangerous situations for problems with wake waves from the vessels. people staying on the beach, in the colonial harbor as an example, if large waves without notice washes over the beach. London Mining / the EIA should address this issue, and if the assessment demonstrates a need for it, the EIA should describe appropriate measures to mitigate the possible problems. Spills of chemicals and oily products under transport are mentioned in Annex 6, sections 6.1 and 8.2. Section 4.8.3. p.88 more detailed descriptions of handling of truck or Fuel Storage and Handling: a description of tank truck accidents is to be part of the the handling of accidents involving trucks or Environmental Management Plan (EMP) for tank cars on the road is missing. construction. See EIA Annex 10 about EMP.

24.15 Generally about descriptions of alternatives - section 4.11: DCE/GN: Nothing to add. An important element of an EIA report are Finding the most environmental solution is an None descriptions of possible alternatives to the integrated part of designing a modern mine. This solutions, and the company's reasons to includes the location mine facilities where potential prioritize the solutions. Descriptions of the impacts on terrestrial, freshwater and marine alternatives are important and would give environment are taken into consideration. The EIA 170 decision makers the opportunity to assess team has taken an active part in this process. For whether the company has chosen the most example was the design of the road-pipeline environmentally friendly alternatives, and / alignment modified to include ramps to make it or the alternatives are from political decision easier for wildlife to pass the pipeline. The EIA Team makers' assessment the most desirable was also part of the design of the stacks at the compared to an overall assessment. power plants in order to insure that air quality limits This element is not covered sufficient in the are met. report. Section 4.11 contains only a few In some situations the choice of a particular solution descriptions of alternative solutions. is a precondition for the entire mine project to be technically and/or economically feasible. This includes the transportation of the mineral Examples concentrate to the port where it is proposed to 4.11.2. Mine site alternatives: Parameters, transport the concentrate as a slurrythrough a as for example stripping ratio, refers only to pipeline. Alternatives such as using trucks or building the selected alternative, nothing is said a railway would not be technically or economically about differences in the environmental possible and were therefore ruled out at an early consequences of the two alternatives. Other stage. In this case there are no real alternative to the parameters are discussed only superficially pipeline. This also applies to the processing of the and do not include a comparison of the two iron ore at Isua, that is the crushing and magnetic alternatives. extraction of the iron, which follows a standard technique used in iron ore mine all over the World. 4.11.3. Alternative locations of the plant: The reasons for the selected alternative are In the EIA report the discussion of alternatives is mentioned, however, no alternatives are limited to situations where there are options and described. they differ significantly in their impact on the 4.11.4. Technological alternatives: The case environment. This includes the port location with for the selected alternative is mentioned, the associated alignment of the road-pipeline to the but no alternative are described. mine pit. In other situations such the location for mine facilities at the mine site, the alternatives differ For designating of the location of the port, only marginally as far as the impact on the and choice of energy source is given a good environment is concerned. In these situations the overview of the considerations that were alternatives are not discussed. made and the basis for the final decision. In the descriptions of key elements to the design of mine, the choice of transport 171

solutions for ore, the road, etc. are the alternatives rejected largely without argument, and without a proper description of the possible alternatives. 24.16 Several times during the consultation The BFS design is for a mine life of 10 years with a DCE/GN notes that the EIA is valid only None process has it been mentioned that the mine production of 15 Mtpa based on indicated resources for 15 years. If the company wants to life may be extended beyond the 15 years. proven by drilling. The BFS also has a design for 15 extend the production period, The environmental consequences of such an years mine life with a production of 15Mtpa, since preparation of a supplementary EIA extension are nowhere addressed in the EIA the inferred resources are expected to be converted shoulde be commenced in good time. report. It is anticipated that such an into indicated resources based on some additional extension will have a significant impact on drilling. The assumption in the BFS is based on the project's environmental impact, and it is international recognized methods to estimate the therefore highly open to criticism that this is indicated resources that have to be used for not included as an item in the assessment. financing purposes (so-called JORC codes). For example are the calculations and the environmental assessment of the proposed The London Mining expectations are that the iron tailings deposit in Lake 750 only based on a resource estimate can be upgraded to 15 years of planned operation phase of 15 years. An mine life with a production of 15 Mtpa upon some assessment of the impact of an extended additional exploration drilling. The assumption of 15 period of operation will have on disposal of years mine life of 15 Mtpa has been the basis for the tailings is missing. Is there capacity in Lake EIA. 750 for tailings from an extended operation period, and if not, how will tailings be If the mine life is extended beyond the assumption managed if the mine life gets extended? for the approval the conditions shall be reassessed including assessment of the capacity of the tailings lake and a number of other conditions. Since there is no actual plans and no application for such a production this aspect is outside the scope of the EIA.

24.17 The energy supply to the mine has been a London Mining does not have the right to use the DCE/GN: Nothing to add. None major topic in the discussion of the project. hydropower potential in the project area. In spite of However, it is surprising that the available this, LM requested the International Engineering details of a hydropower potential does not firm SNC-Lavalin to study the hydropower match what is found in connection with alternatives for the Isua project. This study 172

Alcoa's extensive feasibility studies for the concluded that the secure hydropower is 120 MW. possible aluminum smelter, and it is LM is not aware how Alcoa made their calculation of reprehensible that the EIA is not based on the hydropower resources. Also refer to answer in this available material. 5.1.

24.18 Chapter 5 describes the existing Comprehensive baseline investigations have been DCE/GN: Reference to answer 7.1. None environment in the area. There is no analysis carried out in the period 2008 – 2011. The program of the water quality in the sea, which should has been prepared upon request by BMP and in serve as recipient for the wastewater consultation with DCE. The results are summarized discharged from the project. in the EIA (main report and Annex 7).

The investigations include marine hydrography survey (one year of continuous measurements of currents in three depths, water level readings), selected water quality parameters (continuous measurements in three depths of conductivity/salinity, temperature), bathymetry survey, geo-morphology survey, marine sediment sampling, marine flora sampling (e.g. bladder wrack), marine fauna sampling (e.g. blue mussels), sampling of fish species (short-spine sea sculpin, arctic char), and video surveys in 19 coastal transects. Selected samples of flora, fauna and fish species are stored at DCE for later comparative analysis of e.g. metals or other relevant components. All baseline investigations have been used to characterize the water quality. In term of additional chemical parameters (metals in water) reference is made to typical values found by DCE in Greenland Fjord as summarized by DCE in the EIA guideline.

24.19 Section 5.1.4. The section on the hydrological system does Yes, the risk has been carefully considered in the DCE/GN: Nothing to add. The not mention the risk of discharge of sub- Bankable Feasibility Study. Since sub-glacial lakes conclusion glacial lakes and glacier-surge and possible discharging large volumes of water over short time from the BFS 173

consequences of such an event. Has this risk could pose a threat to the mining operation this study to be been assessed? phenomena have been assessed as part of a included in comprehensive glacier management study which is the EIA part of the BFS (Appendix K, doc 505076-1000-4GER- report 0002; no. of pages:1061). section5.1.4.

The conclusion is that there is practically no potential for glacier melt water lakes discharging to the open pit. The conclusion is based on rationales of the structures in the catchment area and the sub- glacier topography, etc.

The question and conclusion could be relevant to address in the EIA report.

24.20 Section 5.3.1. The precise location of rare plants should be It is correct that the exact localities of rare plants are DCE/GN: Refers to DCE's reporting to None marked on a map, so it can be assessed not shown in the EIA. This also applies to the nesting BMP on vegetation and botanical whether adequate consideration for site of Gyr falcon. This is done in agreement with interests in the project area. protection is made, so any accidental DCE to avoid disturbance of the rare species by damage can be avoided. collectors. However, the sites will be well-known to the environmental officer who will advise the engineering companies during the construction phase. There will be no conflict between the road alignment and the location of rare species. Additional vegetation surveys was carried out with DCE in August 2012 along the alignment of the access road. 24.21 Section 5.3.7. concerning seabird colonies LM agrees that the text in the main report is DCE/GN: Nothing to add – reference to None should be deepened. The assessment of the condensed. More information on the seabird document with proposal for possible impact of the project is very colonies in Godthåbsfjord are presented in Annex 3. environmental monitoring and superficial, and not enough to be a genuine The assessment (in section 6.2.3) points out that environmental studies, February 2013. assessment of whether the impact is since ships to the project port will move at slow acceptable. speed and keep to the central part of the fjord 2-3 km from the colonies the disturbance will be low. 174

The project will not discharge substances to the fjord that can impact the food resources of the sea birds.

The central chapters in the report are No response required - Chapter 6 and 7 that describes the anticipated environmental effects of the project. 24.22 Section 6.3.3. It is positive that the The point is noted. - None Greenland National Museum and Archives has surveyed the area of ancient monuments. The report shows that the mining company has a duty to report any findings. Since ancient monuments in Greenland may be difficult to recognize, it should be considered whether some employees should be trained specifically to recognize these relics. 24.23 Description of residues from the processes is The overall project is described in Section 4 of the - None missing in flow charts. EIA report.

Detailed process description is presented in section 4.3.1 of the EIA report including a detailed process flow diagram explaining the entire flow from the ore to the product delivery to ships.

Residues will mainly be confined in the tailing that will be deposited in the tailings pond. 24.24 Section 7.1.1. KANUKOKA does not agree The detailed glaciological studies and modeling of DCE/GN: Nothing to add. Correction of with the classification of the change of the the actual conditions and sub-glacial topography the impact landscape as a long-term impact of low carried out as part of the BFS demonstrate that the matrix significance. The prerequisite for this flow of ice (ice creeping) towards the pit will (section classification is that there will not be people continue after the mining has terminated. The 7.1.1) in the in the area. The development of the ice horizontal speed of the glacier movement indicates Danish sheet in recent years will likely mean that that the pit will be filled with the progressing ice translation. the ice edge will withdraw and not cover the after a few decades. The infilling processes can also 175

hole - so that it will remain as a permanent be helped by the freezing of some of the melt water. scar in the landscape and on the access road, access to the area after activity will be less. It The spatial extent of the landscape alteration is surprises also how the reference to the assessed as “regional” with and without mitigation geographical distribution changes from in the EIA in the English version (original) but an regional to local, since there are no error is included in the Danish translation (the suggested mitigation measures. Greenlandic translation is correct).

24.25 Section 7.1.5. In the section on waste The final monitoring program which will include a DCE/GN: Nothing to add. None management a description of the control suite of control parameters regarding waste will be system for waste is missing. The control developed in a co-operation with London Mining and system will ensure that waste is managed in the Greenland authorities. Such a control program an environmentally sound manner and that will include monitoring of waste water, incinerator the incineration slag as specified does not slag and other relevant parameters. This is also part contain contaminants. It is not clear whether of the Environmental Management Plan framework there will be established treatment of flue –EMP which is presented in Annex 10 of the EIA. gas from the incinerator, but it is assumed that this will be required in connection with An agreement will also be entered regarding the the approval of the plant, so it complies with handling of hazardous waste. In that respect an the principles of the use of BAT. agreement with MOKANA is definitely an option that will be considered carefully. The Greenlandic municipalities have entered into an agreement with the facility MOKANA in Aalborg which receive all hazardous waste from Greenland and correspondingly all local authorities are also obliged to send hazardous waste to MOKANA. The cooperation with MOKANA has been extremely beneficial to Greenland, so KANUKOKA would therefore recommend that London Mining is encouraged also to use MOKANA so that waste is managed in an environmentally sound manner.

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24.26 Section 7.1.7. An assessment of how light, Light, heat and radiation have been assessed in DCE/GN: Nothing to add. EIA Section heat and radiation will affect the area's relation to humans in EIA section 7.1.7 and section 7.1.7 and wildlife, especially at night is missing. 8.2.7. 8.2.7 extended The assessment will be amended and include wildlife in the area.

24.27 Section 7.1.8. Generally, it is the opinion of The viewpoint is noted. KANUKOKA that the DCE's recommendations - References should be followed. to IPCC to be included in A significant environmental impact from the The impact of CO2 emissions in terms of global the EIA project is the significant increase in heating is very well described in the numerous UN Greenland's CO2 emissions. The EIA is reports from the IPCC – Intergovernmental Panel on lacking a description and an assessment of Climate Changes, and the main conclusion should be the consequences of this release both well known for all professionals and politicians. environmentally and economically for Lengthy text on climate changes are deliberately not Greenland. In spite of the existence of included in the EIA since no additional conclusions several technological that can potentially can be added to the IPCC assessments. A reference reduce emissions; no suggestions for to the latest relevant IPCC report shall be included in mitigations are described. The consequences the EIA. of any such mitigation on the environmental profile are also lacking. The most significant source of CO2 emission is the diesel power plant. Please refer to the answer to question 5.1 .Other major sources are trucks and mining machines. When deciding the make and type of these, low fuel consumption is of paramount importance.

24.28 Section 7.1.12. An important prerequisite for Reference is made to reply 20.10. DCE/GN: Nothing to add. Amendment the conclusions regarding (lack of) effects of to EIA the substances discharged into the aquatic section 5.1.7 environment is that there is a rapid and and Annex 7 significant mixing of the substances discharged. This assumption however is 177

based solely on a qualitative assessment. A quantitative modeling is lacking on how this mixing will take place, and information on existing background levels is missing as well. The conclusion that treatment is not necessary can have far-reaching and long- lasting consequences, if this turns out to be wrong. It is therefore KANUKOKAs opinion that this assessment should be based on a more solid basis, and be founded on the precautionary principle.

24.29 At the public meeting on the 8. October in The report is in fact known to Orbicon and the BMP: The authorities including the None Katuaq one person referred to a report report is also included in the reference list (EIA National Centre for Environment and which according to this person shows that Annex 7 – Water Management Assessment). This Energy (DCE) have been looking into the one of the reagents, xanthate, which is to be fact became evident after the meeting when the full comments from the public review used for the removal of sulfur from the ore, title and report was identified (NICNAS: National meetings and has also been in dialogue is more harmful to the environment than Industrial Chemicals Notification and Assessment with the company regarding these indicated in London Mining EIA report. Scheme (Australia). 2000. Sodium Ethyl Xanthate issues. Requirements related to Priority Existing Chemical Secondary Notification Chemical Safety will be set in the The report was prepared by the Australian Assessment Report No. 5S. Full Public Report). government approvals in order to meet National industrial Chemicals Notification Without referring to the title in the meeting when international best practice. and Assessment Scheme, an adviser to the presenting the statement, it was difficult to make an The final EIA reports are assessed by Australian authorities concerning Chemical instant answer to this statement during the debate. independent experts as DCE and GN Safety. Orbicon said they were not aware of (both of which are considered that report /study. In order to assess the Moreover, the report referred to is “A second independent). value of the mentioned report, as well as to notification” which assesses liquid xanthate. This meet the criticism and the public concern, product is not used in the Isua project. This liquid DCE/GN: Reference to answer 7.1. the presented report should be assessed by reagent has other characteristics compared to solid an independent expert, so it will be decided xanthate planned to be use in the project when on a professional basis whether the report's sulfur reductions are required. The use of solid findings should be included in the xanthate is explained in the EIA (Section 5.3.3 in the environmental assessment of iron mining EIA - Annex 7). project. And on this basis the needed 178

revisions of the conclusions and similar Characteristics of solid xanthate are detailed in the requirements which have to be made in the NICNAS report from 1995: Sodium Ethyl Xanthate mining license to London Mining. Priority Existing Chemical No. 5. This report is also listed in the EIA references and has been part of data compilation presented in the working document: Note on literature data of reagents. Working Document, Feb.2012, Orbicon (also listed in the references).

Toxicity assessments are complicated and require distinguishing between lethal concentrations (LC), effect concentrations (EC) and predicted no effect concentrations (PNEC) since these results differ greatly. These fundamental aspects have obviously not been accounted for in the statement from the participant in the meeting when he was made citations from the report.

The statement presented at the meeting is therefore not justified and there are no discrepancies between the Australian report data and the data presented in the EIA.

Details on chemical composition from the potential suppliers will be presented to the DCE/ GNIR as part of the approval procedure.

24.30 p.204: It appears that SGS Lakefield and All samples have the origin from the Isua iron ore DCE/GN: Nothing to add. The AMEC (Canada) has conducted formation. The term “similar” in the comment is not explanation environmental analyzes on four samples right. All material tested were obtained directly from of composite from material similar to tailings from Isua. the Isua deposit by drilling. All testing were done samples will What are the reasons that the analysis is not using actual real material from the Isua deposit. be included performed on material taken from Isua? in section Which uncertainty does this imply in relation Furthermore, the 4 tailings samples tested are all 7.1.11. to the results obtained? And is a spot test of the samples produced from 1 year of metallurgical 179

four samples sufficient to give a true and fair test work program at SGS Lakesfield. view? The samples are not spot test. The four samples represent composite samples of low grade ore; medium grade ore (two independent samples) and of high grade ore.

The composite samples are used to increase the representatively of the tailings and considered to give a true and fair assessment of the characteristics.

24.31 EIA report generally We disagree with the KANUKOKA conclusion that DCE/GN: Nothing to add. None The tables of the assessment of individual introduction of non-native species are identical in factors effects are not consistently filled out. the construction phase (cf. section 6.2.7) and the An example is provided in Section 6.2.7. and operational phase (section 7.2.9) and consequently 7.2.9., which both deal with the introduction the impact matrix should be identical. of non-native species with ballast water for the construction and operational phases In the EIA (section 6.2.7 and 7.2.9) it is explained respectively. The risk for both activities is that the construction phase will imply most ships will likely to be similar in the two phases, but the call the port loaded with goods to the site and thus assessment of significance is different. At the not be in ballast mode. Contrary, in the operational same time it is a question whether phase most ships calling will be large bulk carriers in complying with international rules is a ballast mode. "mitigation measures", or simply a basic condition. Therefore the release of ballast water will differ in quantity and frequency and consequently the impact significance is phrased Low in the construction phase and Medium in the operational phase (before mitigating measures of complying with treatment of ballast water). 24.32 The descriptions of mitigation measures are The EIA report contains the views of the DCE/GN: Nothing to add. None several places too vague, and it is unclear independent consultant Orbicon. If London Mining is what in the report is defined as mitigation granted the permission to start the construction action. works, the Greenland Self Government and its Examples: administration (BMP) will specify the conditions for 180

It is said on p.158: as "mitigation measures" the permission. Such conditions will typically include for disruption by passage of vessels: "keep the mitigation measures proposed by the EIA low speed in the fiord" - the report should consultant. These mitigations will then be very be based on scientific studies and / or specific. For example could a mitigation proposed in experience indicate a recommended speed the EIA such as “keep low speed in the fjord” be limit, distance or noise limit. converted to “ships to the Isua port must observe a X P.194: The only proposals for mitigation knot speed limit in the fjord”. The same will apply to measures against the effect of dust and air for example air emissions and dust. In this case it is pollution, is compliance with the latest very likely that the BMP will require compliance with emission standards. There are no concrete either Danish or EU emission standards which were proposals for how this can be achieved for the limits considered in the EIA. each of the possible sources of the process. 24.33 Legends, north arrow and scale are missing We are uncomprehendingly on this comment. - None on many of the maps. Legends are generally included on sketches and Many of the characters are unclear and of a maps or alternatively explained in the text. All maps poor resolution, so they are difficult to read and sketches are consequently oriented to the when the document is printed, and the north. Important sketches and maps have a scale figure explanations are several places not attached. adequate in order to understand the characters. It is correct that sketches can appear blurred when printed. The document files are very large due to the number of illustrations. When the documents are published on the web site and shall be manageable for downloading it unfortunately necessitates a downscaling in resolution having the consequence of reduced printing quality. The documents can be provided in high resolution if required. 24.34 In several places the text is vague and there Originally, the EIA has been drafted in English and DCE/GN: Nothing to add. Typist errors is signs of insufficient quality control, for subsequently translated into Greenlandic and Danish to be example is the text on page 116 regarding under great time pressure. Despite quality control corrected ice almost impossible to understandable. typist errors or misunderstandings translating technical terms can be observed. They will to the Examples: extent possible be eradicated in the final version to On p.113 is mentioned "boulders" scattered be prepared after the hearing period. in the landscape (boulders are shaped 181

blocks, and it's probably not what is Comments to pages: meant?), P.118: "moraine" is a landscape p. 113. The English word ’boulders’ is translated to form, the material is called "till" in all the Danish word ‘kampesten’. This is a precise scientific literature. translation. We disagree with the perception of P.218: under "Mitigation Measures" is stated KANUKOKA. that "in the event that discharges do not p. 118. The English word ‘till’ is translated to the meet the agreed levels actions must be Danish word ‘moræne’ which is the correct taken immediately to ratify this" - what does expression (cf Den Store Danske Encyklopædi’ - it mean? And when you have "ratified", what Gyldendal). then?

24.35 The overview of the monitoring program is The monitoring program to be implemented under DCE/GN: Nothing to add. None very uneven in quality. Some points are the Isua project will be prepared and agreed upon in satisfactory described, while others are so a co-operation with LM, BMP and DCE. The incorrect defined that it is not possible to proposed monitoring program in the EIA is indicative make an objective assessment. It is not for the approach. enough to write that "A series of monitoring programs will be part of ..." without describing what these monitoring programs should contain.

24.36 The EIA report is unfortunately in too many Orbicon A/S that has been contracted by London DCE/GN assesses overall, that the EIA None places characterized as being prepared for Mining to prepare the EIA report as independent report gives a comprehensive picture of the mining company, and there are passages consultant. the project's environmental impacts. in the report that seems colored by its wish for a particular design of the project and not The EIA report has been prepared in accordance a real independent description of the with the BMP EIA guidelines and in close dialog with expected environmental effects based on a London Mining. In the cause of the process professional assessment. Formulation such consultations have been held with BMP and their as the headline of section 4.8: "Built eco- consultant to clarify approaches. However, the design" - gives the impression of bias opinion assessments of the various impacts of the project and should not belong in a report which will and conclusions are Orbicon’s own. form the basis for a reliable assessment of environmental impacts of the project.

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24.37 The section on effects on the local fauna The EIA has been prepared in accordance with DCE/GN assesses overall, that the EIA None provides generally the impression of being guidelines issued by the Greenlandic authorities report gives a comprehensive picture of well written and expected effects are (BMP). Before the EIA was uploaded for public the project's environmental impacts. sufficiently described, but KANUKOKA think hearing the BMP scanned all the documents to overall that there should be expected a determine if the quality of the EIA is sufficient to be higher quality of an environmental used in an approval procedure. assessment for such a large project.

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24 A. KANOKOKA (Bilag A – Qaasuitsup Kommunia)

No. Question Response from London Mining Response from BMP and/or DCE/GN Amendment to EIA/SIA 24. A Kanukoka 1 Mining Group - - -

Re.: Contributions to the hearing response in connection with the London Mining project – Isukasia

From Ilulissat, Qaasuitsup Kommunea

From Qaasuitsutp Municipality we must The municipalities that have been engaged in the - None point out that we find it unfortunate that SIA process and where information meetings have London Mining has not hold public taken place has been organized in agreement with information public meeting about Isukasia BMP. However, with respect to job opportunities for project. It is our experience that in general the people of Qaasuitsutp Municipality, London there is very strong support and adherence Mining will arrange information meetings later on in to that London Mining must complete their the Municipality once the project is moved in the project in Isukasia. But the citizens lack next phase. information on job opportunities in connection with the project and lacking information about the courses or qualification efforts that will be associated with the project.

Qaasuitsup kommunia is affected by large unskilled unemployment and there is a great need for upgrading the labor force from the known jobs for new job opportunities that will come in connection with Isukasia project.

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The municipality's economy has been hit hard because of declining activities within the fishing industry and jam in the construction industry. Therefore, are new large-scale projects that can help to create new jobs - also with labor from Qaasuitsup Municipality - more than welcome.

Therefore, our unique opinion is that London Mining's Isukasia project should be initiated without further delay. The sooner the better. We are ready for concrete actions that could help both to reduce unemployment and initiate training activities that makes that the available will be upgraded and in all can look forward to a job.

Kanukoka's draft to the hearing response can we also connect us to.

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24 B. KANOKOKA (Bilag B – Qeqqata Kommunia)

No. Question Response from London Mining Response from BMP and/or DCE/GN Amendment to EIA/SIA 24 B Re. Hearing of the Isua projekt 1 It is a very thorough response prepared by London Mining has made a general response to - None KANUKOKA. The only comment from Qeqqata questions related to utilizing hydropower potential Kommunias is addressing the aspect, that as part of the project. utilization of hydropower should not be completely neglected as a possible energy Please see response for question no. 5.1. source, although the EIA is stating that hydropower construction will incur additional capital costs of approx. 900 million. USD.

The potential of Imarssup Isua is reserved for the Alcoa project, but there is also considerable potential in the large lake Tasersuaq.

Exploitation of hydropower will increase the project's environmental profile considerably, and it seems obvious that London Mining should enter into negotiations with Alcoa on takeover of the Tasersuaq power plant when the mine is closing down. This will allow Alcoa to increase the production at the smelter for a relatively modest investment. The Alcoa project has a much longer time horizon than Isua project.

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25. Birger Poppel

No. Question Response from London Mining Response from BMP and/or DCE/GN Amendment to EIA/SIA 25.1

As stated in the coalitionagreement for the BMP: Noted. None Naalakkersuisut regarding the values of the Comment for the Government of Greenland. coalition: “ A solidary, cooperative and strong selvgovernment should be developed that relies on open, democratic dialog. This imply that the people have joint influence and responsibility for the development of the society based on peoples equal worth and equal dignity” (the bold markings are Birger Poppels).

The four public meetings BMP has held since the end of August on the ISUA project, do not live up to the value set for formulations of 'an open democratic dialogue' and 'public participation and responsibility for social development'. It is due, inter alia, to following reasons:

25.2 Only part of Greenland's population have been included in the information on ISUA BMP: There is a continuously project: Comment for the Government of Greenland. evaluation of the hearing process in None ' Working together, we can and will make order to have this improved. history in and for Greenland!' The quote is from London Mining’s Power Point

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presentation that summarizes LM's assessments. This quote was pronounced several times during the public meetings by LM's director Xiaogang Hu and was supplemented with comments stating like the ISUA-mining project as Greenland's largest industrial project ever. It will also mean that if LM gets the exploitation license - the construction of iron mine and the subsequent operation will have far-reaching consequences for the whole Greenland. Therefore, it is necessary that the entire population of Greenland - and not only the residents of Nuuk and Kapisillit – will be involved in the discussion about ISUA-mining project. It has not been the case!

25.3 For a short time for a real debate on an informed basis: Comment for the Government of Greenland. BMP: There is a continuously evaluation of the hearing process in None The time that been available for going order to have this improved. Comment through the comprehensive documents referring to the consultation period is (even without attachments) and for non- noted. professionals a difficult task, has effectively been limited to approx. two months when the SIA and EIA only have been available in this period. This means that a qualified preparation and participation in a public debate has been impossible for anyone who has not been able to put everything else aside and concentrate on the report read. Since it is crucial to be able to handle a project like London Mining’s iron-project on a fully informed basis and in a context, it is in this less interesting context that over a 188

period of several years that workshops and information sessions have been organized. There were nine weeks from the publication of the reports; an applicant is required to prepare for the consultation deadline, which is crucial.

25.4 The organization of public meetings in Nuuk has not adhered to democratic criteria or standards of professional meeting Comment for the Government of Greenland. BMP: There is a continuously None management: evaluation of the hearing process in The public process, as it has been arranged, order to have this improved. with four public meetings effectively excluded discussions, and the answers to some of the questions raised at the first meeting first was answered at a subsequent meeting (for the third meeting only in writing form) without the possibility for detailed questions, have been very far from a democratic inclusive process. Despite Naalakkersuisoq for raw materials and commercial issues and BMP claims to the contrary, the process is indeed far from the 'Canadian model', which occasionally has been referred to during the public meetings. When the Canadian process has been highlighted due to, among other things, that it allows local communities to assign experts to assess the material (environmental assessments and evaluations of social impact), companies present and that the process itself extends over a considerably longer period.

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25.5 Solid citizen criticism: Comment for the Government of Greenland. BMP: There is a continuously One of the most consistent feature of all evaluation of the hearing process in None four public meetings have been widespread order to have this improved. dissatisfaction and a massive criticism of meeting content and form and the process itself, which have had the name of 'public consultation' but, at best, have been 'public information'.

From the first to the last public meeting, there was a growing (albeit not impressive) participation. The experience of this process is that it takes time to draw sufficient attention to a very important project, and the experience may lead to longer course – and hence more time.

At the end of the consultation period, the 4th public meeting on 8 October which was recorded was still not put on the hearing portal. Nor answers / comments on the 52 questions and comments contained in the minutes of the third public meeting on 24 September were seen published.

25.6 Sustainability / environmental impact Comment for the Government of Greenland. BMP: Noted. In the coalition agreement the principle of None sustainability is stressed in the following

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"The original communities must be strengthened and contribute to a society that is based on the Greenlandic culture, and how change is created taking into account the collective sustainable management and exploitation of living and non-living resources." And "A self-governing Greenland is a country where the exploitation of resources is based on the principles of equality, community and sustainability, and where the self-sufficiency of food is also pursued." (My highlights)

Greenland's international responsibility is pointed in the following passages: "A self-governing Greenland is also a country that takes its share of global responsibility, and one that cares about and collaborate with other indigenous groups, and the rest of the world."

"Therefore, a self-governing Greenland and its people shall meet and reach their international obligations and responsibilities that apply to them." (My highlights)

London Mining’s summary conclusion of the investigations of ISUA iron ore project's

191 environmental impact is:

" ISUA is an environmentally friendly mining project with low volumes of waste materials, clean operation and simple closure requirements". (From London Mining Power Point presentation) and it is emphasized that ”No significant environmental issues were identified ".

The two quotes are remarkable, as one of the most significant consequences of the project is a near doubling of Greenland's total CO2 emissions. This is primarily due to repeated questions at the public meetings that this fact is revealed and has to occupy a central place in public debates. Such an important relationship dimmed by London Mining can also contribute to skepticism about whether other key issues have been underestimated.

The cause of CO2 emissions from the project is that LM has chosen to use diesel generators for production. This means that more than 200 million liters of diesel (London Mining data) will annually sail to Nuuk and through Nuup Kangerlua in giant tankers. In addition, the risks that the actual transport, which the transport could lead to, will the transport lead to an additional

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amount of CO2 emissions from tankers, and this release is not included in the more than 80%, Greenland's CO2 emissions are expected to increase by. The extent of this spill is not available, but should be documented.

Compared to Naalakkersuisut recognition of 'sustainable management' and 'international obligations', it does not matter whether Greenland is exempted from a follow up to the Kyoto Protocol, and CO2 emissions from tankers conferred other countries' emissions.

25.7 The use of hydroelectric power, (which seems to be available in sufficient quantities) Refer to response given in 5.1 regarding BMP: The Government of Greenland is must be not only a legitimate expectation hydropower. focused on supporting Hydro Power if None but also an indispensable requirement, this is possible in a financial and a which should take precedence over investor technical way. A decision related to the repayment. China Development Bank (CDB), use of Hydro Power also has to be the London Mining CEO, Dr. Hu who is listed realistic, and therefore it is a must that as probable investor (interview in Nuuk Local all these considerations are taking into TV, October 1, 2012), has sustainability as a account when these decisions are key success factor for its investments. Any taken. iron mine in the bottom of Nuup Kangerlua based on hydropower could contribute to CDB's environmental profile.

Greenland has during many years been 'branded' on a clean environment and sustainable use of energy. Thus, Royal Greenland marketed its products on the

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basis of a clean aquatic environment. The implications of iron mining project in different shapes should be carefully considered because they can affect Greenland's international reputation.

Based on Naalakkersuisut basic positions (see quotes from the coalition agreement), it is likely that any decision to grant permission for London Mining for the construction and production requires the use of hydropower.

25.8 Greenland's economic benefits No response required - What is certain and known about the None consequences of implementing a large-scale project such as ISUA-mining project is that there will be impacts on the natural environment and a wide range of risks. To make London Mining iron mining project interesting / worth to take on, a financial return for Greenland needs to be guaranteed for the economic benefits for Greenland by adding nature and the environmental risk to the project. Since Greenland is not operating with 'royalty', the direct revenue generated from mining activities, which the London Mining has sought its license of exploitation, are: • income taxes • corporate taxes from local businesses • Corporation of London Mining Income taxes will (at a given income tax rate) depend on the total payroll, distribution of local and outside labor and 194

wage levels of the various groups and the effectiveness of the PA tax collection.

25.9 Tax Income

Payroll cost will depend, inter alia, on the Comment for the Government of Greenland. None requirements for minimum wages for BMP: The bill on large-scale projects foreign labor. The lower salaries accepted in the bill for the large-scale projects, the lower which opens for foreign expertise, the income tax. There are several reasons labour and lower wages during the (including international conventions, construction period, is meant to rejection of social dumping and Greenlandic facilitate project with a construction companies' competitive situation) to focus budget over 5 billion Danish kr which on the requirements from the Self- government for minimum wages, and one is cannot be implemented by the current that tax income as the only income the Self- Greenlandic workforce. Such project Government is sure to get from construction will generate tax revenues from person of the project startup. tax during the construction and The Self-Government’s considerations in this operation phases. area has been absent from the debates.

In the operational phase, it is expected that a greater proportion of the workforce will be Lower wages will generate lower tax local. It will depend on the qualifications of income but lower wages also increases the Greenland applicants, how many people the profit and thereby the revenue are employed, but tax revenue would also from corporation tax. during operation depend on the wage levels of the various employee groups. It is not Naalakkersuisut’s intention that the favourable tax condition will The current bill on the large-scale project, include the operation phase. only covers specific conditions in the construction phase. For various reasons - see above - but also for income tax payments during the operational phase, it will be important to confirm that Naalakkersuisut 195

will not give more favorable conditions during the operational phase. The question is relevant because of the experience – e.g. from Sierra Leone, where London Mining has apparently negotiated extraordinarily favorable terms by a direct agreement with the local government. Commitment to strengthen (and not relax) the conditions will provide a better basis to match revenue expectations for. (Http://www.christianaid.org.uk/Images/sier ra-leone-mining-briefing.pdf)

25.10 Corporate taxes from local businesses

The size of the local corporation will depend BMP: The special conditions regarding None on the extent to which local firms have the Comment for the Government of Greenland. wages which are described in the bill on contracts, and their scope will again both in large-scale projects covers only the operating and construction phases depend constructions phase not the operation on the extent to which firms are phase. The operation phase must take competitive. Here, an important parameter place under the normal conditions as is about wages - the more favorable described in the Mineral Act § 18 stk.1 conditions for foreign businesses, the worse and 2 regarding inclusion of the Greenlandic economy is lodged. Also for Greenlandic labour and businesses. this reason a clear indication is important from Naalakkersuisut on any future However, it should be noted that the reductions / exemptions in relation to project cannot be implemented in minimum wages, act on trade and industry. accordance with the bill on large-scale projects if not an IBA agreement has been signed by Naalakkersuisut, Kommuneqarfik sermersooq and London Mining.

Greenlandic workers and companies will not compete with foreign labour 196

and businesses because the IBA agreement states that if qualified workers are available and companies are available which are competitive commercially and technically, they will be offered the jobs/deals first. Only after this procedure has followed can the remaining jobs/deals be offered to foreign labour/companies. 25.11 Corporate taxes from London Mining and other foreign companies London Mining is estimated to start paying dividend BMP: A number of variables influence None London Mining will begin to pay tax when withholding tax immediately after one year of the tax revenue from the project. capital expenditures and expected closure operation; corporate taxes will start to be collected Naalakkersuisut together with external costs are written off. Is there any estimate as when the company cellects profits. The personal consultants are currently assessing the to when the first income tax payments from income taxes will start as soon as the construction economical revenues including the tax London Mining can be expected? starts. Greenland has an established legal system, revenue. Far larger and more experienced countries / including tax laws and London Mining will follow the states with strong resources and specialized laws. tax administrations have problems securing corporate tax paid, where the multinational Naalakkersuisut is aware that the staff companies have revenues. It is not specify - and expertise of the administration, apart from a few comments in the EIA on including the tax administration, but be hiring more in tax administration - how prepared for the tasks in the coming Greenland is expected to manage the task of collecting tax revenue estimated at 28.5 years. Naalakkersuisut is prepared to billion DDK over a 15-year period. support the administration with external specialists is needed.

25.12 Other factors that may affect the Self- Government’s income: BMP: The Greenland Selfgovernment Greenland gained experience from the gold has no exact knowledge about the risk 197

mine at Nalunaq in South Greenland and Comment is a matter for the Government of of the project closing ahead of time None olivine at Atammik in Fiskefjorden Greenland. because of external factures. However, respectively, and their minelife is actually it has minimized the effects and dependent on the world market, and expenses by requiring that a doposit Greenland has no influence on this. How must be paied to the government to does these experiences effect the Self- cover the expenditures of closing the Government assessment of the London minen. Mining project's with regard to long-term economic effects - including the risk / likelihood of a closure within a 15 year period?

25.13 There are many parameters that affect earnings (and thus the Self-Government derivative income) in addition to the world The BFS can only be carried out for the confirmed market: ore resource. The current available resource can only supply 10 years of mine life with 15 Mtpa • Operation period length. Feasibility study production rate. It is expected that with an for the iron mine is calculated from an additional of 10000 m of drilling, the confirmed expected operational life of 15 years. It is resource will eb sufficient for 15 years of mine life. likely that the overall incidence may include a duty cycle for a total of 30 years, and even longer. It will only be finally resolved in the course of five years (information from Dr. North sea routes can be good wishes but can not be Hu). used for a BFS as it is not proven. • Transport distance from the mine to the port of discharge decreases. It is anticipated that approximately 70% are to be sold on the Chinese market. In the context of climate change, there are expectations that a northern sea route will be available to an ever greater extent. This will mean radically changing cost conditions (confirmed by Dr. Please refer to question No 5. Hu). 198

• The energy form (s). The use of hydropower resulting in increased construction costs, but radically less operating expenses, which obviously felt more forcefully, the longer the operation period will be. These factors must be considered in relation to the expected This is not allowed for a BFS, as discussed development of the world market. previsouly. After information from London Mining are the Bankable feasibility study not developed for more than 15 years. In spite of this,

there may be reasons to consider also a longer-term perspective than the 15 years -

including for the demands and expectations for energy use.

25.14 The EIA and SIA assessed respectively Viewpoint acknowledged – no response required. DCE/GN: Nothing to add. consequences for the environment, populations of fish and animals and derived None consequences for the fishing of fishing for commercial and recreational hunters (including traditional activities). At worst, the effects are assessed to have limited negative impacts despite the fact that there is such a marked increase in traffic in Nuup Kangerlua (tankers, supply vessels and ships carrying iron ore and passengers). 199

25.15 Synergy with tourism and leisure services is The SIA has assessed the long term potential also assessed as being positive to some positive impact on the tourism during the None extent. It seems likely that a major industrial operations. The transportation and management activity in the fjord will make tourism more methods referenced in the question refer to the attractive and popular. It is not what has construction periods which is a short term issue and emerged from LM's presentations (both is not significant. BMP and LM's own briefing), where the mine's employees must not move outside the mining area, and during transport from Nuuk to mine and back they will be accompanied by security personnel from the mine.

25.16 To manage - as supervisory authority - the Comment is a matter for the Government of BMP: There is a continuously focus on None series of activities and issues that are Greenland. the requirements imposed on the current, if the Self-Government authorizes government administration related to the construction and operation of an iron the development of mineral projects in mine. It requires the establishment / Greenland. This is also why the hearing construction / expansion of expertise in a process is important, as the different wide range of areas such as.: immigration / departments and institutions in this foreigners (currently state responsibility); process is given the opportunity to customs and tax environment; Nature evaluate whether further assistance is Conservancy; work (currently state needed in the short and in the long run. responsibility); ship inspection (currently To mention one example; the Tax state responsibility). This means that there Authorities have already voiced this will be held a variety of costs (especially if issue as the demand for control etc. in the Self-Government intends to take such this area of administration is migration / immigration from the state) substantial. before there will be income of a significant degree within the Treasury. What consideration has the Self-Government done to prevent this?

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25.17 The debate emphasized that a prerequisite Comment is a matter for the Government of BMP: In the education system today None for a successful outcome of such a project as Greenland. there are already a number education London Mining iron mine, is the use of local actions related to the exploitation labor. A significant part of the latter will be sector. Among others the Mining trained to perform jobs in the mine. This School in Sisimiut can be mentioned. raises a number of questions: Besides these established actions, o What are the forecasts and plans already themes as education, local workforce, available for the training of potential apprentships and similar workforce employees for mining sector? related issues will be a part of the IBA o What is mobility: how many want in the negoations. The Impact Benefit different circumstances to travel / move to Agreement (IBA) is a concrete action work in the mine (results from 'the mobility plan focusing on these issues and is study' did not indicated a very high readiness therefore considered an important to move)? education related document. o If the opposite is proved that mobility is large, the emigration of educated people Mobility and related issues will be from villages and small towns outside of monitored throughout the project in Nuuk mean an migration of the most order to give a foundation for qualified people (which an important eventually future corrections. Detailed resource), which may be important for these monitoring plans have to be prepared places cohesion and survival. by the company (London Mining).

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26. Avataq

No. Question Response from London Mining Response from BMP and/or DCE/GN Amendment to EIA/SIA 26.1 Energy and air emissions

Avataq notes that London Mining Plc (LM) is Please confer response to questions detailed in 5.1 - None planning to use diesel-powered generators to and 5.2 as well as answers to questions raised at the rd meet the energy needs for both mining and 3 public hearing meeting (no. 7-9, 15, 31-34). port facilities (viz. 130 MW and 25 MW). In

view of the large hydropower potential in the area, Avataq considers this deeply problematic and contrary to all good intentions from official sources emphasizing the use of non-fossil energy production.

As justification LM indicates that the hydropower potential cannot meet the total needs of 155 MW. This is difficult to take seriously when pre-investigations made for decades - and even in the former iron mining project design - is indicating the presence of a potential of up to 200 MW.

Furthermore, LM justifies the use of diesel powered electricity production with the construction of a hydroelectric power plant will take up to seven years. This is also contrary to other plans utilizing hydropower 202

potential. These plans operate with a time horizon of five years at the most.

26.2 The Avataq statement on CO2 emission increase is - None Avataq considers it deeply problematic that noticed. this one project with this kind of energy production will increase Greenland CO2 However, the apparently dramatic increase of 89 % emissions by 89%. shall be seen in the context with the fact that Greenland has a very low CO2 emission (i.e. total quantity of CO2) because of the very low number of inhabitants and low industrial activities. All new major industrial development in Greenland will relatively add to increasing CO2 emission in Greenland – also in case hydropower is utilized. See also answer to 5.1, 12.2, 13.4, 24.26 regarding CO2.

Black carbon (BC) is a major component of soot emitted by incomplete combustion of fuel. BC In addition, the emission of the so-called influences cloud formation and reduces the black carbon i.e. soot particles (PM2.5), which reflectivity (albedo) of snow and ice when it is is commonly realized having a strong negative deposited. BC also contributes to the adverse effect, both when it comes to warming of the impacts on human health of PM2.5. Most BC in the atmosphere, in connection with the Arctic comes from emissions outside the Arctic. deposition on snow and ice, which will include increase the melt of the ice cap. In addition, it The air emission from the modern and highly is known to be a connection between PM2.5 efficient diesel power plants specified for the Isua and increased mortality due to respiratory project and running on low sulphur content diesel oil and heart diseases and some types of cancers will fulfill stringent international criteria to deceases. particulate emissions.

The EU enacted PM2.5 ambient air quality criteria specified in a EU directive (Limit values in ambient 203

air for protection of human health and the environment) and enacted in Denmark (cf. BEK nr. 851 of 30/06/2010) are fulfilled in the entire port area and at the mine area outside the open pit.

Since Black Carbon is an integrate part of particulate matter, the health effects associated with Black carbon are taken into account in the EU limit values

for PM10 and PM2.5 for the protection of human health.

26.3 Another problematic issue related to Recent studies indicate that there is no significant DCE / GN recommend that None emissions of soot (PM2.5) is the use of heavy difference in soot or black carbon emission between requirements are set which comply fuel oil on ships to transport iron concentrate heavy and light fuel oil. with the IMO recommendations. Refers through Nuup Kangerlua. To remedy this to the previous section 11.11. serious problem the IMO is preparing the so- The perspective of a Polar Code and the called Polar Code including a significant international initiatives to regulate heavy fuel oil in reduction in the emission of soot using the Arctic waters has been addressed in the EIA (Section heavy fuel oil. 7.1.8).

The viewpoint of Avataq has been noted for future detailed planning and work and is a matter for the Government of Greenland.

26.4 Avataq would therefore recommend that LM London Mining has noticed the position of Avataq. None continues to work towards finding a solution BMP: Requirements related to heavy taking advantage of the area's hydropower contra light fuel will be set in the potential instead of using polluting diesel government approvals. generators. The project should not be implemented without utilizing hydropower. Additionally, we recommend that the project takes advantage of vessel capacity not using heavy fuel oil in order to avoid serious inconvenience from this type of fuel and 204

therefore strives to follow the recommendations considered to be the Polar Code.

26.5 Ballast Water None Avataq notes that the EIA addresses the The responsibility of proper ballast water BMP: Requirements related to problem of introducing invasive species management system is the owner of the ship (as discharge and inspections will be set in through the discharge of ballast water. In stated in the EIA). the government approvals. Navigational Safety Investigation it is stated that the Regulation D-2 of the International Inspection and control of the management system DCE/GN: To reduce the risk of transfer Convention for the Control and Management including the Ballast Water Record Book and/or of invasive species in ballast water, DCE/GN reccomend that all ships that of Ships' Ballast Water and Sediments (BWM) sampling of the ballast water can be made by the will be pursued. come to Greenland from international port State control officers according to BWM waters and ports must It is desirable, however, that it is made clear convention Article 7. discharge/replace ballast water in a who is responsible for the provisions of the zone between 200 and 300 nautical The BWM convention has in its Annex D several miles from the coast of Greenland. In BWM is followed. In Annex 7_Water it is regulations numbered D-1, D-2, D-3, D-4 and D-5. addition, the ballast water should be indicated that "It is assumed that treated when IMO’s Ballast Water responsibility for ships following the The Regulation D-2 is named “Ballast Water Convention is brought into force. convention will rest with the shipping Performance Standards”. These are the overarching DCE/GN refers to the document companies. How can it be assured that the performance standards used in the convention and ”Environmental Requirements and Conditions” (draft DCE/GN February regulations are complied with? to which the various methods shall comply with. This 2013). is the rationale for making reference to this specific

regulation in the report. Additionally, there is a lack of arguments why Regulation D-2 is being satisfactory compared The other regulations deal with other subjects e.g. to Regulation D-3, D-4 and D-5 as well as the “Approval of Ballast Water Management Systems” potential emissions to be expected in (D3); “Prototype Ballast Water Treatment connection with the discharge of chemically Technologies” (D4); and “Review of the Standards by treated ballast water. Organization” (D5).

There are no discrepancies between the various regulations. The D-2, D-3, D-4 and D-5 are 205

complementary to each other. 26.6 Tailings

Avataq has no qualifications to comment in detail on the discharge which takes place The effluent criteria will have the overall objective DCE/GN: Comment in the document None from tailings lake and sedimentation basin. that there will not be toxic effects in the aquatic with proposals for requirements and We note, however, that the emission from environment outside a dilution zone. conditions. Lake 750 will end up in llulialik and Nuup It is expected that the final EIA report, Kangerlua because the lake - through Control of the criteria compliance will continuously as recommended by DCE/GN, will Tarsartuup Tasersua - has its final outflow, be monitored by the company's internal control and include the results of ecotoxicological and at that point hazardous chemicals will be by authorities. In addition, the environmental tests based on ore, tailings and waste discharged into Qussuk. monitoring includes measuring toxic effects. rock.

We also take note of the discharge of various In general iron ore exploitation don’t generate metals to be estimated in many tonnes and it release of large amount of heavy metals to the gives the cause for great concern. We have aquatic environment. Comprehensive geochemical noticed that studies have not been carried tests of the Isua iron (cf. the EIA-Annex 8) confirm out to give any certain conclusion about the this conclusion. impact of the so-called cocktail effect can have in an eco-system. The processing will not add significant amounts of metals transported through the aquatic

environment to the fjord compared to the natural This topic is not addressed in the EIA. The transport of material (including a suite of metals) cocktail effect i.e. the fact that different transported in melt water from the glacier chemical components in various combinations influenced catchment area . Refer to answers in 7.1, may have a (strong) increased eco-toxicity, we 20.2, 20.3, 20.4, 20.8. believe is a serious shortage in the report. London Mining agreed with the recommendation made by DCE, and London Mining is committed to performing complementary eco-toxicity tests early

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in the construction phase, once the necessary feasible conditions for these tests are fulfilled, namely confirmation of the protocols with DCE/GN, access to the site for the shipping of actual samples of Lake 750 water for the tests, availability of more tailings and concentrate materials from metallurgical tests. This commitment is stated in the EIA which was issued for Public Hearings.

- None 26.7 The EIA is deliberately dealing with the Isua project In addition, the LM should also be aware of only. The Isua EIA has to make assessment of factual the available hydropower plans, which will plans and cumulative effects hereof. (see also cause - if they are realized - that the Tailings response no. 20.3 and 31.2) pond (Lake 750) will have its outflow in Ujarassuit Paava fjord. However, having made this position clear, London Mining and its environmental consultant (Orbicon) What impact will the many tonnes of have no indications for flagging environmental emissions have on the eco-system of this concerns related to the effluent from the tailings fjords? It seems that this subject are not lake and a changed position of the outflow to treated in the report, and this is also a Ujarassuit Paava fjord if the Alcoa hydropower deficency. project materializes.

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27. Råstofskolen i Sisimiut

No. Question Response from London Mining Response from BMP and/or DCE/GN Amendment to EIA/SIA

27.1 Greenland workers, such as a machine The salery for Greenlandic employees will be based - None operator, explosive officers and those who on the Greenlandic agreements between SIK and GA have attended common corer courses, and (Greenlandic scale). skilled within mining and construction work as well as trainees. What is the pay scale out? Apart from the four areas!

27.2 Will one also be paid also in free time, The salary will be distributed such that the workers - None because free time is quite long. get regular pay cheques. The salary depends on the How much is the salary for the workers? position, experience and qualification.

The salary will be based on the number of hours worked on site.

27.3 How long must rotation schedules be? In the In section 6.1.2.2 of the SIA it is assumed that the BMP: Rotation schedules can also be an None SIA, it says 4 weeks in and 4 weeks out, and majority of the workers will be working on a 6 weeks issue discussed at the Impact Benefit in another part it says 6 weeks in and 3 in and 3 weeks out rotation during the operations. Agreement negotiations between weeks out so which one will it be? London Mining, Kommuneqarfik Sermersooq and the Greenland Government. 27.4 Should one decide yourself on union? within Comment is a matter for the Government of BMP: If you for example are employeed None the mining and contraction work. Even if you Greenland. in a Greenlandic registered company have a local or country based Association working on the ISUA project in the (SIK), one must have a value as in a construction and production phases you international base model! And one must be are entitled to choose labour union 208

able to even create a union! according to your own wishes, as long as you follow the requirements in the labour unions. You are therefore also free to create your own labour union

Additional questions from Kristian Andersen (student)

No. Question Response from London Mining Response from BMP and/or DCE/GN Amendment to EIA/SIA

27.5 Do you have experience from mining The Director and the Deputy Director for London - None industry in Arctic? Mining Greenland have significant experiences from mining industry in the Arctic. Furthermore, the engineering team is led by the Canadian SNC Lavallin, a well-recognised mining engineering consultancy, with a long list of references in mining in the Arctic.

27.6 Equipment: Construction equipemnt and No. The needed equipment will be included in the - None pipeline? Do you have these already tendering procedure.

27.7 Wil the monthly salery include salery for The salary will be based on the number of hours - None freetime periods? worked on site.

The salary will be distributed such that the workers get regular pay cheques.

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27.8 Where is the salery level? The salary level will follow Greenlandic legislation. - None

27.9 Is it possible to use non-polution energy As far as to the use of hydropower, see answer to - None source? question number 5.1.

27.10 Will the permafrost potentially be a The permafrost is not expected to be a problem for - None probelm in the construction of the road? the construction of the road. And where?

27.11 (Culturel and naturel values) 9 out of 10 In section 5.8 Cultural and Natural Values is stated - None are hunters in Greenland, where do you that 9 out of 10 consider traditional activities have this from? And the dogsledgse during important for their identify and wellbeing. This winter in Nuuk ”Isukasia”? information is from the Survey of Living Conditions in the Artic (Poppel et al 2007).

There will be no dog sledges used in Nuuk. It is only possible to have dogs in Sisimiut (the southernmost area in West Greenland, where it is legal).

27.12 Are there room for apentices and The camp will not be for spouses and children. - None employees with ”spouses and children”

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28. Jacob Mathiassen

No. Question Response from London Mining Response from BMP and/or DCE/GN Amendment to EIA/SIA 28.1 BMP: The Government of Greenland is I am generally positive about the use of the focused on supporting Hydro Power if None iron ore - and to the aluminum project - but I this is possible in a financial and a think there are serious shortcomings in the technical way. A decision related to the project design. use of Hydro Power also has to be realistic, and therefore it is a must that all these considerations are taking into Regarding that part of the comment about CO2 account when these decisions are In any case, the project should be carried out emission by Isua project, answers are given in 5.1, taken. on the basis of the principles of 12.2, 24.26 and 26.2.

sustainability. The current project design with two diesel plants totaling 160 MW implies that Greenland's current greenhouse gas emissions will double, which is unacceptable when a hydropower potential

is available in the area. Using diesel is not in compliance with either BAT or BEP.

It is the responsibility of Naallakkersuisuts that projects in Greenland are implemented in the most appropriate way. It is not Naalakkersuisut responsibility that the

company maximizes its profits in the shortest time possible. As the project must comply with environmental regulations etc., 211

Naalakkersuisut should ensure that the project meets the Greenlandic legitimate interest of reducing emissions of greenhouse gases by e.g. using available hydropower resources.

My main conclusion is therefore that London Mining should not be given the exploitation license until there is a satisfactory solution to

the energy supply issue. This should include the power supply to the mine, but ideally also the port by hydro-based electricity.

28.2 1. Ambiguity, omissions and possible The principles of BAT (Best Available Techniques) None sources of errors in the EIA and in the SIA and BEP (Best Environmental Practice) are - when compared to BMP guidelines in mentioned in the Mineral Resources Act as well in November 2009, including non-compliance the BMP EIA Guidelines. Detailed description of with the principles of BAT and BEP. what is defined as BAT and BEP is not part of the act or guidelines.

One of the main purposes of an EIA is In the EU directives and thus the Danish legislation, besides listing projects influences on the the BAT principle has the following definition: environment, etc. to identify how these impacts can be minimized or avoided ‘Available techniques’ means those developed on a scale which allows implementation in the relevant altogether. This is not done properly - if at all industrial sector, under economically and – with regard to the hydropower potential technically viable conditions, taking into and economic comparisons between diesel consideration the costs and advantages, whether solution and a full or partial hydro-based or not the techniques are used or produced inside energy supply. the Member State in question, as long as they are reasonably accessible to the operator. 212

In other words economically, technical and accessible aspects shall be considered before it can be concluded whether a solution is BAT or non- In the EIA section. 05.4 on energy, it is said BAT. inter alia: In the actual Isua iron ore project using diesel "The 160 MW energy is 100% based on fossil generated power supply, London Mining and its fuel with diesel generators. Both technical consultant (SNC Lavalin), has analyzed hydropower as well as combinations of these aspects and concluded that the hydropower hydro and diesel power were also solutions resources (the Imarssuaq scheme) is reserved for taken in consideration. The possibilities of other purposes; that the constructing period for a hydropower from the area have been hydropower plant is 7+ years conflicting with the studied for years. Based on the studies marked situation; the construction is technical conducted (summarized in Annex 9), it is complex due to inaccessible terrain and harsh estimated that a plant based on lake climate; and consequently the construction cost Imarssuaq could provide hydropower are high and uncertain; and will require a longer approx. 120 MW. Hydropower based on lake depreciation period than the actual proven iron Taserssuaq would deliver approx. 80 MW. In resources allow. Thus the financing aspects are both cases diesel generators are needed to very difficult. The overall conclusion is that the meet the full energy requirements. These hydropower solution is not technical and economic alternatives seem attractive regarding attractive. Also refer to answer given in 5.1 and reduced CO2 emissions, but studies have 13.4. also shown that hydropower that would be involved in the ISUA project is not financially Therefore it cannot be concluded that the diesel attractive. Water-power resources are also solution is not BAT. studied for other purposes, and will not likely be available in relation to the ISUA project. Overall, hydropower is not a feasible option due to the schedule for the ISUA project where operations start in 2015. Diesel generators can be established in the course of a year. " 28.3 1.1 Incorrect inventory of hydropower potential: 213

Hydropower potential based on Imarsuaq A number of similar questions and viewpoints on - None and surrounding water catchment area is hydropower issues have also been raised as part of not only 120 MW, but 175-200 MW, which is the 3rd public hearing meeting held on 24. revealed by Alcoa studies which therefore September 2012. A detailed response has been implies that of the potential London Mining included in replies to the 3rd meeting questions no. need for 160 MW can be met. 7, 8, 9, 15, 31, 32, 33; and-34 and also summarized in the answer to the written comment no. 5.1 and 5.2. Please confer these replies.

Nukiisiorfiit name it 06.g and on the basis of measurements made in 1974-94, its hydropower potential is estimated to be 154 MW. However, as observed for all hydropower potentials which were examined later, it is assessed this to be higher today (+ 14-30%).

In addition to the other hydropower potential mentioned in the EIA, Tasersuaq (06.h) rated at 65 MW based on previous measurements, while its potential is considered to be 80 MW (i.e. 23% higher). There is also a hydropower potential in Southern Isortuup Isua (07.d) which was rated at 125 MW based on previous measurements in 1974-83.However, today it is likely to be considerably higher.

It should also be borne in mind that Annex 9 only is "... initial evaluation study of alternative hydropower plans ...". Therefore, 214 definitive conclusions should not draw for the project on the basis of the studies, London Mining has been carried out.

My conclusion: It is not true that there is no hydropower solutions to meet the full needs without requiring additional diesel generators.

Moreover, there is nothing to prevent a solution that combines hydro and diesel power, if there is an indispensable need to supplement available hydropower resources. The need at the harbor - which over the last year has increased from 15 to 35 MW, without any explanation – could be covered with diesel if another solution is not possible.

Finally, there is the opportunity to resolve any hydroelectric power deficit that the project measured according to the available hydropower resources. Feasibility studies at 10 Mtpa was, to my knowledge, also highly profitable.

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It is true that the potential is / has been reserved for the aluminum project, but as will be further described in Section 2, the total hydropower potential of a total of approximately 400 MW in the area, has to be seen in conjunction with the aluminum project and the objective of Greenland to exploit the country's hydropower resources to produce green power.

As late as in presenting the basis for the decision proposal EM2012/113, Naalakkersuisut stressed the rationale that,:

"Establishment of a number of large-scale commercial projects - mining and industrial projects based on the use of our hydropower resources – will be considered by Naalakkersuisut to be important contributions to the development of our country in the direction of becoming financially self-sustaining." [My emphasis].

28.4 1.2 Economic comparison of diesel and hydropower solution and CO2 emissions: None The same viewpoints were raised at the 3rd public - The economic and other comparisons shown meeting and the replies can be seen in answers to 216 in Table 4.9, page 93 appears to be partly no. 31 and 32 and for easy reference also quoted erroneous and incomplete not to use below: stronger words. They even contradict clear An engineering study has different accuracy levels. conclusions on the same page 93: LM is not sure what engineering levels and development stages were the referred hydropower studies. For LM’s own reference, our engineering "The studies of hydropower as contained in consultant SNC Lavalin has carried out its own Annex 9 shows that the ISUA project with a study at a scoping level and concluded that the secure hydropower within the economical viability hydropower option is not economically is as indicated in the submitted documents, that is sustainable." 120 MW.

LM does not have the right to use the water in the project area. The financial analyses have also

shown that the capital investment has a very If we just look at the diesel solution (fossil) significant impact to the project economics. An accurate financial analysis has to take all factors compared to Imarssuaq (hydropower), then into the evaluation, including the project capital the investment and operating costs are cost, operational cost, production rate, estimated calculated as follow (for 125 MW): near term and long term product prices, financing conditions and freight arrangements etc. The Mio U.S. $ Diesel Imarssuaq simple calculation as shown in this comment (Hydropower) Difference cannot reflect the real project economic condition. Based on the financial model developed by SNC Investments (Capex) 221 677 +456 Lavalin, the increased capital expenses combined Operating expenses (OPEX) 299 42 -257 with the estimated delay for the production will make the project not financially attractive. This will Additional investment for hydropower is 456 make the project not feasible. million U.S. $. The savings of hydropower in operating costs is 257 million U.S. $. This means that in less than two years of operation, the entire additional investment will be recouped.

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(There is negative cash flow during construction, etc., but it does not affect the overall picture).

If the total energy requirement is considered to the effect of 160 MW, diesel consumption will by 24syv operation and 85% load to 250 million liters per year. Import cost at the current 5.85 kr / liter will be 1,463 million DKK.

Regardless of how the equations are made up, for a savings of over 1.4 billion DKK interest and repaid even very large and heavy investment hydropower plants over a very short period of time.

The conclusion made by London Mining on the lack of economic sustainability is therefore wrong.

28.5 There are no contradictions between the EIA The figures for CO2 emissions are not figures and the figures seen in Greenland Statistics. DCE/GN: Nothing to add. None consistent with the statements Greenland The figures for CO2 emissions from Greenland are based on Greenland Statistics Yearbook 2011 218

Statistics do. Based on the SG's numbers, having figures from 2002- 2009. The total import of emissions of CO2 per tons of gas oil amount liquid fuel as average of 2002-2009 was 251 million to approx. 3.15 tons. London Mining liter/year having an estimated CO2 emission of 0.63 million tons CO2 according to the Statistical expected consumption of 250 million liters Yearbook (i.e. average of 2.5 tons CO2 per m3 fuel). of ~ 208,000 tons will imply an emission of 82 % of the imported fuel is stated as ‘arctic gasoil’ 655,000 tons. and ‘motor gasoil’. The figures can be seen on the Greenland Statics web page http://www.stat.gl/dialog/main.asp?lang=da&versi on=2011&link=EN&subthemecode=t7&colcode=t Greenland emissions from diesel in 2010 The total estimated consumption of arctic diesel were 553,000 tons at a consumption of for the Isua project operational period is 210 about 176 million tons of gas oil. million liter/year and not 250 million liter per year as stated in the viewpoint. Furthermore 78 % are used for power supply and 22 % for mobile equipment (cf. EIA section 4.7.1).

28.6 In Annex 9, section 4.4 is a financial analysis See response no. 28.3 and 28.4 - None with the calculation of the project's internal rate of return, equity internal business and NPV after tax. These requirements are not specified, but it looks as if the value of the hydroelectric power plant after 15 years set to 0. Similar, it cannot be identified if the closure cost (clean-up cost) in the diesel scenario id included.

Based on a reviewed of the London Mining figures, the project is anyway extraordinary profitable, meaning that the payback period of the investment is only 3.5 years,

increasing to 4.3 years if a construction of a

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hydroelectric power station is built. The increase from 3.5 to 4.3 years can probably be explained by the negative cash flow

during the construction of the hydroelectric

power plant. As shown above, in the following years, a saving in operating Refer to answer given in 5.1 and 13.4. expenses will excess 1.4 billion kroner, so the equations will look completely different.

There can be only two reasons why London Mining rejects the hydropower solution. One may be that they are so busy to get started that they do not want to spend time on detailed studies and construction of hydroelectric power station. The second is - regrettable - that ISUA project cannot be awarded the most obvious hydropower potential, namely Imarssuaq. This issue will be addressed in Section 2 below.

28.7 The preliminary conclusion regarding the The CO2 emission with an annual consumption of - None choice of energy and the consequences for 210 million liter of diesel is estimated to 0.56 CO2 emissions, etc. can only be: million tons CO2/year and is based on international London Mining takes wrong decisions in a acknowledged factors between CO2 and oil preliminary, on the basis of incomplete and products used for energy supply. The CO2 emission to some extent obviously wrong numbers. from Greenland in the period 2002 – 2009 is based on data from Greenland Statistics. There is no reason for corrections of the CO2 emissions. Refer to answers given in 5.1, 12.2, 24.26, 26.2. 220

The EIA and its assumptions should be corrected and extended in terms of The CO2 emission from ships traffic to/from the economic calculations and assumptions. mining project sailing through Godthåbsfjorden is estimated in the EIA section 7.1.8. The amount of CO2 from ships is modest compared to the overall emission from the project.

Income from or value of hydropower plant beyond The calculation of CO2 emissions should be the project period used for other purposes not corrected and include emissions from other identified nor agreed upon is hypothetical and activities, including shipping, if necessary, cannot be used in the BFS and is thus outside the project and the SIA. emissions of greenhouse gases from

explosives, etc. Trade with quotas of CO2 is a political issue. For the time being the future for CO2 trading is

unresolved. As appropriate, the results from adjusted calculations should be included in the SIA (e.g. the value of hydroelectric power for other uses after termination of the mining activities), expenses saved for purchase of CO2 quota, etc.).

28.8 The EIA should also include a detailed The question of cumulative effects utilizing water - None description of the mining project discharge for transporting iron concentrate with other into lakes that may affect the same lake projects for utilizing hydropower has also been systems hydropower potential in relation to addressed in answer to hearing input 20.3. Please any changes in the distribution of runoff confer the response. over the year, changes in water quality and the possible impact on the wear of turbines, However, the conclusion is correct since there will etc. be no or only marginally consequences for the (The conveying water at approx. 8 million hydropower potential. m3/year must be deducted from the 221

potential of the lakes. However, this must be considered as marginal.

28.9 The SIA should include information about Same question has been answered as part of None when the stipulated corporate taxes are response 2.1. Please confer. expected to flow into the Treasury.

28.10 Tailings It appears that Lake 750, over 15 years, will The London Mining expectations are that the iron be filled up with 232 million. m3 of tailings, resource estimate can be upgraded to 15 years of DCE/GN: DCE/GN recommend that, for None i.e. approx. 15 million m3/year. After 15 mine life with a production of 15 Mtpa upon some any prolonging of the production years of operation, the remaining volume additional exploration drilling. The assumption of period, a preparation of an EIA be will be 32 million m3 or a maximum of two 15 years mine life of 15 Mtpa has been the basis required. additional years of operation. for the EIA.

If the mine life is extended beyond the assumption for the approval the conditions shall be reassessed There are discussions about the possibility of including assessment of the capacity of the tailings extending significantly the length of the lake and a number of other conditions. Since there operating time (30 + years). Irrespectively, is no actual plans and no application for such a that operation period is only planned for 15 production this aspect is outside the scope of the EIA. years of operation, this crucial condition

should be assessed in the EIA in terms of Please also confer response to question 24.16. safe deposit and without pollution.

The DCE/GN comment about the requirement to prepare an EIA for an operating period beyond 15 Conclusion years is noted. London Mining must explain how tailings are expected to be deposited when Lake 750 is filled.

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28.11 Lake 792 It is mentioned in many different figures for The water balance of Lake 792 and Lake 750 is DCE/GN: Nothing to add. None the inlet and outlet of water from Lake 792. important. The hydrology is however complicated The question is really outside of what is which is evident when the water balance diagram central in this hearing input, but for in the EIA section 7.1.2 is observed. The diagram information only some examples from Annex has been constructed with great care as part of the 7: BFS utilizing all available hydrological data. 1) Page 64 mentioned that 3% of the outflow equivalent to 8.1 million m3 will be used to The water flows are annual averages and transport iron concentrate through the considered to be the best estimates for long time slurry pipeline to the port. The remaining series. London Mining has initiated hydrological 97%, which is also mentioned on page 63, measurements and figures from 2010 and 2011 are must therefore be 262 million m3. also seen in the EIA report. These figures are indeed not identical to longer time series which is 2) From Figure 2-4 on page 14 shows that clearly spelled out in the EIA report Annex 7 the annual inflow is 91 million m3 and that (section 4.3.1). The flow for 2010 and 2011 was 30.1 will be used to 'process and flush'. higher due to higher melting rates compared to (Perhaps the figure of 91 is a typist error. If it average melting rates based on long time series. says 191 the water balance in Figure 2-4 to Mentioning various figures for the outlet of Lake fit reasonably). 792 are not indicative for ’errors’.

3) In Table 4-2 is 'Annual discharge' (which I The inflow in to Lake 792 will cease out in the assume means discharge) from the lake winter period. The continuous abstraction of listed as 133/138 million m3/year in process water in winter month will consequently lower the water level in the lake. These 2010/2011. consequences are also described in the EIA section 7.1.2. 4) In Table 5-1 on page 68 is 'existing outflow from Lake 792 substracted process water' set to 111 million m3. If the process water is 31, the total outlet in this calculation is the 141.

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It is surprising that a lake in 800 meters close to the ice at very low temperatures can be tributaries year round. With normal water consumption for 6-7 months, there will be a deficit in the Lake 792 of up to 15-17 million m3. Compared to the modest volume of the lake estimated to 41 million m3, there must be a significant risk that the mine cannot run at full speed all year.

28.12 2. The project's failure to meet the objectives of Naalakkersuisut coalition agreement, including the need to see hydropower resources for iron mining and aluminum project in a larger and longer- term context.

London Mining during both informal London Mining is willing to purchase power from None conversations and later at the public hydropower plants operated by third parties if meeting on October 8th stated that it would these options exist. DCE/GN: See comment to question 5.1. prefer to base the energy supply on hydroelectric power, but that it does not This has also been announced at the 3rd public have the financial strength to build hearing meeting – see answer no.9. hydroelectric plant. If another company was to build hydroelectric plant with the ability to supply energy to iron mine, they will be more than happy to buy energy. (These statements are made in spite of the summary and incorrectly reasoned rejection of the EIA of a hydropower solution.)

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London Mining has also expressed that it was because of the intent to get started as soon as possible with mining and it could also imagine a temporary diesel solution that replaces hydropower, once hydropower plant (s) are built.

Conclusion London Mining should be associated with its application a clear expression of the opportunities the company envisages a long- term, environmentally friendly solution to the energy, see the statements made verbally by more or less official occasions.

28.13 Naalakkersuisut objectives on energy and the environment as expressed in the coalition agreement of June 2009 is clear London Mining will indeed comply with conditions and ambitious: and requirements determined by the Greenland Government DCE/GN: See comment to question 5.1. None "Climate area: ... By setting clear goals on climate change for the industry and for the rest of society we will ensure that Greenland also after 50 years is known as a beautiful country with a population putting actions behind its words when it comes to sustainable use of natural resources.

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Energy

The energy sector must continue to focus on development of environmentally friendly energy sources, such as hydropower. A Greenland, which primarily derives its energy from green energy, is the bearing vision…

Mining, heavy industry and oil

The prospect of rising global prices for minerals and fossil fuels has renewed the focus for ways to leverage our non-living resources; the economic implications can be very large. Therefore, it is important that Naalakkersuisut mineral exploration policy is closely coordinated with industrial policy, labor market policy, environmental policy ...

We accept exploitation of non-living resources as an important potential - not at the expenses of the environment. When self-government is a reality and Greenland has taken over responsibility for the non- living resources, it is important that the law ensures people direct influence and

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involvement in decision-making. "

London Mining should of course feel committed to these objectives and therefore do its utmost to fulfill them.

28.14 Comment for the Greenland Government. It is even more Naalakkersuisut commitment BMP: The Government of Greenland is None to pursue these objectives and to see the focused on supporting Hydro Power if energy supply for iron mining and aluminum this is possible in a financial and a technical way. A decision related to the project in a larger context including the use of Hydro Power also has to be maximum use of available hydropower realistic, and therefore it is a must that resources of about 400 MW in the area. It is all these considerations are taking into not Naalakkersuisut obligation to ensure account when these decisions are companies maximized profits when ensuring taken. that licenses for exploitation and establishment is given with respect for their own political objectives.

On the aluminum area process technology has developed rapidly. Alcoa has already raised the expected production from the initial 340,000 tons / year to 400,000 tons / year after what I have been told, based on a technology that uses approximately 390 kAmp. There is already production

227 elsewhere in the world on the basis of 440- technology and testing for time at both 500 - and 600 kAmp technologies. The increase in production is hardly proportional, but it can be expected that Alcoa in a few years will be able to produce the 340th-400 000 tons / year with a current capacity of less than the current 650 MW.

The following long-term solution enabling Alcoa the option after 15-30 years to have an even larger production than the 400,000 tons / year. Alcoa has at public meetings and other occasions often expressed (quote):

"Alcoa will be part of the Greenlandic society".

Alcoa prides itself on a very high environmental profile and it should therefore not be difficult to get Alcoa to contribute to social and environmentally sound solution, while taking into account the companies' commercial interests. If the (t) south hydroelectric plant is constructed by another company, it will furthermore reduce Alcoa's financial burden.

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28.15 A vision could be the following:

VISION Comments for the Greenland Government. BMP: Suggesting regarding an None Naalakkersuisut intermediary - possibly in independent company is noted. collaboration with London Mining and Alcoa - to form an independent company in charge of the construction of hydroelectric power stations in the area, so that both London Mining and Alcoa can get the required supply of energy from 2-3 hydroelectric plants in the area.

There are already very large players in the area who might be interested, for example, Statkraft, Vattenfall and Landsvirkjun. DONG could also be relevant.

Hydroelectric plants are connected in a coherent network, which for the time being is sufficient for the iron mine at ISUA and the aluminum smelter at Maniitsoq. It will provide greater security for both Alcoa and the iron mine and hydroelectric power will already be available at the coast.

In the longer term, when the iron mine is depleted, Alcoa will have the opportunity for

229 even greater supply totaling 500 to 700 MW or create other energy-intensive industries at the coastal areas. There has already been considered hydrogen technology, server farms, zinc refinery mm

Hoping that Naalakkersuisut and Inatsisartut - and London Mining and Alcoa - will see energy supply for large-scale projects in a broader context.

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29 Jakob Mathiassen II

No. Question Response from London Mining Response from BMP and/or DCE/GN Amendment to EIA/SIA

29.1 The area applied, as shown on the map on This is a relevant observation. DCE/GN: Nothing to add. The map is the web portal, includes as far as I can see The area applied for should include the entire not part of only the northern tip of the Lake 750 surface area of Lake 750 since this lake will the EIA or (Tailings Pond). become a technical part of the project. SIA. No changes to the reports are required.

A correction to the licence area application will be forwarded to the BMP by London Mining.

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30. Departementet for Fiskeri, Fangs tog Landbrug (APNN) – Department of Fiskeries, Hunting and Farming

No. Question Response from London Mining Response from BMP and/or DCE/GN Amendment to EIA/SIA 30.1 The project is situated in a caribou area The construction of a large mine including over DCE/GN recommend that caribou None where professional hunters, leisure hunters 100 km of road/pipeline and a port facility in a population’s use of the area is and trophy hunters explore caribou in the caribou area cannot take place without some monitored, in order to assess whether hunting season. The hunting season is disturbance of the animals. In particular the the proposed mitigation measures are typically from the beginning of August to activities during construction of the road/pipeline having the desired effect. October. According to section 4.8 in Annex 2 are expected to have an impact on caribou. of the EIA caribou in August mainly occur in However, the construction works will be of limited the flat lowlands in Narsarsuaq, in the duration and during operation the disturbance will valleys of Ilulialik and in Qussuk. There is be much less. For example will the noise impact be clearly a conflict of interests between the much smaller and the mine staff will not be professional hunters, leisure hunters and allowed to leave the working areas. Also helicopter trophy hunters and London Mining. traffic will be much less during operation. Based on experience from other mines the EIA report According to the EIA caribou is mainly concludes that caribou will be disturbed in a zone present in the planned port area 2-5 km wide round the mine facilities. This means (Taseraarsuk) from August to April, in the that caribou will occur in lower numbers in this planned mine area (Isuakasia) between June zone (but not necessarily be absent). The caribou and September, while they occur around the will probably habituate to the traffic on the road planned airport (west of Kuussuaq in after some years. Disturbance will therefore Ilulialik) all year. According to Annex 2 of the mainly take place in the zone round the port and – EIA a large area northwest of the planned during the first years – along the road through mine area has large number of female Narsarsuaq and Illulialik. We agree that some of caribou with small calves and this area has these areas have very lush vegetation but only a been appointed “important area for very small part of this will be within the wildlife” by the National Centre of disturbance zone. In the EIA we conclude, that Environment and Energy because of the hunting will only be affected in a relatively small many calving caribou. The planned road and area and that this is unlikely to have an impact on pipeline between the port and the mine will the caribou population in the area. pass through wintering-, summer- and 232

calving areas as well as cross paths used by It should be noted that the important calving area caribou for their annual migration. Noisy identified by DCE/NERI is well outside the project activities during the construction phase such area. as blasting, noise from machines and disturbance from staff that moves around in the area will disturb caribou significantly and they will move to other places. The disturbed areas are lush and particularly important for caribou and it is difficult to identify other areas that are as important to caribou as Taseraarsuk, Narsarsuaq and Ilulialik. According to Annex 2 of the EIA fewer female caribou with calves were observed in the Narsarsuaq-valley in the last years and this could indicate how sensitive the caribou are to disturbance. Surveys and human activities in the area also disturb the animals. It is the hunter’s view that caribou in Ilulialik area already have moved away due to disturbance from helicopters flying much to low and other activities.

30.2 Shipping in the Godthåbsfjord has been assessed DCE/GN recommend launching a None The EIA focuses on sea birds and it is to have low impact on breeding sea birds because monitoring of seabird uses of the sites assessed in Annex 3 that the planned the weekly vessel, which moves at a speed of only along the shipping route. Refers to the project only will have low impact on the sea c. 10 knots, will pass the colonies at a distance of document with proposals for birds in the area. It is said that shipping in several kilometers. This is believed to have little monitoring. the Godthåbsfjord will not increase disturbance impact on the nesting and foraging sea significantly, that the vessels will move birds. slowly and keep a distance of 2-3 km from The main wintering area for Eider ducks in the the sea bird colonies. As is also mentioned Godthåbsfjord is situated at Nipisat Sound near the in the Annex 3 of the EIA the Godthåbsfjord mouth of the fjord and just across Nuuk. The slow is one of the most important wintering areas moving vessels navigating along the center line of for the West Greenland population of Eider the fjord will be at least 3 km from Nipisat Sound. 233

duck (Somateria mollissima). According to The ships are therefore not believed to disturb the the Greenland Red List (2007) this species is wintering sea ducks at this site. assessed as vulnerable and the importance A shipping accident that leads to an oil spill in the of this area for the entire population is high. fjord can have very severe consequences for This means that disturbance from shipping wintering eiders. However, navigation of large bulk or pollution such as an oil spill will have carriers is a standard practice in the world; large consequences for the eider duck maritime regulations are followed by ships population. Eiders is one of the most hunted companies and the contingency plan and sea birds in Greenland and has thereby high procedure for combating oil spills are in place; the cultural value and to some extent also high likelihood of a major oil spill that would impact the economical value. eiders is deemed to be very low.

30.3 All terrestrial birds that occur in the project area DCE/GN: Nothing to add. None The impacts of the project on the areas are discussed in Annex 1 to the EIA. Special terrestrial birds is not prioritized in spite of emphasis is paid on species on the Greenland Red the fact that several threatened (near List of threatened species. To supplement the threatened and moderate threatened) literature study and ad hoc field observations two species occur. Species such as the Greenland special field studies were carried out (1) mapping White-fronted goose (Anser albifrons and assessment of the importance of spring flavirostris), Great Northern Diver (Gavia staging areas for Greenland White-fronted goose immer) and Harlequin Duck (Histrionicus in the project area and (2) mapping of breeding histrionicus) and mentioned in the EIA under Harlequin Duck in the project area. Birds section 0.7.2, 5.3.3 and 7.2.2, but the associated with habitats other that the fjord has impacts of these species from the planned therefore not been given less emphasis than sea project are assessed as low. This is in spite birds. of the fact that the area is an important The EIA specifically list a mitigation measure that staging area for migrating Greenland White- aims at minimizing the disturbance of Greenland fronted geese in spring. Greenland White- White-fronted geese in spring (“In years when thin fronted geese is an endemic species which snow cover and early snow melting is recorded, the means that Greenland has a responsibility to environmental officer will advise London Mining’s protect this species. The Agreement on the personnel on how to keep disturbance of staging Conservation of African-Eurasian Migratory Greenland White-fronted geese at a minimum Waterbirds (AEWA) is currently preparing a during the first three weeks of May”). management plan for the Greenland White- Specific mitigating measures are not given 234 fronted Goose. Although Greenland is not regarding Great Northern Diver because this member of AEWA, Greenland has been species mainly breed at large lakes in the lowland involved in the preparation of this plan. One where no disturbance outside the port area will of the key points in the plan is that the take place during the operation phase (the staff spring staging areas for the geese must be will not be allowed to leave the working area). protected, because it is essential for the The survey area addressed in Annex 1 only covers geese to find food after migrating across the the land and port area. An additional survey area Inland Ice cap in order to complete the that covers the shipping route in the fjord is migration to the breeding sites. The planned included in Annex 3. project will disturb important staging areas.

According to the Greenland Red List is one of the threats to the Great Northern Diver, which is assessed as near threatened, disturbance of the breeding grounds from mineral project. However, the report suggests no mitigating measures that can minimize this disturbance. Orbicon’s annex on animals and plants of the project area defines a survey area, but this area does not include the entire project area. It is therefore difficult to assess how many Great Northern Diver nest sites there are in the area and to what extent the birds will be disturbed.

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31. Dep. for Indenrigsanliggender, Natur og Miljø (NNPAN)

No. Question Response from London Mining Response from BMP and/or DCE/GN Amendment to EIA / SIA 31.1 Ancient rocks and traces of life None Isua rocks differ from the other very old When a mine company applies for permission to - rocks in Nuuk region in that they are initially initiate exploration activities in an area it is formed in the surface environment of the ultimately with the purpose to open a mine. It is earth. Isua rocks are the oldest and best therefore the responsibility of the government to preserved rocks which can provide ensure that exploration for minerals is not granted information about conditions at the surface in a site where it is considered as a reservation of Earth's earliest geological history, which is area which pose a significant social, therefore of great scientific importance. environmental, scientific or other values. Minik Rosing, from the Natural History Museum, University of Copenhagen has Furthermore, the Greenland National Museum has identified 3 sub-areas where the oldest rocks conducted archeological surveys to bring to the can be found, see attached map. In the EIA project development the necessary inputs and this aspect is not explained, despite the fact recommendations in this respect. Refer to answer that NNPAN has clarified this aspect during in 11.2. the scoping phase. Among the areas of geological importance identified by Minik Rosing sub-area 1 and 2 are situated far from the constructions areas of the Isua project. Sub-site 3 is located c. 2 km south of the processing plant and accommodation site and c. 7 km from the mine pit. A service road and tailings pipeline will go across the site but this will not impact the geological formation per see.

31.2 Cumulative effects

It is in BMP guidance for EIA assumed that LM and its environmental consultant agree that in DCE/GN: Nothing to add. None an EIA must account for the cumulative addition to an assessment of significant individual 236

effects. project component, an overall assessment must also be presented. The total effects of the Isua NNPAN notes that the impact of the various projects are presented in the “Conclusions of the projects and components are quantified with EIA” page 38-41. This also includes the overall and without mitigation measures impacts of the various project activities on caribou. respectively for the project, but that the total effect of all components of the project LM and its environmental consultant are aware of are not accounted for. NNPAN considers it BMP’s requirement to take into account the appropriate to explain the cumulative effects cumulative effects of other projects in the same of the various components of the Isua area. However, at the Isua iron ore project is the project, for example the cumulative effects only scheme that has reached a stage where the on caribou when the process plant, haul constructions works have been defined and an road, runway, harbor, etc. is established and application to start building has been submitted to operational. the Greenlandic authorities for approval. It is therefore not possible to assess specific potential Furthermore, it is relevant that the EIA cumulative effects of other project, such as the describes the cumulative effects of the Alcoa since no detailed plans are available or Alcoa's aluminum smelting plant, despite the approved. fact that a decision to realize the project is not yet taken. This assessment shall include This perception and approach is also in compliance cumulative effects associated with with e.g. the Danish EIA guidelines issued by the disturbance of caribou and the use of water Danish Ministry of Environment. In these resources in the area. NNPAN notes that the guidelines cumulating effects are defined as lakes used by Alcoa are in the same area as impacts from other existing projects or plants Lake 750 and Lake 792, as per the attached and/or approved projects and plans. (cf. Vejl nr. Appendix Map 2. In case Alcoa project is 9339 “Vejledning om VVM I planloven”). realized it may imply that the tailings water will follow a different route than the one described in the EIA, page 106-107. Impact of caribou

31.3 Use of significance levels in mitigation In the early stage of the EIA, it was assesed that a DCE/GN: See answer 30.1. None measure tables, seem unclear. Especially the slurry pipeline would pose a impediment to table "Barrier effect during the operational caribou movements at a regional level. London phase as a result of pipeline with 45 ramps Mining therefore decided to include caribou 237

to passage" is confusing, since significance crossing ramps as part of the road-pipeline design. without mitigation measures is considered When assessing the impact of the barrier effect of to be "low". This is not in line with preceding the pipeline on caribou without mitigation in the paragraph of the report, which refers to "the table section 7.2.4 it is therefore takes into 105 km long road pipeline from the inland account the 45 ramps. The proposed mitigation in ice to the fjord will pose a serious obstacle the table concerns only if additional ramps are or a complete barrier to caribou movements constructed based on future monitoring work. at regional level, if not ramps that allow animals to pass are established." Also it is described as mitigation measures that the number, location and design of the ramps should be adjusted, if the results of future monitoring program show a need. NNPAN welcomes the establishment of a monitoring program. NNPAN recommend that the monitoring program shall be adjusted so that it is possible to quickly change the project if it is found that there had to be barrier effects as a result of the project's infrastructure.

31.4 In connection with the potential barrier The disturbance impact at the port and along the DCE/GN: See answer number 30.1. None effects NNPAN notes further that in the road is expected to cause displacement of caribou Annex of the EIA that deals with caribou it is from a zone extending 2-5 km away. This does not noted that it is a well-known fact the caribou mean that caribou are expected to completely will be scared away from roads and other disappear from the zone but to occur in lower infrastructure at a distance of 2-5 km to each density than previous condition. The zone along side. However it is not estimated in the EIA the road is expected to become very narrow or that this disorder affects the caribou more even disappear as experience from North America than "medium" because "food supply in the show that caribou readily adapt to vehicles on a huge neighboring areas is likely to be of the road. same or almost the same quality." NNPAN The construction of the Isua project will cause would like this presumption to be supported displacement of caribou from important feeding and provided some evidence, as Figure 4-4 areas at Qussuk and along the road in the and 4-10 in Annex 2 of the EIA shows that it Narsarsuaq valley (the first years). The question is 238

is precisely Narsarsuaq valley that is the how large a part of the population that will be caribou core area in winter, as this is where impacted and what the consequences will be. the biggest food supply exists. Narsarsuaq valley is 8 km wide at its widest point, which Caribou are mainly present near the proposed port means that the animals are potentially being site at Qussuk during late autumn and winter displaced from this important core area. If (August-April). Caribou that are displaced from the Figure 2-1, 4-4 and 4-10 are compared it is disturbance zone are forced to find food in other furthermore shown that a large part of the areas. Although the Narsarsuaq Valley without core area of caribou in study area of the EIA doubt is a key area for wintering caribou, other is inaccessible to animals by establishing sites with good food supply are available in the project infrastructure. In view of the above, region. This includes the Akia-Nordlandet which NNPAN it is unclear on what basis the according to GINR was where most caribou (in the disturbance of the animals is considered to Godthåbsfjord area) spend the winter between be "medium". A more detailed analysis of 2000 and 2005. whether food resources in adjacent coastal areas are sufficient to maintain the animals The road between the port and the mine site will existence would be desirable. run along the east edge of the valley for about half NNPAN also notes that there is no expected of its length. In particular during the construction impact of the mitigation measures that are phase but also in the first years of operation traffic proposed in connection with the EIA. For on the road is expected to cause disturbance of example, the significance of "disturbance of caribou in a 2-5 km zone. This disturbance has caribou in the construction phase" - without been assigned “medium” in the EIA. A “medium” mitigation is considered "medium" and the impact is defined as causing “decline/displacement significance of fact, that "construction work of a key animal (such as caribou) at local level” is to be planned so that the calving season is with local defined as 0-5 km (main report page 55- taken into account" and daily planning of the 56). If the caribou habituate to vehicle on the road, day's work of environmental employee, is as is the case in many places in Canada and Alaska, also considered "medium " the overall disturbance will be considerably less.

31.5 NNPAN notes that the planned route goes The pipeline-road corridor will run along the south- - None through one of the DCE appointed caribou eastern border of the calving area designated by calving territories and refers in this respect DCE and also marginally enter the area. A set of to BMP Field Rules, which states that there field rules to limit any disturbance will be should be special consideration in areas of developed by London Mining in cooperation with major importance for wildlife. the Greenland authorities. 239

. 31.6 NNPAN notes that Ivisaartoq is not included LM and its environmental consultant agree that DCE/GN assesses that the project will None in the study area, despite the fact that the caribou at Ivisaartoq are part of the Akia-Maniitsoq not have a direct impact on the caribou animals here are part of Akia- Maniitsoq caribou population and that animals from this area occurring in Ivisaartoq. It is evaluated population and are directly dependent on migrate into the Isua area at times. When this area that inclusion of the site in the EIA the study area, including activities in the has not been specifically mentioned in connection would not have led to a different study area. In the guidelines from BMP for with the assessment of caribou it is because the conclusion than the one presented in preparation of the EIA it is shown that the behavior of caribou from this area is believed to be the submitted. entire area affected by a project must be fundamentally the same as the animals in the Isua involved in EIA. It is therefore unclear to area. This means that the impact assessment and NNPAN why distribution of Isua project proposed mitigations for caribou in the project study area does not include the area of area will also apply to caribou at Ivisaartoq (and to distribution of the Akia- Maniitsoq stock of caribou at the Fiskefjord and Akia-Nordlandet). caribou.

31.7 NNPAN notes that the construction of The selection of the port location is addressed in DCE/GN: Nothing to add. None infrastructure through the most fertile areas 1.1 above and the comments regarding Caribou are together with the fragmentation of caribou addressed in 30.1 and 31.4. core areas could have been avoided if the project had been based on Aninganneq bay. This is shown in Figure 4-4 and 4-10. An assessment of Aninganneq alternative would be relevant proportional to reducing the negative environmental impacts of the project. In the EIA it is stated that Aninganneq at an early stage was abandoned as a result of icebergs in the fjord.

The Tailings Pond and the Retention Pond 31.8 NNPAN notes that one wants to deposit slag The recommendations from a 2003 report DCE/GN will evaluate ”amendment” Amendment from the incineration plant in the lake 750. prepared for the Greenland Home rule is when final EIA is available. to EIA NNPAN can inform that the conclusion of the observed. In the said report, the future practice in section 6.1.5 report, prepared on behalf of the handling slag and fly ash from incinerators in and 7.1.5 re. 240

Government of Greenland Possible solutions Greenland are discussed and recommendations fly ash for the handling of fly ash and slag from made. It is also noted that the recommendations 2003 states that the disposal of fly ash and are adopted by KANUKOKA, namely to separate slag should be organized separately, as there handling of slag from fly ash. is potential for leaching of contaminants, which constitute a potential risk of Furthermore, it has been noted that slag might be contamination of the environment. NNPAN used for building and construction projects also notes that the EIA does not explain how depending on a specific assessment of the slag it will handle fly ash from the incinerator. content. This is in line with the EIA report where NNPAN recommends that this is to be slag from incinerator plants is considered to be included in EIA. inert having low potential for leaching of metals and other constituents and therefore should be acceptable to deposit as part of the tailings. The option recommended in the said report of using slag as part of construction projects have been noted (e.g. used for maintenance of the access road).

The recommendation to deposit fly ash separately from slag has been noticed. Handling of fly ash will be part of the management of hazardous waste as described in the EIA (section 6.1.5 and 7.1.5). In the EIA it is stated that hazardous waste will comply with regulations and mutual agreement with Kommuneqarfik Sermersooq.

The statement will be extended to include fly ash. 31.9 NNPAN notes that the water from Tailings The water quality (WQ) in the outlet from the DCE/GN: Nothing to add. None Pond (Lake 750) and Lake 792 will run out Tailings Pond will comply with the authorities’ into the Godthåbfjord. It is noted that requirement with high confidence. Refer to monitoring will be established but that answer in 7.1 and 20.2.The WQ is expected to be mitigation measures for discharge of well below the requirements throughout the possibly contaminated water from Tailings operational period especially in the first part of the Pond is not described. operational period where the retention time is long. The water quality in the outflow is expected 241

to gradually change in the operational period as indicated in the EIA report graphs (cf. section 7.1.12). If the WQ develops unexpectedly, a number of technical mitigating measures can be introduced in time avoiding violation of the requirements, e.g. mitigating processing technique, mitigating application of reagents, changed discharge mode of tailings into the lake, or seasonally increase in retention time by means of regulating the outflow, etc. These technical measures are optional and internal tools as part of the mining operation and considered to be outside of the EIA context.

31.10 NNPAN recommend that the section on page The recommendation from NNPAN to make a full DCE/GN: Nothing to add. Full title of 207 "Greenland Water Quality Guidelines – citation of the source for the criteria will be ‘Water GWQG is explaining that the levels referred adopted i.e. the term used in the BMP Guidelines Quality to are set by the DCE and thus only for preparing EIA reports will be used namely: Guidelines’ applicable as standards for water quality and “Greenland Water Quality Guidelines in connection will be used criteria applicable for mineral resources with mining activities”. in the EIA activities. (i.e. main report and Annex 7).

31.11 NNPAN notes that "Greenland criteria for The remarks stated by NNPAN (“Greenland criteria DCE/GN: Nothing to add. None water quality" is exceeded by discharges for water quality is exceeded”) is based on a from the Retention Pond. In this context the mistake by NNPAN. EIA should clarify how the guiding values have been stipulated, and what the The criteria for water quality are ambient water consequences will be for the recipient. In quality criteria to be fulfilled after dilution in a addition, there is a lack of detection of the near field around the discharge point (zone of water exchange in the recipient is sufficient dilution) and not effluent criteria. to ensure that there will be an accumulation of toxic substance The ambient water quality criteria are determined by DCE based on a number of international eco- 242

toxicological assessments and international guidelines as explained in the EIA guideline issued by BMP (please confer the BMP – EIA guidelines, 2011 edition, page 16-19).

The practice of determining ambient water quality criteria and convert the criteria to effluent criteria using a dilution factor is an international recognized management principle in administering discharge permits and has also been used for decades in Danish administration.

These aspects have been further detailed in the reply to question no. 4 raised at the 3rd public hearing meeting.

31.12 It is argued in the EIA that waterfowl are Concentrations of residues of reagents in DCE/GN: Nothing to add. None likely to be attracted to the open water area Taseraarsuk bay influenced by water from the that will appear when warmer water from retention pond will be below levels harmful for the Retention Pond is discharged in resting water birds. Taseraarsuk. The EIA does not address whether these birds will be harmed by Fouling of water birds in oily sheens or oily staying in the bay, where the emitted residues in Taseraasuk will not take place during reagents above the acute toxic levels and normal operational procedures. Oily residues the effect of any oil film transferred to mixed in waters from the industrial areas (diesel seabirds. containment berms, maintenance shops, etc) are treated in oil/water separators. Discharge of oily water to the marine environment is not expected during normal operations. If unexpected oil release occur, the oil will be recovered from the retention pond or alternatively in the Taseraasuk Bay as part of the contingency plan. If flocks of birds occur under a spill, mitigating measures will be taken to frighten them away. This measure will be part of the contingency plan. 243

31.13 Assessment of discharges from Retention Effluents are regulated by the authorities through DCE/GN will assess question when final Order of the Pond should take into account the effect identification of ambient water quality EIA is available. magnitude of the total quantity of discharged concentrations and a transition zone. Based hereof estimates of substances rather than merely focusing on the effluent criteria concentrations are stipulated mass the inferred concentration. Thus, there (confer response above and reply no. 4 from 3rd transport to should be accounted for whether the public hearing meeting). The EIA approach is be included emitted substances can be expected to complying with the authorities’ requirements. in the EIA degrade in the marine environment, or Annex 7 and whether the substances will sediment or bio- Only degradable reagents without bio- the main accumulate. Moreover, one should carry out accumulating properties will be approved by the EIA. an assessment of the impact on total authorities according to response no. 4 to emissions over the mine life expectancy. questions raised at the 3rd public meeting.

Estimates of mass transport of water, suspended material and metals from the retention pond can be estimated and compared with natural mass transport from catchment areas to the Godthaabs Fjord.

Using available data sources from the catchment area of Kugssua River, the following order of magnitude estimates can be derived. Copper (Cu) is used as example for metal transport. Other metals can be estimated although the overall conclusion is the same as stated below.

The estimate does not pretend to be of high accuracy, however, the estimates are considered sufficient for order of magnitude comparisons.

Outlet of filtrate Outflow Kugssua from Retention River to Pond to Godthaabsfjord Godthaabs fjord (Ilulialik part) (Qugssuk part)

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Water quantity 7.4 mio. m3/yr 7000 mio. m3/yr per year Total Suspended 10 - 15 mg/l* 150 mg/l** Solids (TSS) (average under (range up to 520 concentrations normal operation, mg/l) range up to 50 mg/l ) Mass transport of 100 tons/yr 1,000,000 tons/yr suspended solids per year Concentration of 2.9 μg/l* 1.4 μg/l** Cu (dissolved) Concentration of 26 μg/l* 11 μg/l** Cu (total / unfiltered) Mass transport of 20 kg/yr 10000 kg/yr Cu per year (dissolved–filter) Mass transport of 0.2 t/yr 75 t/yr Cu per year (total- unfiltered) Data source: * EIA, Annex 8, SGS Laboratory ageing test, average of 3,7,14,28 days. ** EIA, Annex 7, Field measurements in May and August 2011, outflow of Taserâssuk into Kugssua River.

The figures indicate that the natural mass transport (water and suspended solids) to Godthaabsfjord from the Kugssua catchment area (comprising a minor part of the total run off area to Godthaabsfjord only) are 3 - 4 orders of magnitude larger than the expected mass transport from the retention pond (i.e. a factor of 1000 – 10000).

The mass transport of metals from the retention pond is likewise insignificant compared to the natural transport from the Kuggsua River.

Taken into consideration that the total run off to Godthaabsfjorden is several times larger than the Kuggsua River part, it underpins the conclusion

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that the load from the retention pond is insignificant.

The above reflections will be included in the EIA. Dust and air pollution 31.14 NNPAN agrees with the remarks on use of Comment on hydropower has been detailed DCE/GN: See answernumber 5.1. None diesel plants rather than hydropower by the previously (cf. response no. 5.1) Climate and Energy Office. From the precautionary principle and exposition in the EIA on the goal of applying BAT and BEP NNPAN finds it relevant that one uses hydroelectric power rather than diesel power plant. 31.15 The EIA sets out a series of standards for US EPA emission standards for non-road diesel DCE/GN: Nothing to add. None dust and air pollution (EPA standard, IFC engines, for mine equipment and haul trucks, are standard and EU standard). As it in the EIA is slightly stricter than EU standards. The US EPA Tier pointed out that there will be use BEP and 4 standards (2014) for engines 130 to 560 kW are BAT NNPAN recommend the use of the essentially identical to EU Stage IV standards, but highest standards of preventive measures slightly stricter for PM: 0.02 g/kWh vs. 0.025 in the against dust and air pollution. NNPAN can EU standard. EPA has standards for engines > 560 state, that the standard practices according kW but EU does not. to the Environmental Protection Act is a requirement that diesel power plants EU ambient air quality standards are used in comply with the Danish limits. This also dispersion modelling since they apply throughout applies to emergency generators in cities. Europe. Danish C-values for ambient concentrations are normally applied in dispersion modeling using the OML model. OML could not be used due to the complex terrain. The AERMOD model used does not provide the exact statistic required for evaluation of compliance with C- values, so only the EU ambient limit values could be tested for compliance.

World Bank/IFC emission standards for diesel power plants are referenced since the EU Large 246

Combustion Plant Directive does not apply to diesel engines. Emission limit values in Miljøstyrelsen’s Guidelines for Air Emissions (2001) do not apply to large diesel engines. Danish emission standards in Departmental Order no. 621

of 23/06/2005 could apply, giving a lower NOX emission limit value. The air pollution dispersion

modelling assumes World Bank NOX emissions, which makes the dispersion results for NO2 more conservative. The area of NO2 exceedance would be smaller if the Danish emission standards had been used when calculating power plant emissions. 31.16 NNPAN notes that the 105 km long road will The 105 km access road between the port and the DCE/GN will recommend that dust None be a dirt road and lacks a description of mine processing plan will be an unpaved road dispersion along the road is monitored mitigation measures in relation to dust constructed with sand, gravel materials excavated in order to assess possible needs for problems, particularly with special reference from borrows sites and rocks. The road action, if there are indications of to the fact that one will run in convoys. construction will not differ from usual road problems. construction of unpaved roads and there is no environmental concerns related to the material composition.

The traffic on the road is estimated to an average of 76 passages per day (EIA, Annex 5) with a speed of max 50 km/h in summer and max. 35 km/h in winter time. Most of the passages will be vehicles in convoys. Dust from this limited number of traffic will not generate dust in large amount; will not be of environmental concern in the vicinity of the road and the issue will not differ from other unpaved roads constructed in Greenland or elsewhere in other Artic regions with limited traffic. In addition, dust generation during the winter months, which can be up to 6- 8 months along the access road, is very limited. 247

“DCE/GN recommendation to monitor dust along the access road is noted. Furthermore, the best international practices for dust control for mining roads will be implemented under the Isua project. While dusting from the access road and haul roads is not an issue during winter time as the surface forms a freezing snow and sand zone, proven techniques will be applied during dry periods. These include various options such as water spray along sensitive portions of the access roads and/or use of dust suppressants which are mixed with water and applied topically to dirt haul roads or unpaved roads. Dust suppressants that are selected and used in the mining industry are environmentally friendly and approved by environmental authorities.

31.17 Decommissioning Plan

NNPAN note that the open mine pit may be A preliminary closure plan has been prepared as DCE/GN: Nothing to add. None left as it is when the project is completed part of the EIA. The closure plan is further and activity areas shut down. NNPAN developed as required by the Application on considers it appropriate that the closure plan Section 19 and 43 of the Mineral Resources Act. is elaborated. The point about the slow regeneration of arctic According to article Long-term recovery vegetation is noted. patterns of arctic tundra after winter seismic exploration, 2010, arctic flora, and tundra takes long time to regenerate. This should be taken into consideration in connection with the closure plan. 31.18 Ballast Water Convention

NNPAN finds it positive that the Ballast Comment is a matter for the Government of BMP: Noted. None 248

Water Convention will be used despite the Greenland. fact that it has not yet been ratified and DCE/GN: Nothing to add. implemented in Greenland.

Notes to Annex 31.19 Appendix 3 NNPAN notes that Atlantic halibut are not Orbicon has in connection with the baseline survey DCE/GN: Nothing to add. treated in the Annex section on fish. It must in 2010 recorded Atlantic halibut in Godthåbsfjord be assumed that Atlantic halibut, foraging in (but not from Qussuk). This fish species is not shallow water, including in Qussuq are likely discussed in Annex 3 (or elsewhere in the EIA) to be affected by the discharge. NNPAN find because focus here is on the key species in that discharges influence of halibut and connection with commercial and subsistence other species should be examined in the EIA. fishery. The discharges from the project into Qussuq comprise water from the sewage plant and the retention pond. The retention pond will be built to the highest standard and water discharged into the fjord from the plant will not have an impact on fish (or the marine environment in general). Similarly has simulations and analyzed been carried out that show that water from the retention pond will not have any impact on the marine environment outside the Taseraarsuk creek. 31.20 Annex 10 On page 13 it says Niaqornarsuaq Bay which Noted and will be corrected. DCE/GN: Nothing to add. Niaqornarsu must be Taseraarsuk Bay. aq Bay is substituted NNPAN notes that on page 17 it is not It is correct that the falcon nest is not mentioned. by mentioned that there may be found falcon But it should be noted that the description of birds Taseraarsuk nests within the project area as indicated in in Annex 10 is just a summary and that reference is Bay in Annex the EIA in particular on page 156. made to Annex 1 for details. 10 page 13.

NNPAN recommends that there in the The areas identified as very old geological section Potential identified impact on socio formations and noted by NNPAN (according to the economic environment is a description of maps attached the hearing reply) is not in conflict 249 the Isua rocks and the importance the areas with area affected by the open pit mining i.e. the set out in Annex 1 have on science iron ore exploitation. Therefore, commenting these issues under ‘socio-economic’ environment will not add any information to the EIA.

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32. Peter Barfod

No. Question Response from London Mining Response from BMP and/or DCE/GN Amendment to EIA/SIA 32.1

Hydropower MUST be utilized. Anything else Comment on hydropower is adressed previously - None is completely unacceptable. This is aiming at (cf. response no. 5.1). establishing a coherent electricity grid system along the coast. And then in order to utilize clean renewable energy. As in Norway. In a way, London Mining is the cause and the responsible part if there are problems with the timing. Up to the public meeting in autumn 2011 it appears on London Mining homepage that the project was based on hydropower!

32.2 The mining method is decided by the overall - None Underground mining must be utilized. As in evaluations of the project feasibility based on the Kiruna. Provides less dust and better ore and conditions for its mining. Also, it is an occupational health environment. unsubstantiated assertion that underground mining creates less dust and better occupational health.

The structure and formation of the Isua iron ore deposit makes open pit mining the most attractive and feasible method.

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32.3 - None Olivine deposit at the Fiskefjorden must be London Mining produces iron concentrate of used to pellerts production, such as the premium-quality blast furnace grade pellet feed. Cryolite company originally planned. These Pelletizing in Greenland is not an feasible option. added value activities should be introduced in Greenland. Anything else is looting.

Two years ago one got the right to the mineral rights, so one should not just give it away.

32.4 Instead of slurry‐pipe lines a conveyor The alternative of using a 105 km long conveyor - None system (Doppelmayr) should be utilized. system in a harsh arctic climate is not justified Alternatively and even better, electric trains based on technical, environmental or economical as in Kiruna should be used. There is almost considerations compared to a slurry pipeline. energy balance. The argument of using train as large energy Transport down with filled ore-train creates provider is not viable. so much electricity, that transport up is next to free. Waterborne ore freezes. This is The pipeline design has taken the cold known in Kiruna, therefore they have temperature into consideration. The pipeline is established a large underground ore loading thermally insulated and the slurry will not be facilities in Narvik. The so-called Silas frozen over the time when it is transported from project. the process plant to the dewatering plant.

32.5 Co-ordinated transport with e.g. Alcoa ISUA and Alcoa are two different privately owned None should take place, so that ballast water is projects. Each has a different project objectives, avoided. shipping location and project schedule. The idea is beyond any realism in the current condition.

32.6 This is a matter for Greenland Government. BMP: Requirements related to heavy None 252

Heavy fuel oil by shipping should totally be fuel will be set in the government prohibited. This applies all vessels. At the Please also confer reply no 12.5, 13.11 and 16.5. approvals. wharf shall be connected to electricity ashore.

32.7

If the Alcoa‐project is realized at all it must Comment is a matter for the Government of BMP: Noted. None be placed in Nuuk. Following recent Greenland. announcements they should have the fuck finger and Hydro on track again!

32.8 Comment is a matter for the Government of BMP: Noted. None 8. Hydropower to London mining and Alcoa Greenland. should be run by an independent company which is independent of the two companies.

It could be DONG, Statkraft or Vattenfall. Possibly in a joint company. The Cryolite company was originally the Danish State. They operated with hydropower. There should be no obstacles for the state to come back on track again!

32.9 The above viewpoints are assumed to be the key None The content of the two newspaper articles is comments to be included in the hearing process. maintained in its entirety. Please confirm The content of the articles have not been reception of hearing response. considered in details.

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33. Grønlands Politi

No. Question Response from London Mining Response from BMP and/or DCE/GN Amendment to EIA/SIA 33.1 BMP has, through the hearing portal on At the scoping workshop a proposed list of - None vww.nanoq.gl published the "EIA" and the stakeholder were present to the invited selected SIA" of London Mining iron mining project stakeholder. The invited stakeholders were agreed near Nuuk for public consultation. The end with BMP. of the consultation period was set to 19 October 2012.

By mail of the 19th October 2012 I At the workshop it was asked if additional announced to BMP that Greenland Police stakeholders should be included into the SIA had not received the reports for process. At that meeting Greenland’s Police was consultation. Thus, BMP informed me on, 23 not mentioned. October 2012, that BMP looks forward to receiving the responses from Greenland police within 14 days as also proposed by

me.

I hereby submit my comments on the two assessments. I must emphasize that my comments are limited to the issues I believe are relevant on the impacts on the environment and social impacts. Allow me, in this context, to assume that Greenland's Police will be involved in the ongoing process on other aspects of the project that

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may interface with police responsibility.

33.2 Impacts on the Environment In the EIA report section 7.4.3 on pollution of marine habitats a cross-reference is The correct cross-reference is section 6.2.3 of the - Correction mentioned to section 6.2.8, where the main EIA report (and not section 6.2.8). of the cross- potential contamination of Godthåbsfjorden reference are discussed. In this context, I have not will be been able to identify section 6.2.8. included in the EIA. 33.3 According to Act of Inatsisartut No. 14 of 26 A detailed Environmental Management Plan (EMP) - None May 2010 (Emergency Management Act) § will be in place prior to the construction phase and 13 paragraph. 1, the overall combat effort of will be revised throughout the project period as accidents and disasters is to be coordinated appropriate. The EMP will comprise a by the police. In this regard I have with comprehensive Emergency Response Plan. This is satisfaction noted that the EIA states that spelled out in the EIA (e.g. section 9). there must be contingency plans for environmental emergencies in place (e.g. Chapter 9.1 and 9.3). However, I do not find in the assessment or in the appendices The Annex 10 of the EIA is a preliminary (particularly Annex 10) more detailed framework for the Environmental Management description of the contingency plans. Based Plan. The preliminary framework will be further on Annex 10, Chapter 9, a draft contingency elaborated immediately after commencement of plan exists in the Appendix D, which simply the project assuming the project is approved by refers to a separate file. This file is not published or sent to me. the Greenland Government and financing is in place.

In this context, I request that draft The central role of the Greenland Police in contingency plans shall be submitted for emergency planning is acknowledged and likewise consultation to Greenland Police, and the kindly offer to act as advisor in this respect. likewise the Greenland Police would be 255

pleased to participate as an advisor during Greenland Police will be involved in planning and the process in elaborating the plan. discussing the emergency response plans throughout the process. Finally, I request that the final plans will be made available in well before the start of the The viewpoints of having the emergency plans in project enabling all stakeholders to place and as well as sufficient time for considering familiarize themselves with the plans and adequate rehearsal exercises before the takeoff of consider exercise activity, etc. the activities are acknowledged.

33.4 Social Impact Assessment

The assessment does not include an analysis Comments are noted. - None in relation to the number of police core tasks related to the project. It is in this context, an incomplete assessment without an analysis of these issues. Allow me to recommend that such an analysis is prepared as a supplement to the assessment. Below are a number of issues which I believe should be included.

33.5 Chapter 1.3 and 9:

From the chapters is shown which To be taken into account - None authorities and organizations etc, there has been consulted during the SIA process. From this it is shown that the Greenland Police has not been involved. Moreover, it appears that not even the Greenland Command (per 31 October 2012 Arctic Command) has been involved. Since Greenland Command is a

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major player in particular areas for sea rescue, maritime safety and pollution control, allow me to suggest that the command involved.

33.6 Chapter 2.1: Citizens of From the chapter is stated that the citizens Greenland of Greenland " has a Danish passport, which To be taken into account - have Danish automatically gives them the same rights as nationality Danish citizens". This is after my view, not a which is correct description, as citizens of Greenland similar to are Danish nationals in exactly the same other conditions as nationals of the other parts of nationals of the kingdom and thus obviously has a Danish the Danish passport. Kingdom and thus they will have a Danish passport. 33.7 Chapter 2.2.1:

From the chapter is shown a list of the main To be taken into account - Law to be laws that applies for the project. In my added opinion, lnatsisartutlov No. 14 of 26 May 2010 (Emergency Management Act) § 13 paragraph could usefully be mentioned in this context.

33.8 Chapter 5.3: A description From the chapter is shown a description of To be taken into account. - of the the authorities of the Self-Government and imperial authorities 257

municipalities. In this context is missing in as the my view a description of the imperial Labour authorities, who are important stakeholders Inspection, Greenland in the project. For example, the Labour Command, Inspection, Greenland Command, Danish Danish Maritime Authority, Greenland Justice and Maritime Police. Authority, Greenland Justice and Police will be included in the SIA. 33.9 Chapter 5.7.3.4:

The chapter is, in my opinion inaccurate and contains several factual errors. The chapter includes a very brief description of Comment taken into account. - A revised Greenland Police. The description is not version of correct, since the police district is divided the chapter into 4 police regions, each with a main police will be sent station and a number of local police stations. for The chapter also describes that in 2014 in comment to Nuuk will open a closed prison. This date is not correct. I will in this context, allow to the Police suggest that there the Probation in before Greenland will be addressed for a correct included in description of the probation conditions. In the final SIA addition, the chapter "Greenland Supreme Court" that rightfully should be reported as'' High Court of Greenland ", the Supreme Court is one for the whole of unified court located in Copenhagen. Finally, the chapter describes crime in Greenland. Section contains several errors, so I shall suggest 258

that it undergo a quality control. Greenland Police participates would be happy to assist in this work.

33.10 Chapter 6.3:

The chapter describes the impacts on the public services during the construction and Comments noted. and should add an section in - A section to operational phases. It is below described the report be added to that there will be an increased workload for the SIA immigration authorities regarding the Report processing of work and residence permits. I agree to this assessment. In the same regard, I recommend that the assessment should be extended to include resource use for in and out travel controls during the construction and operational phases.

33.11 Chapter 6.4:

This chapter describes the social aspects of Comment taken into account - This will be the project. I have in this relation found that included in the risk of crime is not covered by the the SIA assessment. I must in this connection very much urge to make an assessment of the Report. project's impact on crime for both the crime act and the special acts, which is relevant for the project. As examples of this is the risk of violence, property crimes, violations of environmental, hunting and nature conservation rules violations of the working condition acts and the import and use of illegal substances.

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33.12 Other: In the SIA is not an assessment of the rescue ability of authorities to carry out initiatives Comment taken into account. - A section to under construction and operational phase in be added to mine area with the associated land and on the SIA vessels going to and from the area. I take the Report liberty to recommend that such an assessment should be made.

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34. DCE/GN comments to the EIA for the ISUA project

No. Question Response from London Mining Response from BMP and/or DCE/GN Amendment to EIA/SIA

34.1 DCE/GINR notes that on the background of No respond required - None the forwarded comments will London Mining carry out eco-toxicological tests of water from the pipeline and tailings. London Mining will develop a test protocol. It should be noted that the water must be representative and include realistic maximum concentrations of reagents and metals.

34.2 DCE/GINR notes that London Mining in a No respond required - None new note has explained the composition of drainage water from the area where waste rock will be deposited.

34.3 DCE/GINR notes that London Mining has No respond required - None explained in a satisfactory way the number of samples for which geological and chemical tests has been carried out as well as their representativeness.

34.4 DCE/GINR notes that London Mining has No respond required - None changed the wording in the EIA regarding shipping to Nuuk and in the Godthåbsfjord. It should be noted that shipping in the

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Godthåbsfjord will increase significantly. 34.5 DCE/GINR notes that London Mining has No respond required - None modified the wording in the EIA and has prepared a supplementary note on emissions of SO2, NOx, sod and greenhouse gasses. It should be noted that the emissions are significant compared to other emissions in Greenland. 34.6 DCE/GINR has noted that London Mining has No respond required - None addressed the risk of possible oil spills. It should be noted that London Mining indicate that they will follow international and national regulations but that London Mining will not voluntarily introduce that ships calling in at the project port must not use heavy oil. 34.7 DCE/GINR notes that London Mining based No respond required - None on DCE/GINR’s comments has expanded the description of the Godthåbsfjord included the section on the occurrence of whales in Godthåbsfjord and have addressed the potential impact on wildlife. 34.8 DCE/GINR notes that London Mining based No respond required - None on comments from DCE/GINR has moved the outlet of wastewater from Niaqornarssuaq bay to Taseraarssuk. It should be noted that Taseraarssuk already will be impacted by the port and the associated shipping. 34.9 DCE/GINR notes that the description of the No respond required - None marine fjord-system in the main EIA report has been modified to include the references Orbicon has been provided with and that these references have been included in the document. As far as DCE/GINR can assess 262

there has not been carried out specific surveys and the composition of species belonging to the benthic fauna. Reference is made to video takes but this does not necessarily provide information on the benthic species that occur at Qussuq and Taseraasuk.

34.10 DCE/GINR notes that London Mining has No respond required - None expanded the description of the contents of some of the reagents that are planned to be used in the various processes. It should be noted, however, that the information of the content of reagents/chemicals is still not complete. London Mining has expressed that detailed information on the content of reagents/chemicals will be required from the producers/suppliers before an agreement will be made with producers/suppliers 34.11 DCE/GINR notes that London Mining agrees No respond required - None that limits should be defined for the contents of reagents/chemicals in processwater and wastewater and that on-line monitoring should be established that provides on-going information on the contents in processwater and wastewater. In addition, any the potentially harmful substances to the environment in reagents/chemicals must be substituted. It should be noted that it can be necessary to purify the processwater and wastewater including the water discharged from the 263

retenstionspond.

34.12 DCE/GINR notes that London Mining has No respond required - None clarified a number of questions regarding the retentions pond, including the contents of suspended material. 34.13 DCE/GINR notes that London Mining does No respond required - None not expect that the discharge to the marine environment will lead to a coloration of the fjord or that flocculation will take place when wastewater mixes with salt water in the fjord.

34.14 DCE/GINR notes that London Mining will No respond required - None continue to establish the background levels of metals, nutritiens etc. in freshwater after the permission has been granted and during the construction phase. 34.15 DCE/GINR notes that BMP has explained No respond required - None that London Mining intent to continue to study the option of constructing a hydropower plant as part of the project. 34.16 DCE/GINR notes that London Mining agrees No respond required - None that a study is carried out of the vegetation and occurance of rare plant species along the remaining section of the road corridor and the designated borrow sites where materials will be extracted fro roads, bridges etc. 34.17 DCE/GINR notes that London Mining agrees No respond required - None that the (location of ) facilities and construction works should be considered on the basis of (the distribution of) the

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vegetation and rare plant species.

34.18 DCE/GINR notes that London Mining in the No respond required - None EIA has changed definition regarding vegetation and plants. 34.19 DCE/GINR notes that London Mining No respond required - None adequately has modified the description of the utilisation of the area by caribou and has re-assessed how big an area that will be impacted by the project. 34.20 DCE/GINR notes that London Mining will No respond required - None ensure that monitoring on the projects impact on caribou will be carried out. 34.21 DCE/GINR notes that London Mining has No respond required - None prepared a supplementary note regarding underwater noise and the risk of collisions with whales and that the EIA has been corrected regarding the number of ships. It should be noted that the note is general and that the noise assessment is a rough estimate. The increase in shipping and noise from shipping will in parts of Godthåbsfjord increase significantly, in particular from the large ships that are part of the project. It is the opinion of DCE/GINR that detailed noise measurements should be carried as well as monitoring of whales in the Godthåbsfjord before shipping starts in order to determine the baseline levels. Noise measurements and noise modelling will be important tools in connection with the development of a monitoring program of potential impacts from the project on whales and other marine mammals in the Godthåbsfjord. 265

34.22 DCE/GINR notes that London Mining has No respond required - None provided additional information regarding the 400 tonnes of dust which can be dispersed in connection with the loading of iron concentrate to the ships. In the reply London Mining has explained that the 400 tonnes per year is a maximum value and that the dust control measures that will be imposed will reduce the amount of dust that will be dispersed to the environment. It should be noted that the dust deposition can be considerable in the port area and that the impact of the dust and its contents is unknown. Monitoring of dust and its content should be part of the monitoring program. 34.23 DCE/GN notes that London Mining has No respond required - None responded on DCE/GINR comments regarding implementation of EU-thresholds for effects of NO2 and SO2 on vegetation and Arctic plants. 34.24 DCE/GINR notes that London Mining in the No respond required - None planning and implementation of the construction works will take potential problems with erosion into account. 34.25 DCE/GINR notes that London Mining has no No respond required - None comments to the letter from DCE/GINR dated 15 June 2011 with comments regarding monitoring principles and the development of a monitoring program. The criteria for the monitoring carried out by the mine companies will be agreed in connection with the finalization of the exploitation licence. BMP in cooperation with DCE/GINR will carry out continuous 266 monitoring of the terrestrial and aquatic environment.

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