KITSAULT MINE PROJECT ENVIRONMENTAL ASSESSMENT

Section 6.7 Freshwater Aquatic Resources

VE51988

KITSAULT MINE PROJECT ENVIRONMENTAL ASSESSMENT FRESHWATER AQUATIC RESOURCES

TABLE OF CONTENTS

6.7 Freshwater Aquatic Resources ...... 6.7-1 6.7.1 Valued Component Selection Rationale...... 6.7-2 6.7.1.1 Valued Component / Issue Identification and Scoping ...... 6.7-3 6.7.1.2 Valued Component / Issues Confirmation ...... 6.7-24 6.7.2 Dolly Varden ...... 6.7-29 6.7.2.1 Introduction ...... 6.7-29 6.7.2.2 Relevant Legislation and Legal Framework ...... 6.7-29 6.7.2.2.1 Federal ...... 6.7-29 6.7.2.2.2 Provincial ...... 6.7-30 6.7.2.2.3 Nisga’a Lisims Government ...... 6.7-31 6.7.2.3 Spatial Boundaries ...... 6.7-31 6.7.2.3.1 Local Study Area ...... 6.7-32 6.7.2.3.2 Regional Study Area ...... 6.7-34 6.7.2.3.3 Cumulative Effects Study Area...... 6.7-34 6.7.2.4 Temporal Boundaries ...... 6.7-38 6.7.2.5 Information Source and Methods ...... 6.7-38 6.7.2.5.1 Field Studies ...... 6.7-38 6.7.2.5.2 Regional Baseline ...... 6.7-41 6.7.2.6 Detailed Baseline for Dolly Varden ...... 6.7-41 6.7.2.6.1 Genetics ...... 6.7-41 6.7.2.6.2 Distribution and Catch-Per-Unit-Effort ...... 6.7-41 6.7.2.6.3 Length, Weight, and Condition ...... 6.7-44 6.7.2.6.4 Age, Growth, and Maturity ...... 6.7-46 6.7.2.6.5 Diet ...... 6.7-50 6.7.2.6.6 Energy Storage and Energy Use ...... 6.7-53 6.7.2.6.7 Life History...... 6.7-56 6.7.2.6.8 Tissue Residual Metals ...... 6.7-56 6.7.2.7 Cultural, Ecological or Community Knowledge ...... 6.7-61 6.7.2.8 Past, Present or Future Projects / Activities ...... 6.7-62 6.7.2.9 Potential Effects of the Proposed Project and Proposed Mitigation ...... 6.7-69 6.7.2.9.1 Identification and Analysis of Potential Project Effects ...... 6.7-69 6.7.2.9.2 Mitigation Measures ...... 6.7-83 6.7.2.10 Potential Residual Effects and their Significance ...... 6.7-128 6.7.2.10.1 Potential Residual Effects after Mitigation ...... 6.7-128 6.7.2.10.2 Change in Stream Flows in Lime Creek ...... 6.7-160 6.7.2.10.3 Change in Water Temperatures in Lime Creek ...... 6.7-172 6.7.2.10.4 Change in Benthic Macro-Invertebrate Community in Lime Creek ...... 6.7-175 6.7.2.10.5 Summary of Potential Residual Effects after Mitigation ...... 6.7-176 6.7.2.10.6 Significance of Potential Residual Effects ...... 6.7-176 6.7.2.11 Cumulative Effects Assessment ...... 6.7-179 6.7.2.11.1 Rationalisation for Carrying Forward Project Related Residual Effects Into the Cumulative Effects Assessment ...... 6.7-179 6.7.2.11.2 Interaction Between Dolly Varden and Other Past, Present or Future Projects / Activities ... 6.7-180 6.7.2.11.3 Mitigation Measures ...... 6.7-185

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6.7.2.11.4 Potential Residual Cumulative Effects and Their Significance ...... 6.7-185 6.7.2.12 Limitations ...... 6.7-188 6.7.2.13 Conclusion ...... 6.7-189 6.7.3 Coho salmon ...... 6.7-190 6.7.3.1 Introduction ...... 6.7-190 6.7.3.2 Relevant Legislation and Legal Framework ...... 6.7-191 6.7.3.2.1 Federal ...... 6.7-191 6.7.3.2.2 Provincial ...... 6.7-193 6.7.3.2.3 Nisga’a Lisims Government ...... 6.7-193 6.7.3.3 Spatial Boundaries ...... 6.7-193 6.7.3.3.1 Local Study Area ...... 6.7-193 6.7.3.3.2 Regional Study Area ...... 6.7-194 6.7.3.3.3 Cumulative Effects Study Area...... 6.7-194 6.7.3.4 Temporal Boundaries ...... 6.7-195 6.7.3.5 Information Source and Methods ...... 6.7-195 6.7.3.5.1 Field Studies ...... 6.7-195 6.7.3.5.2 Regional Baseline ...... 6.7-196 6.7.3.6 Detailed Baseline for Coho Salmon ...... 6.7-197 6.7.3.6.1 Distribution and Catch ...... 6.7-197 6.7.3.6.2 Length, Weight, and Condition ...... 6.7-197 6.7.3.6.3 Life History...... 6.7-198 6.7.3.6.4 Diet ...... 6.7-199 6.7.3.6.5 Habitat ...... 6.7-199 6.7.3.7 Cultural Ecological or Community Knowledge ...... 6.7-199 6.7.3.7.1 Nisga’a Nation ...... 6.7-199 6.7.3.7.2 Aboriginal Groups ...... 6.7-200 6.7.3.8 Past, Present or Future Projects / Activities ...... 6.7-201 6.7.3.9 Potential Effects of the Proposed Project and Proposed Mitigation ...... 6.7-207 6.7.3.9.1 Identification and Analysis of Potential Project Effects ...... 6.7-207 6.7.3.9.2 Mitigation Measures ...... 6.7-219 6.7.3.10 Potential Residual Effects and Their Significance ...... 6.7-231 6.7.3.10.1 Potential Residual Effects After Mitigation ..... 6.7-231 6.7.3.10.2 Significance of Potential Residual Effects ...... 6.7-237 6.7.3.11 Cumulative Effects Assessment ...... 6.7-240 6.7.3.11.1 Rationalisation for Carrying Forward Project Related Residual Effects Into the Cumulative Effects Assessment ...... 6.7-240 6.7.3.11.2 Interaction Between Coho Salmon and Other Past, Present or Future Projects / Activities ...... 6.7-240 6.7.3.11.3 Mitigation Measures ...... 6.7-244 6.7.3.11.4 Potential Residual Cumulative Effects and Their Significance ...... 6.7-245 6.7.3.12 Limitations ...... 6.7-245 6.7.3.13 Conclusion ...... 6.7-247 6.7.4 Rainbow Trout ...... 6.7-247 6.7.4.1 Introduction ...... 6.7-247 6.7.4.2 Relevant Legislation and Legal Framework ...... 6.7-248 6.7.4.2.1 Federal ...... 6.7-248 6.7.4.2.2 Provincial ...... 6.7-249 6.7.4.2.3 Nisga’a Lisims Government ...... 6.7-250

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6.7.4.3 Spatial Boundaries ...... 6.7-250 6.7.4.3.1 Local Study Area ...... 6.7-251 6.7.4.3.2 Regional Study Area ...... 6.7-253 6.7.4.3.3 Cumulative Effects Study Area...... 6.7-253 6.7.4.4 Temporal Boundaries ...... 6.7-253 6.7.4.5 Information Source and Methods ...... 6.7-254 6.7.4.5.1 2010 Field studies ...... 6.7-254 6.7.4.5.2 2011 Field Studies ...... 6.7-256 6.7.4.6 Detailed Baseline for Rainbow trout ...... 6.7-259 6.7.4.6.1 Species Composition and Relative Abundance ...... 6.7-259 6.7.4.6.2 Catch Per-Unit-Effort in Lakes...... 6.7-259 6.7.4.6.3 Length, Weight, and Condition ...... 6.7-260 6.7.4.6.4 Age, Growth, and Maturity ...... 6.7-262 6.7.4.6.5 Diet ...... 6.7-265 6.7.4.6.6 Tissue Metal Residues ...... 6.7-266 6.7.4.6.7 Lake 901 Inlet Tributaries ...... 6.7-268 6.7.4.7 Cultural Ecological or Community Knowledge ...... 6.7-274 6.7.4.8 Past, Present or Future Projects / Activities ...... 6.7-274 6.7.4.9 Potential Effects of the Proposed Project and Proposed Mitigation ...... 6.7-279 6.7.4.9.1 Identification and Analysis of Potential Project Effects ...... 6.7-279 6.7.4.9.2 Mitigation Measures ...... 6.7-292 6.7.4.10 Potential Residual Effects and their Significance ...... 6.7-320 6.7.4.10.1 Potential Residual Effects after Mitigation ...... 6.7-320 6.7.4.10.2 Significance of Potential Residual Effects ...... 6.7-382 6.7.4.11 Cumulative Effects Assessment ...... 6.7-393 6.7.4.11.1 Rationalisation for Carrying Forward Project Related Residual Effects Into the Cumulative Effects Assessment ...... 6.7-393 6.7.4.11.2 Interaction Between Rainbow trout and Other Past, Present or Future Projects / Activities ... 6.7-395 6.7.4.11.3 Mitigation Measures ...... 6.7-400 6.7.4.11.4 Potential Residual Cumulative Effects and Their Significance ...... 6.7-401 6.7.4.12 Limitations ...... 6.7-402 6.7.4.13 Conclusion ...... 6.7-403 6.7.5 Benthic Macro-Invertebrates ...... 6.7-404 6.7.5.1 Introduction ...... 6.7-404 6.7.5.2 Relevant Legislation and Legal Framework ...... 6.7-405 6.7.5.2.1 Federal ...... 6.7-405 6.7.5.2.2 Provincial ...... 6.7-406 6.7.5.2.3 Nisga’a Lisims Government ...... 6.7-406 6.7.5.3 Spatial Boundaries ...... 6.7-406 6.7.5.3.1 Local Study Area ...... 6.7-406 6.7.5.3.2 Regional Study Area ...... 6.7-409 6.7.5.3.3 Cumulative Effects Study Area...... 6.7-409 6.7.5.4 Temporal Boundaries ...... 6.7-409 6.7.5.5 Information Source and Methods ...... 6.7-410 6.7.5.5.1 BMI Field Methods in 2009 ...... 6.7-410 6.7.5.5.2 BMI Field Methods in 2010 ...... 6.7-411 6.7.5.5.3 Fish Diet Analysis in 2009 and 2010 ...... 6.7-411 6.7.5.5.4 Laboratory Methods and Data Analysis ...... 6.7-412

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6.7.5.6 Detailed Baseline for Benthic Macro-Invertebrates ...... 6.7-412 6.7.5.6.1 Density and Relative Abundance in Streams . 6.7-412 6.7.5.6.2 Richness and Diversity Indices for Streams ... 6.7-414 6.7.5.6.3 Density and Relative Abundance in Lakes ..... 6.7-415 6.7.5.6.4 Richness and Diversity Indices for Lakes ...... 6.7-415 6.7.5.6.5 BMI Composition in Fish Diets ...... 6.7-416 6.7.5.7 Cultural Ecological or Community Knowledge ...... 6.7-417 6.7.5.8 Past, Present or Future Projects / Activities ...... 6.7-418 6.7.5.9 Potential Effects of the Proposed Project and Proposed Mitigation ...... 6.7-421 6.7.5.9.1 Identification and Analysis of Potential Project Effects ...... 6.7-421 6.7.5.9.2 Mitigation Measures ...... 6.7-432 6.7.5.10 Potential Residual Effects and Their Significance ...... 6.7-462 6.7.5.10.1 Potential Residual Effects after Mitigation ...... 6.7-462 6.7.5.10.2 Significance of Potential Residual Effects ...... 6.7-483 6.7.5.11 Cumulative Effects Assessment ...... 6.7-485 6.7.5.11.1 Rationalisation for Carrying Forward Project Related Residual Effects Into the Cumulative Effects Assessment ...... 6.7-485 6.7.5.11.2 Interaction Between Benthic Macro- Invertebrates and Other Past, Present or Future Projects / Activities ...... 6.7-487 6.7.5.11.3 Mitigation Measures ...... 6.7-489 6.7.5.11.4 Potential Residual Cumulative Effects and Their Significance ...... 6.7-490 6.7.5.12 Limitations ...... 6.7-494 6.7.5.13 Conclusion ...... 6.7-495

List of Tables Table 6.7.1-1: Issues Raised or Identified for Freshwater Aquatic Resources by the Nisga’a Nation, Aboriginal Groups, the Public, and Federal and Provincial Regulators During Pre-Application Consultations ...... 6.7-4 Table 6.7.1-2: Valued Component / Issue Interaction Matrix for Freshwater Aquatic Resources ...... 6.7-9 Table 6.7.1-3: Potential Issues by Project Component for Freshwater Aquatic Resources – Construction Phase ...... 6.7-12 Table 6.7.1-4: Potential Issues by Project Component for Freshwater Aquatic Resources – Operations Phase ...... 6.7-15 Table 6.7.1-5: Potential Issues by Project Component for Freshwater Aquatic Resources – Closure and Decommissioning Phase ...... 6.7-19 Table 6.7.1-6: Potential Issues by Project Component for Freshwater Aquatic Resources – Post-Closure ...... 6.7-22 Table 6.7.1-7: Freshwater Aquatic Resources Valued Component Selection Rationale ...... 6.7-25 Table 6.7.2-1: Summary of Fish Captured and Average Catch-Per-Unit-Effort, By Season and Gear Type, in Lime and Patsy Creeks in 2009 ...... 6.7-42 Table 6.7.2-2: Summary of Fish Captured and Catch-Per-Unit-Effort, by Season, Reach, and Gear Type, in Lower Lime Creek in 2010...... 6.7-43 Table 6.7.2-3: Average Length, Weight, and Condition Factor for Dolly Varden Captured in Lime Creek in 2009 and 2010 ...... 6.7-44 Table 6.7.2-4: Percent Maturity, by Age, for Female and Male Dolly Varden Captured in Lime Creek in Fall 2009 ...... 6.7-49

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Table 6.7.2-5: Average Length, Weight, and Condition Factor at Age for Dolly Varden Captured in Lime Creek in 2009 and 2010 ...... 6.7-49 Table 6.7.2-6: Mean Hepatosomatic Indices for Dolly Varden Captured in Lime Creek in 2009 and 2010 ...... 6.7-54 Table 6.7.2-7: Mean Gonadosomatic Indices, by Sex, for Dolly Varden Captured in Lime Creek in 2009 and 2010 ...... 6.7-55 Table 6.7.2-8: Metal Concentrations in Juvenile Dolly Varden Muscle Tissue ...... 6.7-58 Table 6.7.2-9: Metal Concentrations in Adult Dolly Varden Muscle Tissue ...... 6.7-59 Table 6.7.2-10: Test for Significance Differences in Mean Metal Concentrations between Adult and Juvenile Dolly Varden Muscle Tissue in Lower Lime Creek ...... 6.7-60 Table 6.7.2-11: Historical Land Use Activities in Biophysical Cumulative Effects Assessment Study Area ...... 6.7-62 Table 6.7.2-12: Present Land Use Activities in Biophysical Cumulative Effects Assessment Study Area ...... 6.7-65 Table 6.7.2-13: Reasonably Foreseeable Projects in Biophysical Cumulative Effects Assessment Study Area ...... 6.7-67 Table 6.7.2-14: Assessment of Linkages between Other Projects, Human Activities and Reasonable Foreseeable Projects with Dolly Varden ...... 6.7-68 Table 6.7.2-15: Potential Direct Project Effects on Dolly Varden ...... 6.7-70 Table 6.7.2-16: Potential Indirect Project Effects on Dolly Varden ...... 6.7-72 Table 6.7.2-17: Potential Combined Project Effects by Project Phase on Dolly Varden ...... 6.7-76 Table 6.7.2-18: Potential Indirect Project Effects on Other Valued Components ...... 6.7-79 Table 6.7.2-19: Summary of Potential Interaction Between Project Effects on Dolly Varden and Other Valued Components ...... 6.7-81 Table 6.7.2-20: Summary of Potential Project Effects to be Carried Forward Into the Assessment for Dolly Varden ...... 6.7-83 Table 6.7.2-21: Potential Indirect Project Effects on Dolly Varden through Changes in Surface Water Quality and Mitigation Measures During Construction Phase ...... 6.7-87 Table 6.7.2-22: Potential Indirect Project Effects on Dolly Varden through Changes in Surface Water Quality and Mitigation Measures During Operations Phase ...... 6.7-90 Table 6.7.2-23: Potential Indirect Project Effects on Dolly Varden Through Changes in Surface Water Quality and Mitigation Measures During Closure / Decommissioning Phase ...... 6.7-94 Table 6.7.2-24: Potential Indirect Project Effects on Dolly Varden Through Changes in Surface Water Quality and Mitigation Measures During Post-closure Phase ...... 6.7-97 Table 6.7.2-25: Summary of Provincial and Federal Water Quality Guidelines for the Protection of Freshwater Aquatic Life in Lower Lime Creek ...... 6.7-100 Table 6.7.2-26: Summary of Predicted Exceedences of Provincial and Federal Water Quality Guidelines for the Protection of Freshwater Aquatic Life in Lower Lime Creek ...... 6.7-102 Table 6.7.2-27: Potential Indirect Project Effects on Dolly Varden through Changes in Hydrology in Lower Lime Creek and Mitigation Measures During Construction Phase ...... 6.7-107 Table 6.7.2-28: Potential Indirect Project Effects on Dolly Varden through Changes in Hydrology in Lower Lime Creek and Mitigation Measures During Operations Phase ...... 6.7-110 Table 6.7.2-29: Potential Indirect Project Effects on Dolly Varden through Changes in Hydrology in Lower Lime Creek and Mitigation Measures During Closure / Decommissioning Phase ...... 6.7-113 Table 6.7.2-30: Potential Indirect Project Effects on Dolly Varden Through Changes in Hydrology of Lime Creek and Mitigation Measures During Post-closure Phase ...... 6.7-115

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Table 6.7.2-31: Baseline and Predicted Mean, Minimum, and Maximum Monthly and Annual Discharge in Lower Lime Creek During Construction, Operations, Closure, and Post-Closure Phases of the Project ...... 6.7-120 Table 6.7.2-32: Optimal and Maximum Tolerance Water Temperature Ranges for Different Dolly Varden Life stages ...... 6.7-125 Table 6.7.2-33: Recommended Site-Specific Acute and Chronic Aluminum Guideline Criteria for the Protection of Freshwater Aquatic Life in Lower Lime Creek ...... 6.7-137 Table 6.7.2-34: Comparison of Median and 95 percentile Dissolved Aluminum Concentrations to Alternative Site-Specific Acute and Chronic Aluminum Guideline Criteria for Lower Lime Creek ...... 6.7-137 Table 6.7.2-35: Daily Discharges and Percent of Mean Annual Discharge in Lower Lime Creek During Data Collection Periods for Development of Hydraulic Relationships at Riffle Crests and Pool Tail-Outs, 2010 ...... 6.7-161 Table 6.7.2-36: Comparison of Predicted Water Depths and Water Velocities at Pool Tail-outs and Riffle Crest Mesohabitats in Lower Lime Creek During the Dolly Varden Spawning Period (September and October) Under Average and Low Flow Conditions During Pre-Mine, Construction (Stage 2 & 3), and Operations (Year 15) Phases of the Project ...... 6.7-167 Table 6.7.2-37: Comparison of Predicted Water Depths and Water Velocities at Pool Tail-Outs and Riffle Crest Mesohabitats in Lower Lime Creek During the Dolly Varden Egg Incubation Period (November to March) Under Average and Low Flow Conditions During Pre-Mine, Construction (Stage 2 & 3), and Operations (Year 15) Phases of the Project ...... 6.7-170 Table 6.7.2-38: Summary of Residual Effects for Dolly Varden ...... 6.7-176 Table 6.7.2-39: Residual Effects Assessment by Project Development Phase for Dolly Varden ...... 6.7-177 Table 6.7.2-40: Project Related Residual Effects - Rationale for Carrying Forward Into the Cumulative Effects Assessment ...... 6.7-180 Table 6.7.2-41: Assessment of Interaction between Other Projects, Human Activities and Reasonable Foreseeable Projects with Dolly Varden ...... 6.7-182 Table 6.7.2-42: Assessment of Spatial and Temporal Overlap Between the Project and Other Projects and Human Actions with Dolly Varden ...... 6.7-183 Table 6.7.2-43: Potential Cumulative Effect by Project Phase on Dolly Varden and Mitigation Measures ...... 6.7-185 Table 6.7.2-44: Summary of Residual Cumulative Effects for Dolly Varden ...... 6.7-186 Table 6.7.2-45: Residual Cumulative Effects Assessment on Dolly Varden by Project Development Phase ...... 6.7-187 Table 6.7.3-1: Historical Land Use Activities in Biophysical Cumulative Effects Assessment Study Area ...... 6.7-201 Table 6.7.3-2: Present Land Use Activities in Biophysical Cumulative Effects Assessment Study Area ...... 6.7-204 Table 6.7.3-3: Reasonably Foreseeable Projects in Biophysical Cumulative Effects Assessment Study Area ...... 6.7-205 Table 6.7.3-4 Assessment of Linkages Between Other Projects, Human Activities and Reasonable Foreseeable Projects with Coho Salmon ...... 6.7-206 Table 6.7.3-5: Potential Direct Project Effects on Coho Salmon ...... 6.7-208 Table 6.7.3-6 Potential Indirect Project Effects on Coho Salmon ...... 6.7-209 Table 6.7.3-7: Potential Combined Project Effects by Project Phase on Coho Salmon ...... 6.7-214 Table 6.7.3-8: Potential Indirect Project Effects on Other Valued Components ...... 6.7-216 Table 6.7.3-9: Summary of Potential Interaction Between Project Effects on Coho Salmon and Other Valued Components ...... 6.7-217 Table 6.7.3-10: Summary of Potential Project Effects to be Carried Forward Into the Assessment for Coho Salmon ...... 6.7-219

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Table 6.7.3-11: Summary of Provincial and Federal Water Quality Guidelines for the Protection of Freshwater Aquatic Life in Lower Lime Creek ...... 6.7-221 Table 6.7.3-12: Summary of Predicted Exceedences of Provincial and Federal Water Quality Guidelines for the Protection of Freshwater Aquatic Life in Lower Lime Creek ...... 6.7-6.7-223 Table 6.7.3-13: Summary of Residual Effects for Coho Salmon ...... 6.7-237 Table 6.7.3-14: Residual Effects Assessment by Project Development Phase for Coho Salmon ...... 6.7-238 Table 6.7.3-15: Project Related Residual Effects - Rationale for Carrying Forward Into the Cumulative Effects Assessment ...... 6.7-240 Table 6.7.3-16: Assessment of Interaction Between Other Projects, Human Activities and Reasonable Foreseeable Projects with Coho Salmon ...... 6.7-242 Table 6.7.3-17: Assessment of Spatial and Temporal Overlap Between the Project and Other Projects and Human Actions with Coho Salmon ...... 6.7-242 Table 6.7.3-18: Potential Cumulative Effect by Project Phase on Coho Salmon and Mitigation Measures ...... 6.7-244 Table 6.7.3-19: Summary of Residual Cumulative Effects for Coho Salmon ...... 6.7-245 Table 6.7.4-1: Summary of Fish Sampling Effort in Stream 76800 and ILP 887 Watersheds in June and July, 2011 ...... 6.7-258 Table 6.7.4-2: Summary of Known Rainbow Trout Stocking in Killam Lake by the BC MOE ...... 6.7-259 Table 6.7.4-3: Average Length, Weight, and Condition Factor of Rainbow Trout Captured in Clary Lake and Lake 901 Creek in 2010 ...... 6.7-261 Table 6.7.4-4: Weight-Length Relationship for Rainbow Trout Captured in Clary Lake and Lake 901 in 2010 ...... 6.7-261 Table 6.7.4-5: Average Length, Weight, and Condition Factor at Age for Rainbow Trout Captured in Clary Lake in 2010 ...... 6.7-264 Table 6.7.4-6: Length and Age of Mature Female and Male Rainbow Trout Captured in the Clary Lake Inlet (910-929800-05800-76800) in Spring 2010 ...... 6.7-264 Table 6.7.4-7: Metal Concentrations in Rainbow Trout Muscle Tissue from Clary Lake ...... 6.7-267 Table 6.7.4-8: Summary of Fish Captured in Lake 901 Inlets in Summer, 2010...... 6.7-268 Table 6.7.4-9 Summary of Fish Captured in Stream 76800 and ILP 887 Watersheds in June and July, 2011 ...... 6.7-269 Table 6.7.4-10: Historical Land Use Activities in Biophysical Cumulative Effects Assessment Study Area ...... 6.7-275 Table 6.7.4-11: Present Land Use Activities in Biophysical Cumulative Effects Assessment Study Area ...... 6.7-276 Table 6.7.4-12: Reasonably Foreseeable Projects in Biophysical Cumulative Effects Assessment Study Area ...... 6.7-277 Table 6.7.4-13 Assessment of Linkages Between Other Projects, Human Activities and Reasonable Foreseeable Projects with Rainbow Trout ...... 6.7-278 Table 6.7.4-14: Potential Direct Project Effects on Rainbow trout ...... 6.7-280 Table 6.7.4-15 Potential Indirect Project Effects on Rainbow Trout ...... 6.7-283 Table 6.7.4-16: Potential Combined Project Effects by Project Phase on Rainbow Trout ...... 6.7-286 Table 6.7.4-17: Potential Indirect Project Effects on Other Valued Components ...... 6.7-288 Table 6.7.4-18: Summary of Potential Interaction Between Project Effects on Rainbow Trout and Other Valued Components ...... 6.7-290 Table 6.7.4-19: Summary of Potential Project Effects to be Carried Forward Into the Assessment for Rainbow trout ...... 6.7-291 Table 6.7.4-20: Potential Project Effects on Rainbow Trout and Mitigation Measures ...... 6.7-293 Table 6.7.4-21: Upstream Watershed Areas at the Lake 901 Outlet and the Clary Lake Outlet During Pre-Mine and Construction, Operation, and Closure / Post-Closure Phases of the Project ...... 6.7-307

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Table 6.7.4-22: Predicted Average Monthly Flow Reductions in Lake 901 Due to Construction of the Northeast Embankment of the Tailings Management Facility ...... 6.7-308 Table 6.7.4-23: Predicted Average Lake Level Change in Clary Lake From Baseline, by Depth and by Percentage, during Construction, Operations, and Closure / Post-Closure Phases of the Project ...... 6.7-311 Table 6.7.4-24 Percentage Change in Average Monthly and Average Annual Flows at Different Locations in the Clary Creek Watershed During Construction, Operations, Closure, and Post-Closure Phases ...... 6.7-314 Table 6.7.4-25: Summary of Provincial and Federal Water Quality Guidelines for the Protection of Freshwater Aquatic Life in Lake 901 and Clary Lake ...... 6.7-316 Table 6.7.4-26: Summary of Predicted Exceedences of Provincial and Federal Water Quality Guidelines for the Protection of Freshwater Aquatic Life in Lake 901 ...... 6.7-319 Table 6.7.4-27: Summary of Predicted Exceedences of Provincial and Federal Water Quality Guidelines for the Protection of Freshwater Aquatic Life in Clary Lake ...... 6.7-319 Table 6.7.4-28: Summary of Habitat, by Reach and Tributary, in the Stream 76800 Watershed ...... 6.7-323 Table 6.7.4-29: Summary of Habitat, by Reach and Tributary, in the ILP 887 Watershed ...... 6.7-325 Table 6.7.4-30: Summary of Habitat Area, by Habitat Type, in the Two Lake 901 Inlet Tributaries Affected by the Construction and Operation of the Tailings Management Facility ...... 6.7-325 Table 6.7.4-31: Predicted Percent Change in Littoral Area of Clary Lake from Baseline, during Construction, Operations, and Closure / Post-Closure Phases of the Project ...... 6.7-327 Table 6.7.4-32: Predicted Average Monthly and Annual Flow Reductions in the Lake 493 Outlet Due to Water Diversions to Lake 901 Through the Diversion ...... 6.7-333 Table 6.7.4-33: Habitat Suitability Criteria for Rainbow Trout ...... 6.7-334 Table 6.7.4-34: Predicted Wetted Perimeter, Water Depth, and Water Velocity in the Lake 493 Outlet During May and August during Pre-Mine Baseline Conditions and During Construction / Operations and Closure / Post-Closure Phases of the Project ...... 6.7-336 Table 6.7.4-35: Trigger Ranges for Total Dissolved Phosphorus Concentrations in Freshwater Lakes and Streams in Canada (CCME 2004) ...... 6.7-351 Table 6.7.4-36: Baseline Trophic Parameter Values for Clary Lake and Lake 901 ...... 6.7-351 Table 6.7.4-37: Trophic State Index Ranges for Freshwater Lakes (from Carlson and Simpson (1996)) ...... 6.7-352 Table 6.7.4-38: Predicted Nitrogen / Phosphorus Ratios for Lake 901 During the Construction, Operations, Closure, and Post-Closure Phases of the Project ...... 6.7-353 Table 6.7.4-39: Trophic State Index (TSI) Values for Lake 901 Based on Predicted Total Nitrogen Concentrations During Construction, Operations, Closure, and Post-Closure Phases of the Project ...... 6.7-353 Table 6.7.4-40: Summary of Water Quality Predictions ...... 6.7-371 Table 6.7.4-41: Summary of Residual Effects for Rainbow Trout ...... 6.7-382 Table 6.7.4-42: Residual Effects Assessment of Loss of Fish Habitat Under and Downstream of the Tailings Management Facility on Rainbow Trout ...... 6.7-383 Table 6.7.4-43: Residual Effects Assessment of Change in Fish Passage at Stream Crossings Along the Kitsault Road on Rainbow Trout ...... 6.7-384 Table 6.7.4-44: Residual Effects Assessment of Change in Surface Water Quality Due to Tailings Management Facility Seepage on Rainbow Trout ...... 6.7-387 Table 6.7.4-45: Residual Effects Assessment of Lake Level Changes in Clary Lake on Rainbow Trout ...... 6.7-388

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Table 6.7.4-46 Residual Effects Assessment of Change in Stream Flows in the Clary Creek Watershed on Rainbow Trout ...... 6.7-389 Table 6.7.4-47 Residual Effects Assessment of Change in Stream Flows in the Clary Creek Watershed on Rainbow Trout ...... 6.7-390 Table 6.7.4-48: Residual Effects Assessment of Change in Benthic Macro- Invertebrates on Rainbow Trout ...... 6.7-392 Table 6.7.4-49: Project Related Residual Effects - Rationale for Carrying Forward Into the Cumulative Effects Assessment ...... 6.7-394 Table 6.7.4-50: Assessment of Interaction Between Other Projects, Human Activities and Reasonable Foreseeable Projects with Rainbow Trout ...... 6.7-396 Table 6.7.4-51: BC MOE Regional Fish Tissue Metal Concentration for Rainbow Trout in Pinchi Fault Lakes ...... 6.7-397 Table 6.7.4-52: Assessment of Spatial and Temporal Overlap Between the Project and Other Projects and Human Actions with Rainbow Trout ...... 6.7-398 Table 6.7.4-53: Potential Cumulative Effect by Project Phase on Rainbow Trout and Mitigation Measures ...... 6.7-400 Table 6.7.4-54: Summary of Residual Cumulative Effects for Rainbow Trout ...... 6.7-401 Table 6.7.4-55: Residual Cumulative Effects Assessment on Rainbow Trout by Project Development Phase ...... 6.7-402 Table 6.7.5-1: Sampling Precision, Mean Density, And Community Metrics For Stream BMI Sites Sampled in The Lime Creek Watershed In 2009 ...... 6.7-413 Table 6.7.5-2: Sampling Precision, Mean Density, And Mean Community Metrics For Stream BMI Sites Sampled In 2010 ...... 6.7-414 Table 6.7.5-3: Sampling Precision, Mean Density, And Community Metrics For Lake BMI Sites Sampled In 2009 And 2010...... 6.7-415 Table 6.7.5-4: Historical Land Use Activities in Biophysical Cumulative Effects Assessment Study Area ...... 6.7-418 Table 6.7.5-5: Present Land Use Activities in Biophysical Cumulative Effects Assessment Study Area ...... 6.7-419 Table 6.7.5-6: Reasonably Foreseeable Projects in Biophysical Cumulative Effects Assessment Study Area ...... 6.7-419 Table 6.7.5-7: Assessment of Linkages Between Other Projects, Human Activities and Reasonable Foreseeable Projects With Benthic Macro-Invertebrates ...... 6.7-420 Table 6.7.5-8: Potential Direct Project Effects on Benthic Macro-Invertebrates ...... 6.7-421 Table 6.7.5-9: Potential Indirect Project Effects on Benthic Macro-Invertebrates ...... 6.7-423 Table 6.7.5-10: Potential Combined Project Effects by Project Phase on Benthic Macro-Invertebrates ...... 6.7-426 Table 6.7.5-11: Potential Indirect Project Effects on Other Valued Components ...... 6.7-428 Table 6.7.5-12: Summary of Potential Interaction Between Project Effects on Benthic Macro-Invertebrates and Other Valued Components ...... 6.7-430 Table 6.7.5-13: Summary of Potential Project Effects to be Carried Forward Into the Assessment for Benthic Macro-Invertebrates ...... 6.7-432 Table 6.7.5-14: Potential Project Effects by Project Phase on Benthic Macro- Invertebrates and Mitigation Measures ...... 6.7-433 Table 6.7.5-15: Summary of Provincial and Federal Water Quality Guidelines for the Protection of Freshwater Aquatic Life in lower Lime Creek Watershed ...... 6.7-442 Table 6.7.5-16: Summary of Predicted Exceedances of Provincial and Federal Water Quality Guidelines for the Protection of Freshwater Aquatic Life in Lower Lime Creek ...... 6.7-445 Table 6.7.5-17: Summary of Predicted Exceedances of Provincial and Federal Water Quality Guidelines for the Protection of Freshwater Aquatic Life in Lake 901 in the Clary Creek watershed...... 6.7-446

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Table 6.7.5-18: Baseline and Predicted Mean, Minimum, and Maximum Monthly and Annual Discharge in Lower Lime Creek During Construction, Operations, Closure, and Post-Closure Phases of the Project ...... 6.7-454 Table 6.7.5-19 Percentage Change in Average Monthly and Average Annual Flows at Different Locations in the Clary Creek Watershed during Construction, Operations, Closure, and Post-Closure Phases ...... 6.7-458 Table 6.7.5-20: Predicted Average Lake Level Change in Clary Lake from Baseline, by Depth and by Percentage, during Construction, Operations, and Closure/Post-Closure Phases of the Project ...... 6.7-461 Table 6.7.5-21: Comparison of Toxicity Test Responses of Benthic Macro-invertebrates and Fish to Chemicals of Potential Concern Predicted to Exceed BC and / or CCME Guidelines for the Protection of Freshwater Aquatic Biota in Lime Creek and / or Lake 901 ...... 6.7-466 Table 6.7.5-22: Screening of Predicted Surface Water Quality Concentrations Against Background and Toxicological Benchmark Concentrations ...... 6.7-467 Table 6.7.5-23: Comparison of Predicted Wetted Perimeters and Water Velocities at Pool Tail-Outs and Riffle Crests in Lower Lime Creek Watershed During July and August Under Average and Low Flow Conditions During Pre-Mine, Construction (Stage 2 & 3), and Operations (Year 15) Phases of the Project ...... 6.7-473 Table 6.7.5-24: Predicted Average Monthly and Annual Flow Reductions in the Lake 493 Outlet due to Water Diversions to Lake 901 through the Gravity-Fed Pipeline ...... 6.7-6.7-475 Table 6.7.5-25: Predicted Wetted Perimeter, Water Depth, and Water Velocity in the Lake 493 Outlet during May and August during Pre-Mine Baseline Conditions and during Construction/Operations and Closure/Post- Closure Phases of the Project ...... 6.7-6.7-477 Table 6.7.5-26 Percentage Change in Average Monthly and Average Annual Flows at Different Locations in the Clary Creek Watershed During Construction, Operations, Closure, and Post-Closure Phases ...... 6.7-6.7-479 Table 6.7.5-27: Predicted Percent Change in Littoral Area of Clary Lake from Baseline, during Construction, Operations, and Closure/Post-Closure Phases of the Project ...... 6.7-482 Table 6.7.5-28: Summary of Residual Effects for Benthic Macro-Invertebrates ...... 6.7-483 Table 6.7.5-29: Residual Effects Assessment by Project Development Phase for Benthic Macro-Invertebrates ...... 6.7-483 Table 6.7.5-30: Project Related Residual Effects - Rationale for Carrying Forward Into the Cumulative Effects Assessment ...... 6.7-486 Table 6.7.5-31: Assessment of Interaction Between Other Projects, Human Activities and Reasonable Foreseeable Projects with Benthic Macro-Invertebrates ...... 6.7-488 Table 6.7.5-32: Assessment of Spatial and Temporal Overlap Between the Project and Other Projects and Human Actions with Benthic Macro-Invertebrates ...... 6.7-489 Table 6.7.5-33: Potential Cumulative Effect by Project Phase on Benthic Macro- Invertebrates and Mitigation Measures ...... 6.7-490 Table 6.7.5-34: Summary of Residual Cumulative Effects for Benthic Macro-Invertebrates ...... 6.7-492 Table 6.7.5-35: Residual Cumulative Effects Assessment on Benthic Macro-Invertebrates by Project Development Phase ...... 6.7-492

List of Figures Figure 6.7.2-1: Dolly Varden Local and Regional Study Area ...... 6.7-33 Figure 6.7.2-2: Dolly Varden Cumulative Effect Study Area ...... 6.7-37

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Figure 6.7.2-3: Length-Frequency Distribution of Dolly Varden Captured in Lower Lime Creek in 2009 and 2010 ...... 6.7-46 Figure 6.7.2-4: Age-Frequency Distributions of Dolly Varden Captured in Lower Lime Creek in 2009 And 2010 ...... 6.7-47 Figure 6.7.2-5: Growth Curve for Dolly Varden Captured in Lime Creek in 2009 and 2010 ...... 6.7-48 Figure 6.7.2-6: Length-at-Age for Dolly Varden Captured in Lime Creek in 2009 and 2010 ...... 6.7-48 Figure 6.7.2-7: Relative Abundance of Prey Items in Dolly Varden Stomachs Captured in 2009 ...... 6.7-50 Figure 6.7.2-8: Relative Percentage of Total Wet Weight of Prey Items, by Taxa, in Dolly Varden Stomachs Captured in 2009 ...... 6.7-51 Figure 6.7.2-9: Relative Abundance of Prey Items in Adult Dolly Varden (>180 mm) Stomachs Captured in 2009 ...... 6.7-52 Figure 6.7.2-10: Relative Percentage of Total Wet Weight of Prey Items, by Taxa, in Dolly Varden (>180 mm) Stomachs Captured in 2009 ...... 6.7-52 Figure 6.7.2-11: Relative Abundance of Prey Items in Dolly Varden (<180 mm) Stomachs Captured in 2009 ...... 6.7-53 Figure 6.7.2-12: Relative Percentage of Total Wet Weight of Prey Items, by Taxa, in Dolly Varden (<180 mm) Stomachs Captured in 2009 ...... 6.7-53 Figure 6.7.2-13: Relationship Between Hepatosomatic Index and Body Weight for Dolly Varden Captured in Lime Creek in 2009 and 2010 ...... 6.7-54 Figure 6.7.2-14: Relationship Between Gonadosomatic Index and Body Length (mm) of Male and Female Dolly Varden Captured in Lime Creek in 2009 ...... 6.7-55 Figure 6.7.2-15 Watershed Model Streamflow Nodes ...... 6.7-117 Figure 6.7.2-16: Comparison of Predicted Average Monthly Discharges in Lower Lime Creek during Construction, Operations (Years 13 and 15), Closure, and Post- Closure Phases to Average Pre-Mine Conditions ...... 6.7-121 Figure 6.7.2-17: Comparison of Predicted Average Monthly Discharges in Lower Lime Creek during Construction, Operations (Years 13 and 15), Closure, and Post- Closure Phases to Pre-Mine Average Monthly Discharge and the Calculated BC Instream Flow Guideline Threshold ...... 6.7-122 Figure 6.7.2-18 Mean, Minimum, and Maximum Daily Water Temperatures in Lower Lime Creek in 2010 / 2011 ...... 6.7-126 Figure 6.7.2-19: Study Transects Lower Lime Creek ...... 6.7-162 Figure 6.7.2-20 Hydraulic Relationship Between Discharge and Average Water Depth at Riffle Crests and Pool Tail-Outs in Lower Lime Creek ...... 6.7-164 Figure 6.7.2-21 Hydraulic Relationship Between Discharge and Average Water Velocity at Riffle Crests and Pool Tail-Outs in Lower Lime Creek ...... 6.7-165 Figure 6.7.3-1 Length-Frequency Distribution of Coho Salmon Captured in Lower Lime Creek in 2010 ...... 6.7-198 Figure 6.7.3-2: Comparison of Predicted Average Monthly Discharges in Lower Lime Creek during Construction, Operations (Years 13 and 15), Closure, and Post- Closure Phases to Average Pre-Mine Conditions ...... 6.7-227 Figure 6.7.3-3 Comparison of Predicted Average Monthly Discharges in Lower Lime Creek during Construction, Operations (Years 13 and 15), Closure, and Post- Closure Phases to Pre-Mine Average Monthly Discharge and the Calculated BC Instream Flow Guideline Threshold ...... 6.7-228 Figure 6.7.3-4 Mean, Minimum, and Maximum Daily Water Temperatures in Lower Lime Creek in 2010/2011 ...... 6.7-235 Figure 6.7.4-1: Rainbow Trout Local, Regional and Cumulative Effect Study Area ...... 6.7-252 Figure 6.7.4-2: Length-Frequency Distribution of Rainbow Trout Captured in Clary Lake in 2010 ...... 6.7-260 Figure 6.7.4-3: Age-Frequency Distribution of Rainbow Trout Captured in Clary Lake in 2010 ...... 6.7-262

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Figure 6.7.4-4: Von Bertalanffy Growth Curve for Rainbow Trout Captured in Clary Lake in 2010 ...... 6.7-263 Figure 6.7.4-5: Stomach Contents, as Percent of Total Weight by Major Taxa, of Rainbow Trout captured in Clary Lake in 2010 ...... 6.7-266 Figure 6.7.4-6 Location of Fish Captured or Observed in Lake 901 Tributaries Potentially Affected by the Tailings Management Facility ...... 6.7-271 Figure 6.7.4-7 Longitudinal Gradient Profile of Stream 76800 from Lake 901 Upstream Past the 1st Cascade Impediment to Fish Passage...... 6.7-272 Figure 6.7.4-8 Longitudinal Gradient Profile of ILP 887 from Lake 901 Upstream Past the 1st Cascade Impediment to Fish Passage ...... 6.7-273 Figure 6.7.4-9 Kitsault Mine General Layout ...... 6.7-282 Figure 6.7.4-10 Location of Mine Infrastructure in the Lime Creek and Clary Creek Watershed ...... 6.7-302 Figure 6.7.4-11: Lake 493 Diversion to Lake 901 Options Buried Pipline ...... 6.7-310 Figure 6.7.4-12: Clary Lake Bathymetry Map ...... 6.7-328 Figure 6.7.4-13: Littoral Habitat Calssification of Clary Lake ...... 6.7-329 Figure 6.7.4-14 Relationship Between Discharge and Wetted Perimeter in the Lake 493 Outlet ...... 6.7-335 Figure 6.7.4-15 Relationship Between Discharge and Water Depth in the Lake 493 Outlet ...... 6.7-335 Figure 6.7.4-16 Relationship Between Discharge and Water Velocity in the Lake 493 Outlet .... 6.7-336 Figure 6.7.4-17 Distribution of Water Depths Available to Rainbow Trout in the Lake 493 Outlet During the Open-Water Months of 2011 ...... 6.7-338 Figure 6.7.4-18 Distribution of Water Velocities Available to Rainbow Trout in the Lake 493 Outlet During the Open-Water Months of 2011 ...... 6.7-339 Figure 6.7.4-19 Natural and Man-Made Obstructions to Rainbow Trout in the Upper Clary Creek Watershed ...... 6.7-341 Figure 6.7.4-20: Stream Gradient Profile of Clary Creek from Clary Lake to Lake 493 ...... 6.7-342 Figure 6.7.5-1: Benthic Macro Invertebrate (BMI) Study Area...... 6.7-408 Figure 6.7.5-2: Comparison of Predicted Average Monthly Discharges in Lower Lime Creek During Construction, Operations (Years 13 and 15), Closure, and Post- Closure Phases to Average Pre-Mine Conditions ...... 6.7-455 Figure 6.7.5-3: Comparison of Predicted Average Monthly Discharges in Lower Lime Creek During Construction, Operations (Years 13 and 15), Closure, and Post- Closure Phases to Pre-Mine Average Monthly Discharge and the Calculated BC Instream Flow Guideline Threshold ...... 6.7-456 Figure 6.7.5-4: Predicted Average Monthly Discharges in Clary Creek Downstream of the Lake 901 Confluence During Baseline, Construction (Phases 1 and 2), Construction (Phase 3) and Operations, and Closure / Post-closure Phases ... 6.7-459 Figure 6.7.5-5: Predicted Average Monthly Discharges in the Clary Lake Outlet During Baseline, Construction (Phases 1 and 2), Construction (phase 3). Operations (Year 13 and 15), and Closure / Post-closure Phases ...... 6.7-460 Figure 6.7.5-6: Hydraulic Relationship Between Discharge and Average Water Depth at Riffle Crests and Pool Tail-Outs in Lower Lime Creek Watershed ...... 6.7-469 Figure 6.7.5-7: Hydraulic Relationship Between Discharge and Average Water Velocity at Riffle Crests and Pool Tail-Outs in Lower Lime Creek Watershed ...... 6.7-470 Figure 6.7.5-8: Relationship Between Discharge and Wetted Perimeter in the Lake 493 Outlet ...... 6.7-476 Figure 6.7.5-9: Relationship between Discharge and Water Velocity in the Lake 493 Outlet .... 6.7-476

List of Appendices Appendix 6.7-A Freshwater Aquatic Resources Baseline Report Appendix 6.7-B Development of Alternative Site-Specific Water Quality Guidelines

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Appendix 6.7-C Using the Biotec Ligan Model to Predict Acute Water Quality Criteria for Dissolved Copper and Zinc Appendix 6.7-D Summary of Transect Data Collected in Lime Creek in Pool Tail Out and Riffle Crest Habitats During June, July and August 2010 Appendix 6.7-E Hydraulic Transect in Pool Tail Out and Riffle Crest Habitats in the Lower Lime Crek (June, July and August 2010) - Channel Cross Section and Water Levels Appendix 6.7-F Description of Flowmaster Hydraulic Model Appendix 6.7-G Habitat Suitability Index Model for Dolly Varden Appendix 6.7-H Diversion Channel letter (KP)

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6.7 Freshwater Aquatic Resources Healthy freshwater aquatic ecosystems are important to the Nisga’a Nation, to Aboriginal groups, the public, the federal and provincial governments, and to the proponent. As such, assessment of potential Project effects on Freshwater Aquatic Resources is an important component of Avanti’s Kitsault Mine Ltd.’s (proponent) Application for an Environmental Certificate for the proposed Kitsault Mine Project (proposed Project). This assessment is necessary to develop appropriate mitigation measures to reduce or eliminate potential Project effects on Freshwater Aquatic Resources, both locally and cumulatively, to identify any residual effects that may remain, and to identify any harmful alteration, disruption, or destruction (HADD) of fish habitat that may require compensation under the federal Fisheries Act.

The framework for the assessment of potential effects on Freshwater Aquatic Resources VCs was as follows. First, all potential Project components or activities that had the potential to interact directly, indirectly, or cumulatively with Freshwater Aquatic Resources Valued Components (VCs) were identified. These components and activities were identified from the Project Description and from the Project Feasibility Study. Second, key issues for each VC were identified from the list of relevant Project components and activities using an interaction matrix. Key issues were identified in the interaction matrix using input obtained during pre-application-stage issues scoping with the public, the Nisga’a Nation, First Nations groups, other tenure holders, and federal and provincial regulators, and using professional judgment based on an understanding of the freshwater biotic communities and how the Project would be built, operated and decommissioned. Third, VCs were rationalised by considering the potential interaction of the Project on various freshwater aquatic species and taxonomic groups identified during baseline investigations and from input obtained during consultations with the Nisga’a Nation, First Nations groups, the public, and federal and government agencies. Finally, potential direct, indirect, combined, and cumulative effects were assessed for each identified VC. This was done for each phase of the proposed Project: construction, operations, decommissioning/closure, and post-closure.

For this assessment, the following definitions were used to identify potential direct, indirect, combined, and cumulative effects of the Project on Freshwater Aquatic Resources:

 Direct effects are interactions between Freshwater Aquatic Resource VCs and Project components and activities necessary for construction, operation, and decommissioning of the mine that have the potential to result in the direct mortality of Freshwater Aquatic Resource VCs (e.g., blasting) or the direct loss of their habitat under the Project footprint;  Indirect effects are interactions between Freshwater Aquatic Resource VCs and Project components and activities necessary for construction, operation, and decommissioning of the mine that have the potential to change the growth, survival, health or recruitment of the selected Freshwater Aquatic Resource VCs through changes in surface water quality, stream flows, and lake levels;

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 Combined effects are interactions between Freshwater Aquatic Resource VCs and Project components and activities that arise from direct and indirect effects of the Kitsault Project that occur simultaneously or overlap through time and occur in the same waterbody or stream to change the growth, survival, health, or recruitment of Freshwater Aquatic Resource VCs; and  Cumulative effects are interactions between residual effects from the Kitsault Project that have the potential to combine cumulatively with residual effects from other past, present, or reasonably foreseeable Projects.  Potential direct effects were assessed for each VC within their defined local study area (LSA). Potential indirect and combined effects were assessed for each VC within their defined regional study area (RSA). Potential cumulative effects of the Project with other past, present, or reasonably foreseeable Projects were assessed in the Cumulative Effects Study Area (CESA).  Mitigation measures to reduce or eliminate potential Project effects on each Freshwater Aquatic Recourses VC were identified during each phase of the Project. These included mitigation measures already included in the Project Description, mitigation measures included in the Aquatic Resources Management Plan and mitigation measures identified in this effect assessment that would become commitments once the Project is approved and permitted. Mitigation measures also include a fish habitat compensation plan for all unavoidable harmful alterations, disruptions, or destructions of fish habitat as required by the federal Fisheries Act. This plan is included as Appendix 11.2.A in this Environmental Application.

6.7.1 Valued Component Selection Rationale Valued Components (VCs) were used to focus the assessment on freshwater species or taxonomic groups that are important to people, are sensitive to environmental change, are important for the resilience of the freshwater ecosystem, or that fall under the auspices of relevant federal or provincial regulations.

The process for identifying and rationalising the selected VCs for the Freshwater Aquatic Resources discipline was a three stage process. First, all Project components and activities that had the potential to interact with Freshwater Aquatic Resources were identified in an interaction matrix. This matrix was populated by reviewing the Project Description and Project Feasibility Study. Second, key issues were identified and rationalised using professional judgement by considering the location, timing, spatial extent, and duration of each Project component and activity in relation to the freshwater aquatic communities known to occur within or downstream of the Project footprint. Key issues were also identified and rationalised using input from the public, the Nisga’a Nation, Aboriginal groups, and provincial and federal regulators during pre-Application consultations of the draft Assessment Information Requirements (dAIR) and the Project Description. Finally, VCs specific to the Freshwater Aquatic Resources discipline were selected and rationalised based on the potential interactions and key issues identified in the previous two steps. Each of these steps is described in the sections and tables below.

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6.7.1.1 Valued Component / Issue Identification and Scoping

Key issues raised by the Nisga’a Nation, Aboriginal groups, the public, and provincial and federal governments related to Freshwater Aquatic Resources during pre-Application consultations are presented in Table 6.7.1-1. From these consultations, the following key issues were relevant to the selection of Valued Components for the Freshwater Aquatic Resources environmental assessment and for confirming issues that need to be addressed and / or carried forward in the assessment:

 Pacific salmon, steelhead and other anadromous and resident freshwater salmonid fish species are important to the Nisga’a Nation and other Aboriginal groups;  Potential effects of the Project on Nisga’a Nation treaty entitlements needs to be addressed;  Potential effects of the Project on the rivers outside of the local and regional study areas (i.e., Nass, Cranberry River, Illiance, Kitsault, Kiteen, Tchitin, Tseax, Kitwanga, and Mediadin Rivers) need to be assessed or rationalised as to why they won’t occur;  Potential effects of increased angling pressure need to be assessed;  Potential effects of transportation routes on fish and fish habitat need to be assessed;  Potential effects on critical fish and fish habitats need to be assessed;  Potential effects of changes in stream flows need to be assessed;  Potential effects of the deposit of deleterious substances on fish habitat needs to be determined and assessed; and  Potential effect of changes in water quality on fish health, survival, and the health of wildlife and humans that eat fish need to be assessed.

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Table 6.7.1-1: Issues Raised or Identified a’a Nation, Aboriginal Groups, the Public, and

Relevant Section of Issue / Comment Source Application The Nisga’a Nation has treaty entitlements and allocations for harvesting Nisga’a Final Agreement Not applicable; Nass River is salmon species in the Nass Area. for Freshwater Aquatic Resources by the Nisg outside of the potential project effects study areas The Nisga’a Nation has a salmon and steelhead entitlement based on a Nisga’a Final Agreement Effects assessment percentage of the annual allowable harvest. Illiance and Kitsault Rivers are designated in the Nisga’a Final Nisga’a Final Agreement Cumulative Effects Agreement as Nisga’a angling guide tenures. Assessment; Fish Habitat Mitigation and Compensation Plan The Nass River is of great importance to Nisga’a Fisheries and is Nisga’a Fisheries; Nisga’a Lisims Not applicable; outside of certified as a “natural river” by the Marine Stewardship Council indicating Government; Open house project effects study areas for that the sockeye fishery meets the standards of a “sustainably managed freshwater aquatic resources fishery”. (see Section 6.7.1.2 below) Chum salmon are of particular management concern due to low Nisga’a Fisheries; Open house Fish Habitat Mitigation and population numbers. Compensation Plan Nisga’a citizens would like The proponent to support salmon Nisga’a Fisheries; Open house Fish Habitat Mitigation and conservation efforts to ensure long-term security of salmon supply. Compensation Plan Riparian areas are important to fish habitat. Nisga’a Land Use Plan (2002) Effects Assessment Critical fish habitat areas “may require special protection, specifically Nisga’a Land Use Plan (2002), Effects Assessment with respect to protection of riparian areas and restriction of access”. Nisga’a Final Agreement The Nisga’a Nation will make provisions for critical fish habitat areas when they are designated. Critically important rivers for the Nisga’a include the Cranberry, Kiteen, Tchitin, and Tseax river systems for Chinook salmon and the many coho salmon bearing stream supporting entitlements for Nisga’a under the Nisga’a Final Agreement. Nisga’a citizens have and continue to harvest a variety of fish and Nisga’a Lisims Government, Nisga’a Effects Assessment aquatic species for nutritional, economic, and ceremonial purposes. Fisheries, Open House Valued components for which the Nisga’a Nation has treaty-defined rights include: pacific salmon (sockeye, pink, coho, chum, and Chinook), steelhead, oolichan, halibut, and aquatic plants.

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Relevant Section of Issue / Comment Source Application Rationale for why steelhead and other salmon species specified in the Nisga’a Lisims Government Effects Assessment; See Nisga’a Final Agreement are not included as Valued Components needs Section 6.7.1.2 below to be provided. The assessment of effects of angling pressure due to increased access Nisga’a Lisims Government Effects Assessment to fishing areas in the vicinity of the Project need to be assessed. Rationale for why the project will not affect Nass River fisheries needs to Nisga’a Lisims Government Effects Assessment be provided. Potential effects of the Project on Nisga’a fish guiding rights in the Nisga’a Lisims Government Effects Assessment Illiance and Kitsault rivers need to be assessed. Quantitative assessment in terms of scale of loss of fish and fish habitat, Nisga’a Lisims Government Effects Assessment; Fish particularly coho salmon habitat, needs to be provided. Habitat Mitigation and Compensation plan The assessment of effects to freshwater aquatic resources and Lax Kw’alaams Band Not applicable; outside of associated species and water quality should include the whole of the project effects study areas for land and marine transportation routes and the Prince Rupert Harbour. freshwater aquatic resources Fishing for sockeye, pink, coho, chum, and Chinook salmon, steelhead, Kitselas First Nation Baseline, Effects Assessment; rainbow trout, Dolly Varden and cutthroat trout are important for see Section 6.7.1.2 below subsistence, economic, and cultural purposes to the Kitselas First Nation. Sockeye and spring salmon are the preferred fish species by the Kitselas First Nation as an important source of food. The Kitselas First Nation fishes for these fish species in the Skeena River and its tributaries. Sockeye salmon are the fish species of greatest importance to the Gitanyow First Nation Effects Assessment; see Gitanyow First Nation. Section 6.7.1.2 below In the past, Gitanyow fishing sites were located on the Kitwanga and Gitanyow First Nation Effects Assessment; see Cranberry river systems. However, depleted stocks in the Kitwanga Section 6.7.1.2 below River have caused Gitanyow fishermen to move to the Meziadin-Nass River system. The Cranberry River is an important spawning and rearing site for Gitanyow First Nation Effects Assessment; see salmon. Section 6.7.1.2 below

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Relevant Section of Issue / Comment Source Application Members of the Watakhayetsxw First Nation fish for coho and pink Watakhayetsxw First Nation Effects Assessment; see salmon in the canyon of the Cranberry River. Section 6.7.1.2 below The assessment of potential effects on fish should include baseline data Health Canada Baseline, Effects Assessment on metal concentrations in fish tissues and this data should be utilised in the human health impact assessment. The significance of any residual effect to individual fish, populations of Fisheries and Oceans Canada Effects Assessment, Fish resident fish and to the fish habitat in Patsy Creek, Lime Creek, and any Habitat Mitigation and other potentially affected fish habitat needs to be assessed. The use of Compensation Plan an “umbrella species” approach is not supported for the effects assessment. The length of fish habitat available to resident and anadromous fish in Fisheries and Oceans Canada Baseline, Fish Habitat Lime Creek is required. Mitigation and Compensation Plan Barrier assessments should include: height, length, pool depth, gradient Fisheries and Oceans Canada Baseline, Effects Assessment and any other attribute of the barrier necessary to determine fish passage limitations. Any upstream limits of fish distribution must be clearly defined with a UTM coordinate and a fish-bearing stream length. Baseline investigations should include methods for providing information Fisheries and Oceans Canada Baseline, Effects Assessment on the migration, spawning, and rearing timing of coho salmon and Chinook salmon in Lime Creek, two salmon species that have been observed rearing in the Lime Creek estuary. Without these data, DFO may not be able to assess impacts to coho or Chinook salmon within Lime Creek. Flow reductions in Lime Creek are expected to result in the greatest Fisheries and Oceans Canada Effects Assessment impact on fish habitat. Baseline studies describing Freshwater Aquatic Resources prior to mine BC Ministry of Environment Baseline, Environmental Effect discharges are necessary to assess project effects in any on-going Monitoring impact assessment. Appropriate biological monitoring tools must be used and sufficient data must be collected and presented in order to demonstrate that the proposed environmental effects monitoring program will be able to detect significant change.

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Relevant Section of Issue / Comment Source Application Baseline information needs to include: 1) description and map of BC Ministry of Environment Baseline, Environmental Effect fisheries and aquatic resources along access roads and utility corridors; Monitoring 2) inventory of specific biological receptors and other sensitive resources such as fish habitats; and 3) identification and quantification of biologically significant changes for selected bio-monitoring tools. A description of the conceptual Fish Habitat Compensation Plan needs BC Ministry of Environment Fish Habitat Mitigation and to be provided. Compensation Plan A rationale for why the Project will or will not require an amendment to Environment Canada Effect Assessment Schedule 2 of the Metal Mine Effluent Regulation under the Fisheries Act is required. Note: BC - British Columbia; DFO - Department of Fisheries and Oceans Canada; UTM - Universal Transverse Mercator

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Baseline studies conducted in 2009 and 2010 provided the list of potential VCs for the Freshwater Aquatic Resources discipline. Candidate VC fish species included Dolly Varden (Salvelinus malma), coho salmon (Oncorhynchus kisutch), coastrange sculpin (Cottus aleuticus), and prickly sculpin (Cottus aleuticus) in the Lime Creek watershed and rainbow trout (Oncorhynchus mykiss) in the Clary Creek watershed. Candidate VC lower trophic communities in streams in the Lime Creek and Clary Creek watersheds included benthic macro-invertebrates and periphyton (i.e., attached algae). Candidate VC lower trophic communities in lakes included benthic macro-invertebrates, phytoplankton, and zooplankton.

Based on input received during the pre-Application consultations and using professional judgement based on how the Project could potentially interact with the various fish, benthic macro-invertebrate, plankton, periphyton communities, the following VCs were selected for scoping of issues related to the construction, operations, closure / decommissioning, and post-closure of the Ktisault Project:

 Dolly Varden (Salvelinus malma) in the Lime Creek watershed;  Coho salmon (Oncorhynchus kisutch) in the Lime Creek watershed;  Rainbow trout (Oncorhynchus mykiss) in the Clary Creek watershed; and  Benthic macro-invertebrates in the Lime and Clary Creek watersheds.

These three fish species were selected because they are valued by people, are sensitive to environmental change, and / or are provincially listed in British Columbia (i.e., Dolly Varden). Benthic macro-invertebrates were selected as a VC because they are typically sensitive to changes in water quality and habitat, they are more sedentary than fish and longer-lived than periphyton or plankton, and are an important prey item for each of the three VC fish species. Periphyton and plankton communities were not selected as VCs because they were not identified as important to people during consultations, because their populations have a high degree of natural variability, and because they do not provide as direct a link between potential project effects and fish as do benthic macro-invertebrates.

Table 6.7.1-2 identifies all potential interactions, potential key interactions, and potential benefits of the Project on the three VC fish species and benthic macro-invertebrates during the construction, operations, closure / decommissioning, and post-closure phases of the Project. The list of Project components and activities included in this table was derived from the Project Description and the Project Feasibility Study.

Interactions and key interactions were those Project components or activities that had the potential to cause a negative effect on a VC. Potential benefits to Freshwater Aquatic Resources were considered only because the Kitsault Project is located at a brown-field site. This is a unique situation for a mine and would not be possible unless there had been past impacts from mining activities in the 1970s and 1980s. Only Project components or activities that would alleviate previous mining effects (i.e., habitat loss, creation of barriers to fish passage, tailings discharges to Lime Creek) were considered potential benefits to VCs.

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Regardless of potential negative or positive effects, only Project components or activities that had the potential to interact with any of the four VCs were included in Table 6.7.1-2.

Table 6.7.1-2: Valued Component / Issue Interaction Matrix for Freshwater Aquatic Resources

Freshwater Aquatic Resources Valued Ecosystem Components Project Phase Benthic Dolly Coho Rainbow macro- Varden salmon trout invertebrates Construction Phase Upgrade and widening of existing access roads o o Construction of new mine access road to processing plant o o Land clearing, top-soil stripping, and grading of land for o o o o mine infrastructure installations, ore stockpiles, and Waste Rock Management Facilities (WRMFs) Soil and till salvage, handling and storage, including o o o o locations, volumes and impacted areas Emissions and dust generation (fugitive emissions, o o o o equipment operation and movement) Mine infrastructure installations including processing plant, o o o camp, equipment washing facility, and primary crusher, conveyor systems, and pipelines Pre-stripping of Kitsault Pit o o o Blasting of Kitsault Pit core o o Development of south embankment of Tailings - - - Management Facility (TMF) development Development of south water management pond - - - Development of northeast embankment of TMF - - Development of northeast sediment control ponds - - Coffer dams, sumps, pump systems, and diversion o o o o ditches Explosives manufacturing facility and explosives o o magazine development Water management including dewatering, diversions, and - - - - downstream discharges Waste-water and sewage management o o o Firearms, fishing, and hunting o o o Operation Phase Maintenance and use of existing access road o o Maintenance and use of new mine access road o o Soil and till salvage, handling and storage, including o o o o locations, volumes and impacted areas Emissions and dust generation (fugitive dust, equipment o o o o operation and movement) East WRMF development - - - TMF development - - - -

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Freshwater Aquatic Resources Valued Ecosystem Components Project Phase Benthic Dolly Coho Rainbow macro- Varden salmon trout invertebrates TMF seepage management - - - - North WRMF development o o o o Low Grade Ore stockpile development o o o Surface water management and diversion systems - - - - Groundwater management - - - - Pit dewatering o o o Process and potable water supply and storage o o Storm-water run-off measures o o o o TMF surplus and contact water discharge (including - - - - blasting residues) Blasting o o Waste water management and treatment plant o o o Sewage effluent and treatment plant o o o Firearms, fishing, and hunting o o o Decommissioning and Closure Phase Access road decommissioning and reclamation o o Mine access road decommissioning and reclamation o o Decommissioning and removal of all processing facilities, o o o infrastructure, and ancillary facilities Decommissioning and removal of mine explosives o o manufacturing facility Emissions and dust generation (fugitive emissions, o o o o equipment operation and movement) Ore stockpiles reclamation o o o o Kitsault Pit reclamation including Kitsault Pit re-filling and - - - overflow East WRMF area reclamation o o o TMF area reclamation o o o o WRMF and TMF seepage management reclamation and - - - - decommissioning Surface water and groundwater management - - - - ML/ARD management - - - Firearms, fishing, and hunting o o o Post Closure Phase Monitoring and maintenance of soil stability and + + + + vegetation Monitoring and maintenance of mine drainage conditions + + + + Monitoring and maintenance of habitat compensation + + + + areas Monitoring and maintenance of Kitsault Pit water and + + + + associated discharge and seepage from WRMF and TSF

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Freshwater Aquatic Resources Valued Ecosystem Components Project Phase Benthic Dolly Coho Rainbow macro- Varden salmon trout invertebrates Monitoring and maintenance of discharge and surface + + + + water quality Monitoring and maintenance of ML/ARD water flow and + + + water quality TMF surplus and contact water discharge - - - Metal Leaching and Acid Rock Drainage (ML/ARD) - - - management Kitsault Pit reclamation including Kitsault Pit re-filling and - - - over-flow Firearms, fishing and hunting O o o Note: TMF - Tailings Management Facility; ML/ARD - metal leaching / acid rock drainage; WRMF - Waste Rock Management Facilities Interaction definitions: o - interaction; - - key interaction; + - benefit; NI - no interaction

Mine construction is expected to be approximately one year in duration and would focus on pre-stripping of the Kitsault Pit and construction of the initial tailings management facility embankments. Project components that may affect Freshwater Aquatic Resources during the mine construction phase include:

 Upgrading access roads and stream crossings for heavy trucks;  Building a new mine access road from the existing Alice Arm Road to the process plant / camp;  Clearing vegetation, stripping and storing top-soil, and grading land for construction of mine infrastructure including the processing plant, the main camp and the coarse and low grade ore stockpiles;  Building coffer dams, pump systems and diversion channels to dewater foundations for the northeast and south embankments of the tailings management facility;  Building diversion channels to capture and divert upstream run-off in the Patsy Creek watershed around the construction site;  Pre-stripping and blasting in the Kitsault Pit to prepare for mining and to create material needed for construction of the south tailings starter dam; and  Eventual impoundment of Patsy Creek run-off behind the south tailings starter dam.

Table 6.7.1-3 identifies the relevant key issues and provides a rationale for why each Project component has the potential to interact with the four Freshwater Aquatic Resource VCs during the construction phase of the Project.

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Table 6.7.1-3: Potential Issues by Project Component for Freshwater Aquatic Resources – Construction Phase

Project Component Relevant key Issue(s) Valued Component Rationale Overdue maintenance of existing access Potential change in fish passage Rainbow trout; benthic Regulatory requirement under roads at stream crossings; potential macro-invertebrates Sections 20, 35 and 36 of downstream sedimentation Fisheries Act Construction of new mine access road to Potential change in fish passage Rainbow trout; benthic Regulatory requirement under processing plant at stream crossings; potential macro-invertebrates Sections 20, 35 36 of Fisheries downstream sedimentation Act Land clearing, top-soil stripping, and Potential sedimentation in fish- Dolly Varden, coho Potential change in growth, grading of land for mine infrastructure bearing watercourses salmon, rainbow trout, survival, and recruitment of fish installations, ore stockpiles, and Waste benthic macro- and their prey Rock Management Facilities (WRMFs) invertebrates Soil and till salvage, handling and Potential sedimentation in fish- Dolly Varden, coho Potential change in growth, storage, including locations, volumes and bearing watercourses salmon, rainbow trout, survival, and recruitment of fish impacted areas benthic macro- and their prey invertebrates Emissions and dust generation (fugitive Potential lake acidification; Dolly Varden, coho Potential change in growth, emissions, equipment operation and sedimentation of incubating eggs; salmon, rainbow trout, survival, and recruitment of fish movement) gill damage from elevated total benthic macro- and their prey suspended solids invertebrates Mine infrastructure installations including Potential increase in suspended Dolly varden, coho Potential change in growth, processing plant, camp, equipment solids in Lime Creek salmon, and benthic survival, and recruitment of fish washing facility, and primary crusher, macro-invertebrates and their prey conveyor systems, and pipelines Pre-stripping of Kitsault Pit Potential increase in suspended Dolly varden, coho Potential change in growth, solids and change in stream salmon, and benthic survival, and recruitment of fish flows in Lime Creek macro-invertebrates and their prey Blasting of Kitsault Pit core Vibration; shock waves; dust Dolly varden, coho Regulatory requirement under generation; change in salmon, and benthic Section 32 of the federal downstream water quality due to macro-invertebrates Fisheries Act; potential change ammonia residue from ANFO use in survival, growth, and health of fish and their prey

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Project Component Relevant key Issue(s) Valued Component Rationale Development of south embankment of Potential change in stream flows, Dolly Varden, coho Potential change in growth, Tailings Management Facility (TMF) and fish habitat, and water quality in salmon, and benthic survival, and recruitment of fish south water management pond Lime Creek macro-invertebrates and their prey Development of northeast embankment of Potential change in stream flows, Rainbow trout and Potential change in growth, TMF and northeast sediment control fish habitat, and water quality benthic macro- survival, and recruitment of fish ponds invertebrates and their prey Installation of coffer dams, sumps, pump Potential change in stream flows Dolly Varden, coho Potential change in growth, systems, and diversion ditches and water quality salmon, rainbow trout, survival, and recruitment of fish and benthic macro- and their prey invertebrates Explosives manufacturing facility and Potential sedimentation in fish- Rainbow trout and Potential change in growth, explosives magazine development bearing watercourses benthic macro- survival, and recruitment of fish invertebrates and their prey Water management including dewatering, Potential change in stream flows Dolly Varden, coho Regulatory requirement in diversions, and downstream discharges and water quality in Lime and salmon, rainbow trout, Section 36 of the federal Clary creeks and benthic macro- Fisheries Act. Potential change invertebrates in growth, survival, and recruitment of fish and their prey Waste-water and sewage management Potential change in water quality Dolly Varden, coho Regulatory requirement in in Lime Creek salmon, and benthic Section 36 of the federal macro-invertebrates Fisheries Act. Potential change in health, growth, survival, and recruitment of fish and their prey Firearms, fishing, and hunting Potential to increase fishing Dolly Varden, coho Potential extirpation of local pressure salmon, rainbow trout sport fish populations Note: ANFO - ammonium nitrate / fuel oil (explosive); TMF - Tailings Management Facility; WRMFs - Waste Rock Management Facilities

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The mine operations phase is expected to be 15 years in duration. During this period, activities would focus on blasting and expansion of the existing Kitsault open-pit, processing of ore in the processing plant, continued development of the tailings management facility, development of the East Waste Rock Storage Facility, storage of mine tailings in the tailings management facility, and stockpiling and process of ore in course and low grade stockpiles. Project components that may affect Freshwater Aquatic Resources during the mine operations phase include:

 On-going pit dewatering and management of site contact water;  Diversion of Patsy Creek along the south wall of the Kitsault Pit;  Collection, release and potential treatment of excess water in the TMF to Lime Creek;  Withdrawal of freshwater from Clary Lake for fire suppression, reagent mixing, dust control, and potable water requirements;  Management of seepage from the northeast and south embankments of the TMF;  Collection, treatment, and release of waste-water and sewage effluent; and  Maintenance of access roads.

Table 6.7.1-4 identifies the relevant key issues and provides a rationale for why each Project component has the potential to interact with the four VCs during the operations phase of the proposed Project.

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Table 6.7.1-4: Potential Issues by Project Component for Freshwater Aquatic Resources – Operations Phase

Project Component Relevant Key Issue Valued Component Rationale Maintenance and use of existing access Potential downstream Rainbow trout; benthic Regulatory requirement in road sedimentation macro-invertebrates Section 36 of federal Fisheries Act; Potential change in the survival, growth, recruitment, and health of fish and their prey Maintenance and use of new mine access Potential downstream Rainbow trout; benthic Regulatory requirement in road sedimentation macro-invertebrates Section 36 of federal Fisheries Act; Potential change in the survival, growth, recruitment, and health of fish and their prey Soil and till salvage, handling and storage, Potential sedimentation in fish- Dolly Varden, coho Potential change in growth, including locations, volumes and impacted bearing watercourses salmon, rainbow trout, survival, and recruitment of fish areas benthic macro- and their prey invertebrates Emissions and dust generation (fugitive Potential lake acidification; Dolly Varden, coho Regulatory requirement in dust, equipment operation and movement) sedimentation of incubating eggs; salmon, rainbow trout, Section 36 of the federal gill damage from elevated total benthic macro- Fisheries Act. Potential change suspended solids invertebrates in growth, survival, and recruitment of fish and their prey East WRMF development Potential change in water quality Dolly Varden, coho Potential change in growth, and stream flows salmon, and benthic survival, and recruitment of fish macro-invertebrates and their prey TMF development Potential change in stream flows, Dolly Varden, coho Potential change in growth, fish habitat, and water quality salmon, rainbow trout, survival, and recruitment of fish and benthic macro- and their prey invertebrates TMF seepage management Potential change in water quality Dolly Varden, coho Regulatory requirement in salmon, rainbow trout, Section 36 of federal Fisheries and benthic macro- Act; potential change in growth, invertebrates survival, and recruitment of fish and their prey

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Project Component Relevant Key Issue Valued Component Rationale North WRMF development Potential change in water quality Dolly Varden, coho Potential change in growth, and stream flows salmon, rainbow trout, survival, and recruitment of fish and benthic macro- and their prey invertebrates Low Grade Ore Stockpile Development Potential change in water quality Dolly Varden, coho Potential change in growth, and stream flows salmon, and benthic survival, and recruitment of fish macro-invertebrates and their prey Surface water management and diversion Potential change in stream flows Dolly Varden, coho Potential change in growth, systems salmon, rainbow trout, survival, and recruitment of fish and benthic macro- and their prey invertebrates Groundwater management Potential change in water Dolly Varden, coho Potential change in growth, temperature and stream flows salmon, and benthic survival, and recruitment of fish macro-invertebrates and their prey Pit dewatering Potential change in water quality Dolly Varden, coho Potential change in the health, salmon, benthic macro- growth, survival, and recruitment invertebrates of fish and their prey Process and potable water supply and Potential lake draw-down and Rainbow trout and Potential change in fish mortality storage impingement of fish benthic macro- (Regulatory requirement in invertebrates Section 32 of federal Fisheries Act); potential change in the growth, survival, and recruitment of fish and their prey Storm-water run-off measures Potential change in water quality Dolly Varden, coho Potential change in health, and stream flows salmon, rainbow trout , growth, survival, and recruitment and benthic macro- of fish and their prey invertebrates TMF surplus and contact water discharge Potential change in water quality; Dolly Varden, coho Regulatory requirement in (including blasting residues) change in downstream water salmon, and benthic Section 36 of federal Fisheries quality due to ammonia residue macro-invertebrates Act; Potential change in health, from ANFO use growth, survival, and recruitment of fish and their prey

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Project Component Relevant Key Issue Valued Component Rationale Blasting Vibration; shock waves; dust Dolly Varden, coho Regulatory requirement under generation salmon Section 36 of the federal Fisheries Act; potential change in survival, growth, recruitment and health of fish and their prey Waste-water management and treatment Potential change in water quality Dolly Varden, coho Regulatory requirement under plant salmon, and benthic Section 36 of the federal macro-invertebrates Fisheries Act; Potential change in the survival, growth, recruitment and health of fish and their prey Sewage effluent and treatment plant Potential change in water quality Dolly Varden, coho Regulatory requirement under salmon, and benthic Section 36 of the federal macro-invertebrates Fisheries Act; Potential change in the survival, growth, recruitment and health of fish and their prey Firearms, fishing, and hunting Potential to increase fishing Dolly Varden, coho Potential extirpation of local sport pressure salmon, rainbow trout fish populations Note: TMF - Tailings Management Facility; WRMFs - Waste Rock Management Facilities

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Closure and decommissioning of the mine would begin during mine operations as part of the progressive reclamation plan. During this period, activities would focus on removal of buildings, equipment, pipelines, ditches, and roads, grading and reclamation of disturbed surfaces, and filling of the Kitsault Pit. Project components that may affect Freshwater Aquatic Resources during the mine closure / decommissioning phase include:

 Decommissioning of the south diversion channel, the southwest diversion channel, and the Patsy Creek diversion channel to allow the Kitsault Pit to fill with water;  Decommissioning of seepage collection ponds and pumps downstream of the northeast embankment of the TMF;  Decommissioning of the south water management pond and pumps at the toe of the East Waste Rock Management Facility;  Removal of the emergency spillway in the northeast embankment of the TMF;  Construction of a spillway in the south embankment of the TMF to allow TMF overflow to enter the Kitsault Pit;  Construction of a spillway at the low point of the Kitsault Pit to allow overflow to discharge to Lime Creek; and  Removal of all buildings, pipelines, ditches, and non-essential roads and stream crossings and grading, scarification, and seeding of all disturbed surfaces.

Table 6.7.1-5 identifies the relevant key issues and provides a rationale for why each Project component has the potential to interact with the four VCs during the closure / decommissioning phase of the proposed Project.

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Table 6.7.1-5: Potential Issues by Project Component for Fr

Project Component Relevant Key Issue Valued Component Rationale Access road decommissioning and Potential sedimentation in streams Rainbow trout and Potential change in growth, reclamation benthic macro- survival, and recruitment of fish invertebrates and their prey Mine access road decommissioning and Potential sedimentation in streams Rainbow trout and Potential change in growth, reclamation benthic macro- survival, and recruitment of fish eshwater Aquaticinvertebrates Resources – Closure andand Decommissioning their prey Phase Decommissioning and removal of all Potential sedimentation in streams Dolly Varden, coho Potential change in growth, processing facilities, infrastructure, and salmon, and benthic survival, and recruitment of fish ancillary facilities macro-invertebrates and their prey Decommissioning and removal of mine Potential sedimentation in streams Rainbow trout and Potential decrease in growth, explosives manufacturing facility benthic macro- survival, and recruitment of fish invertebrates and their prey Emissions and dust generation (fugitive Lake acidification; sedimentation of Dolly Varden, coho Regulatory requirement in emissions, equipment operation and incubating eggs; gill damage from salmon, rainbow trout, Section 36 of federal Fisheries movement) elevated turbidity benthic macro- Act; Potential decrease in growth, invertebrates survival, and recruitment of fish and their prey Ore stockpiles reclamation Potential sedimentation in streams Dolly Varden, coho Potential decrease in growth, salmon, rainbow trout, survival, and recruitment of fish benthic macro- and their prey invertebrates Kitsault Pit reclamation including Kitsault Potential change in stream flows Dolly Varden, coho Potential decrease in growth, Pit re-filling and overflow and water quality in streams salmon, benthic macro- survival, and recruitment of fish invertebrates and their prey East WRMF area reclamation Potential sedimentation in streams Dolly Varden, coho Potential decrease in growth, salmon, benthic macro- survival, and recruitment of fish invertebrates and their prey TMF area reclamation Potential change in stream flows, Dolly Varden, coho Potential decrease in growth, increase in sedimentation and salmon, rainbow trout, survival, and recruitment of fish turbidity benthic macro- and their prey invertebrates

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Project Component Relevant Key Issue Valued Component Rationale North WRMF area reclamation Potential sedimentation in streams Dolly Varden, coho Potential decrease in growth, salmon, rainbow trout, survival, and recruitment of fish benthic macro- and their prey invertebrates WRMF and TMF seepage management Potential change in water quality in Dolly Varden, coho Regulatory requirement in reclamation and decommissioning streams and lakes salmon, rainbow trout, Section 36 of federal Fisheries benthic macro- Act; Potential change in health, invertebrates growth, survival, and recruitment of fish and their prey Surface water and groundwater Potential change in stream flows, Dolly Varden, coho Potential change in growth, management water temperatures and water salmon, rainbow trout and survival, and recruitment of fish quality benthic macro- and their prey invertebrates ML/ARD management Potential change in water quality in Dolly Varden, coho Regulatory requirement in streams and lakes salmon, rainbow trout, Section 36 of federal Fisheries benthic macro- Act; Potential change in health, invertebrates growth, survival, and recruitment of fish and their prey Firearms, fishing, and hunting Potential to increase fishing Dolly Varden, coho Potential extirpation of local sport pressure salmon, rainbow trout fish populations Note: ML/ARD - metal leaching / acid rock drainage; TMF - Tailings Management Facility; WRMF - Waste Rock Management Facilities

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The post-closure phase of the mine would begin during mine closure and would extend at least five years beyond the end of the closure phase. This phase involves monitoring the water quality, stream flows, air quality and associated biological indicators of environmental change determined during consultations with federal and provincial regulators on development of the Environmental Effects Monitoring (EEM) program. These would include the monitoring of biological metrics required under the Metal Mine Effluent Regulations of the federal Fisheries Act. Table 6.7.1-6 identifies the relevant key issues and provides a rationale for why each Project component has the potential to interact with the four VCs during the post-closure phase of the proposed Project.

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Table 6.7.1-6: Potential Issues by Project Component for Freshwater Aquatic Resources – Post-Closure

Valued Ecosystem Project Component Relevant Key Issues component Rationale Monitoring and maintenance of soil stability Reduce sedimentation, decrease Dolly Varden, coho Reductions in sedimentation, and vegetation changes in water temperatures salmon, rainbow trout, water temperature fluctuations, and increase allochthanous inputs and benthic macro- and increases in allochthanous to streams invertebrates inputs to stream has potential to increase health, growth, survival and recruitment of fish and their prey Monitoring and maintenance of mine Maintain stream flows at closure Dolly Varden, coho Maintenance of stream flows will drainage conditions levels salmon, rainbow trout, allow fish and benthic macro- and benthic macro- invertebrate populations to invertebrates stabilise and reach new dynamic equilibrium Monitoring and maintenance of habitat Maintain long-term habitat stability Dolly Varden, coho Regulatory requirement under compensation areas and function salmon, and rainbow trout Section 35 of federal Fisheries Act to achieve “no-net-loss” of productive capacity of fish habitat. Maintenance of habitat compensation areas will allow fish and benthic macro- invertebrate populations to stabilise and reach new dynamic equilibrium Monitoring and maintenance of Kitsault Pit Maintain mine discharges below Dolly Varden, coho Maintenance of discharges below water and associated discharge and water quality objectives salmon, rainbow trout, water quality objectives will allow seepage from WRMF and TSF and benthic macro- fish and benthic macro- invertebrates invertebrate populations to stabilise and reach new dynamic equilibrium

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Valued Ecosystem Project Component Relevant Key Issues component Rationale Monitoring and maintenance of discharge Maintain mine discharges below Dolly Varden, coho Maintenance of discharges below and surface water quality water quality objectives salmon, rainbow trout, water quality objectives will allow and benthic macro- fish and benthic macro- invertebrates invertebrate populations to stabilise and reach new dynamic equilibrium Monitoring and maintenance of ML/ARD Maintain mine discharges below Dolly Varden, coho Maintenance of discharges below water flow and quality water quality objectives salmon, and benthic water quality objectives will allow macro-invertebrates fish and benthic macro- invertebrate populations to stabilise and reach new dynamic equilibrium Kitsault Pit over-flow discharge Potential change in surface water Dolly Varden, coho Potential change in growth, quality in Lime Creek salmon, and benthic survival, and recruitment of fish macro-invertebrates and their prey TMF surplus and contact water discharge Potential change in surface water Dolly Varden, coho Potential change in growth, quality in Lime Creek salmon, and benthic survival, and recruitment of fish macro-invertebrates and their prey Metal Leaching and Acid Rock Drainage Potential change in surface water Dolly Varden, coho Potential change in growth, (ML/ARD) management quality in Lime Creek salmon, and benthic survival, and recruitment of fish macro-invertebrates and their prey Firearms, fishing and hunting Increased fishing pressure Dolly Varden, coho Potential to extirpate local sport salmon, and rainbow trout fish populations Note: ML/ARD - metal leaching / acid rock drainage; TMF - Tailings Management Facility; WRMF - Waste Rock Management Facilities

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6.7.1.2 Valued Component / Issues Confirmation

Dolly Varden, coho salmon, rainbow trout, and benthic macro-invertebrates were selected as the Valued Components for the assessment of potential effects of the Kitsault Project on Freshwater Aquatic Resources. The rationale for the selection of each of these VC is provided in Table 6.7.1-7 below. This rationale was guided by: 1) the potential interactions between the various Project components and the freshwater aquatic communities characterised in the Lime Creek and Clary Creek watersheds during baseline studies conducted in 2009 and 2010; and 2) by the issues raised by the Nisga’a Nation, other Aboriginal groups, the public, and provincial and federal regulators during consultations on the Project Description and draft AIR.

Steelhead (anadromous rainbow trout) and other salmon species (i.e., pink, sockeye, Chinook, and chum salmon) were not included as VCs for the assessment of effects on Freshwater Aquatic Resources. These species, though highly valued by the Nisga’a Nation, other Aboriginal groups, and the public, were not included as VCs because they do not occur in any of the freshwater lakes or streams within or downstream of the proposed Project footprint. The Kitsault Project is confined to the Lime Creek and Clary Creek watersheds and neither of these watersheds supports anadromous runs of steelhead or any of the five Pacific salmon species. Coho salmon are included as a VC only because coho salmon fry have been found in lower Lime Creek. However, these fish are not natal to Lime Creek. Potential effects of the Project on coho salmon are therefore, limited to potential changes in stream flow and water quality on rearing habitat for this life stage (see Section 6.7.3).

The assessment does not include potential effects on Freshwater Aquatic Resources (including salmon) in the Nass, Cranberry, Skeena, Illiance, Kitsault, Kiteen, Tchitin, Tseax, Kitwanga or Meziadin rivers. This is because no mine components and no mine activities would occur in any of these watersheds during any phase of the Kitsault Project. The Kitsault Project is located entirely in the Lime and Clary Creek watersheds; Lime Creek is a tributary of Alice Arm while Clary Creek is a tributary of the Illiance River which itself is a tributary of Alice Arm. As this assessment will show, no effects of the Project on the Illiance River, or its fish community, are expected to occur.

For similar reasons, potential effects of the Project on Freshwater Aquatic Resources in the vicinity of the Prince Rupert Harbour will not be assessed. While Prince Rupert was a transportation alterative investigated by The proponent, a detailed assessment of the Prince Rupert port facilities and shipping routes has since determined that Prince Rupert is not a suitable location for transportation of ore concentrate to markets in Chile and Belgium (letter from Craig Nelson to CEAA and the BCEAO dated February 11, 2011). Instead, ore concentrate would be shipped from the Port of Vancouver. No effects to Freshwater Aquatic Resources in streams and lakes near Prince Rupert will occur as a result.

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Table 6.7.1-7: Freshwater Aquatic Resource

Valued Component Rationale Federal and Scientific Land and Nisga’a Nation and Applicable The public Provincial Common Interaction with literature and resource Scientific name Aboriginal groups government and other regulations name Project activities professional management included by BC EAO agencies stakeholders and judgement plans s Valued Component Selection Rationale guidelines Dolly Varden Salvelinus Potential change Fish species Nisga’a citizens have DFO, BC Central and Important Federal malma in stream flow and sensitive to treaty-defined right to MOE, HC North Coast sport-fish Fisheries Act water quality in changes in harvest fish resources Ecosystem- species in BC Fish Lime Creek may flow, water within the Nass Area. Based BC Protection affect the health, quality, water The Nisga’a Nation has Management Area Act growth, survival, temperature, an interest in preserving (EBM); residents Blue-listed and recruitment of habitat existing fish stocks BC have an fish species Dolly Varden in alteration, within Nisga’a Lands Freshwater interest in in BC (CDC Lime Creek. hybridisation and the Nass Area. The Fisheries preserving 2010) Potential increase and over- five potentially affected Program Dolly in fishing pressure fishing (Haas Aboriginal groups Plan Varden due to presence of 1998; (Metlakatla, Kitselas, populations construction and Armstrong and Kitsumkalum First in the Alice operations Hermans Nations, Gitanyow Arm area workforce may 2005); Fish Hereditary Chiefs and extirpate Dolly species Gitxsan Chiefs) have Varden stocks in particularly interests in harvesting Lime Creek and sensitive to and managing Dolly the greater the changes in Varden for cultural, Alice Arm area overwintering economic, and habitat / subsistence purposes. groundwater Mochnacz 2010) Coho Oncorhynchus Potential changes Fish species of Nisga’a citizens have DFO Pacific Important Federal salmon kisutch in stream flow and management the right to harvest fish Region commercial Fisheries Act water quality in concern for within the Nass Area as Integrated and sport- Pacific Lime Creek may commercial defined in the Nisga’a Fisheries fish species Salmon affect coho fisheries; fish Final Agreement. Management in BC Treaty salmon fry health, species Specifically, the Nisga’a Plan: Area (Northern growth, and sensitive to a Nation treaty- Salmon residents boundary survival changes in designated allocation of Northern have an with Alaska) Potential increase flow, water Coho salmon is 8.0% of B.C. interest in Aboriginal

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Valued Component Rationale Federal and Scientific Land and Nisga’a Nation and Applicable The public Provincial Common Interaction with literature and resource Scientific name Aboriginal groups government and other regulations name Project activities professional management included by BC EAO agencies stakeholders and judgement plans guidelines in fishing pressure quality, and the Coho return to preserving Fisheries due to presence of summer rearing Canada. The Nisga’a coho Strategy construction and habitat for fry Nation has an interest in salmon DFO’s Wild operations preserving existing stocks in Salmon workforce may Coho stocks within the the Alice Policy extirpate coho Nass Area, and does so Arm area salmon stocks in in coordination with the the greater Alice province as part of the Arm area Joint Fisheries Management Committee and the approval of the Nisga’a Annual Fish Plan. At open houses, Nisga’a citizens stated that the proponent should be involved in restoring stocks that were lost during the first mine operations in the 1980s. Potentially affected Aboriginal groups have indicated the importance of salmon for subsistence, commercial, domestic, and cultural purposes. They have interests in maintaining and harvesting salmon along the Kitsault transportation route.

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Valued Component Rationale Federal and Scientific Land and Nisga’a Nation and Applicable The public Provincial Common Interaction with literature and resource Scientific name Aboriginal groups government and other regulations name Project activities professional management included by BC EAO agencies stakeholders and judgement plans guidelines Rainbow Oncorhynchus Potential change Fish species Nisga’a citizens have DFO, BC BC North Important Federal trout mykiss in stream flow and sensitive to treaty-defined rights to MOE Coast Land sport-fish Fisheries water quality in changes in harvest fish resources Resource species in Act; BC Fish Clary Creek and flow, water within the Nass Area. Management BC Protection draw-down of quality, habitat The Nisga’a Nation has Plan; Act Clary Lake may alteration, and an interest in preserving BC affect rainbow to changes in existing fish stocks Freshwater trout health, riparian and within Nisga’a Lands Fisheries growth, survival instream cover and the Nass Area in Program and recruitment (Ford et coordination with the Plan Potential al.,1995) and province as part of the impingement / over-fishing Joint Fisheries entrainment of fish (Haas 1998) Management in potable water Low flow Committee. Some of supply pumps may conditions are the potentially affected increase mortality typically critical Aboriginal groups, of individual fish limiting factor including Kitselas and Potential increase for recruitment Kitsumkalum First in fishing pressure and survival Nation and Gitanyow due to presence of (Ford et al. Hereditary Chiefs, and workforce may 1995; Raleigh Gitxsan Chiefs, have an extirpate local et al. 1984) interest in harvesting rainbow trout and managing rainbow populations trout. Benthic Potential change Primary prey The Nisga’a Nation has DFO Public will Federal macro- in stream flow and items of stream an interest in preserving BC MOE seek Fisheries Act invertebrates water quality in and lake- fish habitat and food EC preservation (benthic Lime and Clary dwelling supply within Nass Area of the macro- creeks and draw- salmonids to maintain strong habitat and invertebrates down of Clary Different BMI Nisga’a fisheries. The food supply are included Lake may affect taxa are Nisga’a Nation of important in definition the density, sensitive to coordinates these sport fish of “fish distribution, and changes in issues and matters with species habitat”) dominance habitat, flow the province as part of such as

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Valued Component Rationale Federal and Scientific Land and Nisga’a Nation and Applicable The public Provincial Common Interaction with literature and resource Scientific name Aboriginal groups government and other regulations name Project activities professional management included by BC EAO agencies stakeholders and judgement plans guidelines structure of and water the Joint Fisheries Dolly benthic macro- quality Management Varden and invertebrate (Hilsenhoff Committee. rainbow communities in 1988; Merritt trout lakes and stream and Cummins downstream of the 1996; project Rosenberg and Resh 1993; Renyoldson et al. 1997) and therefore provide a link between effects to water quality, habitat, and primary producers (i.e., algae and plankton) to fish Note: BC - British Columbia; BC MOE - British Columbia Ministry of Environment; DFO - Fisheries and Oceans Canada; EC - Environment Canada; HC - Health Canada; Catch

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6.7.2 Dolly Varden 6.7.2.1 Introduction

The selection of Dolly Varden as a VC was based on the presence of an anadromous population of Dolly Varden in lower Lime Creek, the potential interaction of the Project with this population due to potential changes in Lime Creek water quality and flow, and the importance of Dolly Varden to the Nisga’a Nation, other Aboriginal groups, federal and provincial regulators and the public at large (see Table 6.7.1-7).

Because the Kitsault Project would be located in the Lime Creek and Clary Creek watersheds, potential direct, indirect, and combined effects on Dolly Varden may occur during all phases of the Project as Dolly Varden are known to exist in the lower reaches of both creeks and in the Illiance River downstream of Clary Creek. Potential direct effects include mortality of fish and eggs from blasting. Potential indirect effects on Dolly Varden include, but are not limited to, changes in Lime Creek water quality due to discharge of mine effluent, tailings seepage, and contact water run-off, and changes in Lime Creek flows due to capture of run-off, alteration of upstream catchment areas, and diversion of upstream tributaries. Potential combined effects include, but are not limited to, changes in Lime Creek water quality and stream flows.

Potential cumulative effects of the Project on Dolly Varden were assessed only for those direct, indirect, or combined effects that would likely result in a residual impact. Each of these residual impacts was then assessed for its potential to negatively affect Dolly Varden effected by residual impacts from other past, present, or reasonably foreseeable Projects in the Alice Arm area.

6.7.2.2 Relevant Legislation and Legal Framework

Three levels of government have potential jurisdiction over Dolly Varden potentially affected by the Kitsault Project. The relevant legislation and legal framework for each of these levels is described below.

6.7.2.2.1 Federal Section 32 of the federal Fisheries Act prohibits the destruction of fish by any means other than fishing except as authorised by Fisheries and Oceans Canada. Fish, as defined in the Fisheries Act, includes: 1) parts of fish; 2) shellfish, crustaceans, marine animals, and any parts of shellfish, crustaceans, or marine animals; and 3) the eggs, sperm, spawn, larvae, spat, and juvenile stages of fish, shellfish, crustaceans, and marine animals. Thus, for the purposes of the Kitsault Project and its effects on Dolly Varden, any Project component or activity that would result in the killing of Dolly Varden eggs, juveniles, or adult fish is prohibited by law.

Section 35(1) of the federal Fisheries Act prohibits the harmful alteration, disruption, or destruction (HADD) of fish habitat in Canada. Such a HADD is defined as “any change in fish habitat that reduces its capacity to support one or more life processes of fish” (DFO

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1998). Fish habitat, as defined in the Fisheries Act, is “spawning grounds and nursery, rearing, food supply, and migration areas on which fish depend directly or indirectly in order to carry out their life processes”. By this definition, fish habitat includes areas that currently produce fish, area that could potentially produce fish, or areas that provide the nutrients, water, or food supply to fish-producing habitat downstream.

Section 35(2) of the Fisheries Act allows a HADD of fish habitat if it is authorised by Fisheries and Oceans Canada (DFO). Such an authorisation would be issued by DFO only if it is satisfied that its guiding principle for the management of fish habitat in Canada would be met, that is there would be “no-net-loss (NNL) of productive capacity of fish habitat”.

The NNL guiding principle strives to avoid a net loss of productive capacity of fish habitat as a result of development projects by requiring the proponent to avoid any loss or harmful alteration by re-designing or relocating the project or mitigating the impacts where relocation or redesign is not possible. If none of these options are possible, compensation for the unavoidable habitat losses or harmful alterations is required.

The proponent would require a Section 35(2) Authorisation from DFO for any unavoidable HADD of fish habitat in Lime Creek where Dolly Varden are known to reside. Any such HADDs would require a fish habitat compensation plan that meets DFO’s “no-net-loss” guiding principle.

Section 36(3) of the Fisheries Act prohibits “the deposit of a deleterious substance of any type in waters frequented by fish or in any place, under any conditions, where the deleterious substance may enter any such water”. A deleterious substance is defined in the Fisheries Act as “any substance that, if added to any water, would degrade or alter, or form part of a process of degradation or alteration, of the quality of that water so that it is rendered, or is likely to be rendered, deleterious to fish or fish habitat or to the use by man of fish that frequent that water”. Thus, for the purposes of the Kitsault Project and its effects on Dolly Varden, Section 36(3) of the Fisheries Act effectively prohibits the deposit of any deleterious substances in Lime Creek in quantities or toxicity sufficient to adversely affect the growth, health, survival, and reproduction of Dolly Varden.

Dolly Varden are not listed on any of the schedules in the federal Species at Risk Act (SARA). They are not considered threatened, endangered, or at risk in Canada by the Committee on the Status of Endangered Wildlife in Canada (COSEWIC).

6.7.2.2.2 Provincial The province of British Columbia is responsible for the management of freshwater fish and fish habitat in BC. While this responsibility largely surrounds the management of fisheries for their sustained recreational use, the province has enacted legislation and various regulations that serve to protect and manage fish habitat. These legal devices include:

 Wildlife Act: fish are defined as “wildlife” for the provisions of the Act that provide for the designation of wildlife management areas and their protection. The Act also

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provides for the acquisition of land or improvements for the management and protection of fish;  Fish Protection Act: provides authority to consider impacts to fish and fish habitat before approving new or renewing existing water licenses and before issuing approvals for working in or near a stream; ensures sufficient water for fish when making decisions about licenses or approvals under the Water Act; allows the listing of streams with recognised fish values as being sensitive to water withdrawals; protects riparian areas through provisions of the Riparian Areas Regulation;  Riparian Areas Regulation: requires Qualified Environmental Professionals to assess riparian habitat, develop mitigation measures, and avoid impacts from development to fish and fish habitat;  Water Act: allows for effects to fish and fish habitat through the diversion or storage of water and to water in and about a stream; the Water Act has been amended for consistency with the Fish Protection Act; and  Forest and Range Protection Act: provides guidance on discretionary and mandatory Riparian Management Areas around fish bearing streams, lakes, and wetlands; provides guidance on size of harvestable forest areas and the rate at which wood can be removed from a watershed; and provides regulations on road building.

Despite these legal devices, the provincial government of BC does not have constitutional authority over fish habitat in BC. Instead, the provincial government provides only an advisory role to DFO in regards to when fish or fish habitat can be destroyed or altered and what would be required to ensure that “no-net-loss of the productive capacity of fish habitat” is achieved. This responsibility rests solely with DFO.

6.7.2.2.3 Nisga’a Lisims Government The Nisga’a Final Agreement (NFA) states “the Minister is responsible for the management of fisheries and fish habitat” with the Minister being defined as either the federal or provincial government. However, the NFA goes on to state that “fisheries management may involve the consideration of issues on a regional or watershed basis”. If Canada or British Columbia proposes to establish fisheries management advisory bodies for areas that include any part of the Nass Area, Canada or British Columbia will consult with the Nisga’a Nation in developing those bodies and, if appropriate, will provide for the participation of the Nisga’a Nation in those bodies.” This indicates that while the authority over fish habitat remains with Canada and the province, they do have a duty to consult on fish habitat issues within the Nisga’a traditional territory.

6.7.2.3 Spatial Boundaries

A description of and rationale for the Local Study Area (LSA), Regional Study Area (RSA), and cumulative effects study area (CESA) for Dolly Varden is provided in the sections below.

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6.7.2.3.1 Local Study Area The Local Study Area (LSA) for Dolly Varden was restricted to the Lime Creek watershed (Figure 6.7.2-1). This LSA was selected because it is the only watershed where potential direct effects to Dolly Varden from the Kitsault Project could occur. The only two potential direct effect of the Kitsault Project on Dolly Varden is mortality of Dolly Varden and their eggs from blasting in the Kitsault Pit and from increased fishing pressure due to the presence of the Kitsault mine workforce.

Although the Kitsault Project encroaches into the Clary Creek watershed and Dolly Varden are known to inhabit the lower reaches of Clary Creek and the Illiance River further downstream, both were excluded from the LSA because:

 No blasting would occur in the Clary Creek watershed;  Dolly Varden are restricted to the lower 250 metres of Clary Creek downstream of an impassable waterfall and so are approximately 10.2 km downstream of the Project footprint; and  The project would not provide any new access for anglers to Dolly Varden in lower Clary Creek or in the Illiance River.

Construction and operation of the Kitsault Project would not result in the direct loss of habitat used by Dolly Varden. This is because all necessary Project components and activities would be located in the non-fish-bearing headwaters of the Lime Creek watershed and in the headwaters of Clary Creek watershed upstream of the impassable waterfalls to Dolly Varden located near the confluence of Clary Creek and the Illiance River.

Although potential direct effects to Dolly Varden are restricted to the lower reaches of Lime Creek below the impassable waterfall, the LSA included the following watercourses and waterbodies within the Lime Creek watershed (Figure 6.7.2-1):

 Patsy Lake: non-fish-bearing lake in the headwaters of the Lime Creek watershed upstream of the impassable falls in Lime Creek. The proposed TMF would be centered on Patsy Lake;  Patsy Creek: non-fish-bearing creek draining Patsy Lake to Lime Creek upstream of the impassable waterfalls. Most mine components and activities, including the TMF, the Kitsault Pit, processing plant and camp, and the East Waste Rock Management Facility would be located in the Patsy Creek watershed; and  Lime Creek: non-fish-bearing reaches upstream of the impassable waterfalls to the confluence with Patsy Creek and the fish-bearing reaches between Alice Arm and the impassable waterfalls.

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465000 470000 475000 480000 485000 490000 Legend LAHTE CREEK Access Road KLAYDUC CREEK Mine Site Road

6160000 6160000 Transmission Line Stream Waterbody TCHITIN RIVER Pipeline - Freshwater

KITSAULT RIVER Diversion Ditch Process Plant

DAK RIVER

ILLIANCERIVER Open Pit

GUMAS CREEK Ore Stockpile Clary Lake Freshwater Intake Topsoil Stockpiles Waste Rock Management Facility

LA ROSE CREEK WASHOUT CREEK 6155000 6155000 Northeast Embankment Tailings Beach

SHISHILABET LAKES ALPINE LAKE Tailings Management Facility (TMF) Supernatant Pond Clary Creek Watershed GWUNYA CREEK Illiance River Watershed SHISHILABET LAKES Lime Creek Watershed Dolly Varden Local Study Area SHISHILABET LAKES FOXY CREEK ALASKA Dolly Varden Regional Study Area KEY MAP THEOPHILUS CREEK NORTHWEST TERRITORIES YUKON 6150000 6150000

FALLS CREEK Fort Nelson Juneau BRITISH COLUMBIA ALBERTA

ALICE ARM MORLEY CREEK KSHADIN CREEK

Fort St. John Stewart Project Location

Edmonton ALICE ARM CLARY CREEK Kitimat Prince George KITSAULT FSR (ALICE ARM ROAD)

KITSAULT Calgary TOWNSITE Kamloops CLARY Kelowna LAKE Vancouver

6145000 6145000 Victoria UNITED STATES KILLAM LAKE LAKE LAKE Scale:1:100,000 #901 #493 UNITED STATES 00.5 1 2 3 4 5

PATSY LAKE Reference Kilometres 1. Base Data ROUNDY CREEK Land and Resource Data Warehouse 1:20,000 (TRIM) 2: Kitsault Mine General Layout Supplied by AMEC and Knight Piesold on March 2011

CLIENT: Avanti Kitsault Mine Ltd.

LIME CREEK

PROJECT: Kitsault Mine Project 6140000 6140000 Dolly Varden Local and Regional Study Area

DATE: ANALYST: November 2011 MY Figure

JOB No: QA/QC: PDF FILE: VE51988 BH 10-50-100_dolly_LSA_RSA.pdf KSI GWINHAT'AL HOAN CREEK GIS FILE: 10-50-100.mxd

PROJECTION: DATUM: 465000 470000 475000 480000 485000 490000 UTM Zone 9 NAD83 Y:\GIS\Projects\VE\VE51988_Kitsault\Mapping\10_fisheries-aquatics\Baseline\10-50-0100.mxd KITSAULT MINE PROJECT ENVIRONMENTAL ASSESSMENT FRESHWATER AQUATIC RESOURCES

This LSA coincides with a portion of the hydrology and surface water quality LSAs. Hydrology and surface water quality LSAs also include the Clary Creek watershed and the Illiance River. This is because the Project has the potential to directly affect water quality and stream flows in these watercourses. Any potential direct effects to surface water quality and hydrology become indirect effects to Dolly Varden. Potential indirect effects of the Project on Dolly Varden were addressed in the Regional Study Area described below.

6.7.2.3.2 Regional Study Area The Regional Study Area for Dolly Varden included the LSA plus the adjacent watersheds known to support Dolly Varden that may be affected by potential indirect effects of the Project. These indirect effects include, but are not limited to, potential changes in water quality due to mine discharges and seepage, potential changes in stream flows due to diversions, catchment area changes, and water use and recycling, and potential changes in fish pressure due to the presence of the Kitsault Mine workforce.

The Regional Study Area (RSA) for Dolly Varden includes (Figure 6.7.2-1):

 The Lime Creek watershed: potential direct effects on Dolly Varden mortality due to blasting and potential indirect effects on Dolly Varden due to changes in water quality, stream flows, and fishing pressure;  The Clary Creek watershed: potential indirect effects on Dolly Varden in lower Clary Creek due to changes in water quality due to tailings impoundment seepage, changes in stream flow due to change in watershed catchment areas and freshwater-withdrawals during operations, and changes in fishing pressure: and  The Illiance River: potential indirect effects on Dolly Varden in the Illiance River due to changes in water quality and stream flows in Clary Creek and changes in fishing pressure. This RSA was consistent with the RSAs for the surface water quality and hydrology disciplines because it reflects all potential indirect effects of the Kitsault Project on Dolly Varden through changes in water quality and stream flows.

6.7.2.3.3 Cumulative Effects Study Area The Cumulative Effects Study Area (CESA) for Dolly Varden includes the watersheds and watercourses within the LSA and RSA plus those watersheds with past, present, or reasonably foreseeable Projects with known or likely residual effects that could cumulatively affect Dolly Varden populations in the Alice Arm area because of temporal or spatial overlap with the Kitsault Project.

The CESA for Dolly Varden was developed from the Project Inclusion List generated from a review of past, current and future land use in the Alice Arm area (Section 8.2.9 Land and Resource Use) and using professional judgement based on the known migratory behaviours and life history of Dolly Varden, the location of known barriers to fish migration in rivers with past, present, or reasonably foreseeable projects, and their known or likely distribution in

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Alice Arm area watersheds obtained from provincial or federal databases (e.g., Habitat Wizard, Mapster), the published literature, and / or available environmental impact assessments.

The “southern form” of Dolly Varden (i.e., the form found from the Aleutian Islands in Alaska south to Puget Sound, the form that includes Dolly Varden along the north coast of British Columbia) are known to migrate up to 250 km in the ocean (Bernard et al. 1995). However, the median migration distance for “southern form” Dolly Varden was found to be between 13 and 60 km (Bernard et al., 1995). These fish were most often found in near-shore areas within sub-tidal areas (Armstrong and Morrow, 1980 cited in Bernard et al., 1995). Thus, it is assumed that the migratory behaviour of adult Dolly Varden in the ocean creates the potential for cumulative effects from any past, present or reasonably foreseeable project or land use with potential residual effects within about 60 km of Lime Creek.

After migrating to sea, adult Dolly Varden feed entirely in marine waters during the summer and return to freshwater in the fall to spawn and then to overwinter (DeCicco 2001). Juvenile Dolly Varden in British Columbia are known to exhibit an amphidromous life history (i.e., moving between salt and freshwater for purposes other than breeding) rather than a truly anadromous life history (Myers 1949 in McPhail 2007). Thus, the movement of Dolly Varden spawned in Lime Creek to other watersheds with other past, present, or reasonably foreseeable is limited to the likelihood of adult fish moving into other watersheds to overwinter and the likelihood of juvenile fish moving between Lime Creek and other adjacent watersheds in summer.

In watersheds without accessible lakes such as Lime Creek, post-spawned Dolly Varden will either overwinter in other watersheds with accessible lakes, in larger rivers with deep pools, or in the ocean (Armstrong 1970, 1974, Bernard et al., 1995). The number of watersheds with accessible lakes in the Alice Arm, Hastings Arm, and Observatory Inlet area is unknown. Presumably this number is low given the steep topography of the area and the frequent barriers present in many of the neighbouring rivers and streams. In the Kitsault River for example, Dolly Varden cannot access Kitsault Lake or Jade Lake because of the impassable water fall approximately 23 km upstream from the mouth. Similarly, a barrier to upstream fish migration in the Illiance River located approximately 1.6 km upstream from Alice Arm prevents Dolly Varden from Lime Creek from entering unnamed lakes in its upper watershed. However, pools and side-channels in these rivers may be used by overwintering Dolly Varden.

Based on the above information, the CESA for Dolly Varden includes the (Figure 6.7.2-2):

 Lime Creek watershed: potential direct and indirect effects on Dolly Varden from the proposed Project and potential interactions with effects from past mining activities on the Kitsault deposit in the late 1960s / early 1970s and again in the early 1980s;

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 Clary Creek watershed: potential indirect effects on Dolly Varden from the proposed Project and potential interactions from past exploration activities at the Bell Moly deposit;  Roundy Creek watershed: potential interactions with past mining activities at the former Macy silica mine, past exploration activities at the Keystone deposit, and past and current exploration activities at the Roundy deposit;  Illiance River watershed: potential interactions with past mining activities at the former Illy mine;  Kitsault River watershed: potential interactions with past mining activities at the former Esperanza, Wolf, La Rose, Dolly Varden, North Star, and Torbrit mines and exploration activities at the Alice, Tiger, Kitsol, Moose-Climax, Victory, Robin, Sault, Vanguard Copper, San Diego, and Silver Chord deposits;  Alice Arm: potential interactions in the marine environment with residual effects from all past, present, and reasonably foreseeable mining projects in watersheds draining into Alice Arm;  Observatory Inlet: potential interactions in the marine environment with residual effects from past, present, and reasonably foreseeable mining projects in watersheds draining into Observatory Inlet.

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380000 390000 400000 410000 420000 430000 440000 450000 460000 470000 480000 490000 500000 510000 520000 530000 Legend Populated Place Road Transmission Line International / Provincial Border 6180000 6180000 Stream Waterbody Mine Footprint Clary Creek Watershed 6170000 6170000 Illiance River Watershed Kitsault River Watershed Lime Creek Watershed Cranberry Junction Roundy Creek Watershed 6160000 6160000 C Wilauks Creek Watershed U A Kitsault FSR N N Cumulative Effect Study Area I A (Alice Arm Road) T D E A Nass Wildlife Area D

S T Alice A T Arm

6150000 E 6150000 S

LICE A A R M ALASKA KEY MAP NORTHWEST TERRITORIES Nass FSR YUKON

6140000 Kitsault 6140000 Fort Nelson Townsite Kitsault Mine Juneau Project BRITISH COLUMBIA ALBERTA

Fort St. John Stewart Project Location

6130000 Nass Camp 6130000

Edmonton Kitimat Prince George

Calgary

Kamloops

6120000 New Aiyansh 6120000 Kelowna

Vancouver

T E Victoria L N I UNITED STATES Y R O 113 T A Scale:1:500,000 V UNITED STATES 6110000 R 6110000 E 0 5 10 20 S B O Kilometres

113 Laxgalts'ap Reference 1. Base Data 6100000 6100000 Geobase 1:20,000 (TRIM) Land and Resource Data Warehouse 1:250,000 (TRIM) Gingolx 2: Kitsault Mine General Layout Supplied by AMEC and Knight Piesold on March 2011

CLIENT: Avanti Kitsault Mine Ltd. 6090000 6090000

PROJECT: t le Kitsault Mine Project n I d n la rt o

6080000 P 6080000 Dolly Varden Cumulative Effect Study Area

DATE: ANALYST: November 2011 MY Figure

JOB No: QA/QC: PDF FILE:

6070000 6070000 VE51988 BH 10-50-101_dolly_CESA.pdf

GIS FILE: 10-50-101.mxd

PROJECTION: DATUM: 380000 390000 400000 410000 420000 430000 440000 450000 460000 470000 480000 490000 500000 510000 520000 530000 UTM Zone 9 NAD83 Y:\GIS\Projects\VE\VE51988_Kitsault\Mapping\10_fisheries-aquatics\Baseline\10-50-0101.mxd KITSAULT MINE PROJECT ENVIRONMENTAL ASSESSMENT FRESHWATER AQUATIC RESOURCES

6.7.2.4 Temporal Boundaries

Temporal boundaries for assessment of potential effects of the Kitsault Project on Dolly Varden were based on the reasonable expectation of time over which the proposed Project has had or would have effects on Dolly Varden. Thus, the selection of temporal boundaries for Dolly Varden was driven by the duration of each of the four primary phases of the proposed Project:

1. Construction Phase: estimated 25 month period that includes preparation of land for construction of mine infrastructure, construction of mine infrastructure including the Tailings Management Facility, camp complex, processing plant, and access roads and transmission lines, and implementation of the construction phase Water Management Plan; 2. Operations Phase: estimated at approximately two months of commissioning, and 15 to 16 years of mining (last two years are milling low grade ore). Phase includes progressive reclamation 3. Decommissioning and Closure Phase: estimated at 15 to 17 years. Includes a closure period during which the buildings and un-needed infrastructure would be removed, facilities reclaimed and closure Water Management Plan is enacted; 4. Post-Closure Phase: estimated at five years or more. Includes post-closure monitoring until on-site water quality has stabilised and indicates no future adverse effects on local receiving waters; stabilisation of waste rock and TMF would also be considered in post-closure monitoring.

The Kitsault site has legacy effects due to two previous mining operations in the 1970s and early 1980s. Of particular relevance to Dolly Varden was the deposit of at least 8 million tonnes of mine tailings directly into Lime Creek during the first mine operation between 1963 and 1972. While the high discharge and energy of Lime Creek has likely removed all of these tailings from Lime Creek and deposited them in Alice Arm, any residual effects of this deposition will be reflected in the baseline condition of Dolly Varden presented in the Appendix 6.7-A and summarised in Section 6.7.2-6 below. Baseline conditions of the Dolly Varden population in Lime Creek are considered to be representative of any residual effects of past mining activities at the Kitsault mine. Therefore, any past residual effects of the former Kitsault mine operations on Dolly Varden are automatically included within the temporal boundaries of the current assessment.

6.7.2.5 Information Source and Methods

6.7.2.5.1 Field Studies Baseline information on Dolly Varden in Lime Creek was collected during 2009 and 2010 field seasons (Appendix 6.7-A). Sampling in 2009 was conducted in July and September and had three main objectives: 1) determine the fish-bearing status of Lime Creek, Patsy Creek, and Patsy Lake upstream of the 8 metres (m) waterfalls in Lime Creek; 2) determine the fish community composition, relative abundance, and spatial distribution in Lime Creek

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The primary method of fish capture during the 2009 surveys was backpack electrofishing. In total 12 discreet sites, ranging from 150 m to 450 m in length, were electrofished between the July and September sampling periods. July sampling included one site below the waterfalls and two sites above the waterfalls in Lime Creek, three sites in Patsy Creek, and one site in a Patsy Lake tributary. September sampling included one site above and below the waterfalls in Lime Creek, one site in Patsy Creek and two sites in Patsy Creek tributaries. Sampling in September also included angling in the pool found directly below the waterfalls in Lime Creek.

Sampling in Lime Creek in 2010 was conducted entirely in Lime Creek below the waterfalls. Sampling was conducted during four distinct periods: early July, late July, early September and early October. Each of these sampling periods had distinct objectives:

 The early July sampling period was conducted to capture and mark as many Dolly Varden in lower Lime Creek as possible to facilitate a mark / recapture population estimate;  The late July sampling period was conducted to three weeks later to recapture as many marked fish as possible for the mark / recapture population estimate;  The early September sampling period was conducted to increase the number of recaptured fish for the mark / recapture population estimate and to increase the number of juvenile (<180 mm) Dolly Varden sacrificed for analysis of tissue metal residues from the four analyzed in 2009; and  The early October sampling period was conducted to document the timing and spatial distribution of the anadromous Dolly Varden spawning run previously documented in late September 2009.

Backpack electrofishing, angling, and baited minnow traps were used during the first three sampling periods in 2010. Electrofishing was used primarily in riffles, runs, and cascade habitats. Minnow traps were used primarily in pools and behind large boulders in riffles and runs. Angling was used exclusively in pools. Spinners and salmon eggs were used as bait when angling. Angling was the only fishing technique used during the early October sampling period because high stream flows precluded the safe and effective use of the other two gear types.

In both years, all Dolly Varden captured were enumerated and measured for length (mm) and wet weight (g). Ageing structures were collected from all Dolly Varden captured in Lime Creek in 2009. These included pelvic fin rays for fish live-released and fin rays and otoliths from fish sacrificed for tissue metal concentrations. Similar ageing structures were collected from live captured and dead sampled Dolly Varden in 2010. All ageing was conducted by North/South Consultants in Winnipeg, Manitoba in both years.

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Adipose fins and / or tissue plugs were collected from Dolly Varden captured in Lime Creek in 2009 for genetic analyses. Genetic analyses were conducted by Dr. Eric Taylor at the University of British Columbia to confirm whether the fish captured were Dolly Varden (Salvelinus malma) or bull trout (Salvelinus confluentus).

All fish sacrificed for metals analysis in 2009 and 2010 were examined internally for sex, gonad maturity, parasite loads and any pathological deformities. Gonad maturity was classified as immature, maturing, mature, ripe, spent, or resting. Gonads and livers were removed and weighed to the nearest 0.01 gram (g). Stomachs were removed and weighed and preserved for identification of dietary items in the lab. In the lab, stomachs contents were removed, blotted with filter paper to remove excess moisture, and weighed to the nearest milligram. Recognisable prey items were identified to Order, enumerated, and weighed, by group, to the nearest milligram.

In total, 12 Dolly Varden from Lime Creek were sacrificed for tissue metals analysis in 2009. All 12 of these fish were captured by angling in September in the pool immediately below the impassable waterfalls. Eight of these 12 fish were large (>180 mm), sexually-mature, adults while the remaining four fish were smaller (<180 mm) immature or maturing fish. An additional 10 juvenile (<180 mm) Dolly Varden were sacrificed in 2010 to increase the total sample size of juvenile Dolly Varden analysed for tissue metals to 14. This was done to determine if there were any significant differences in metal concentrations between juvenile Dolly Varden which had not yet gone to sea and larger sea-run adults. Muscle tissue metal concentrations were analysed by ICP-MS methods at ALS Environmental in Burnaby, BC.

In addition to fish sampling, stream habitat in Lime Creek was assessed and mapped using the following standardised methods:

 Resource Inventory Standard Committee (RISC) Reconnaissance (1:20,000) Fish and Fish Habitat Inventory: Reach Information Guide (RISC 2000);  Fish Habitat Assessment Procedures (Johnston and Slaney 1996); and  Sensitive Habitat Inventory and Mapping (Mason and Knight 2001).

Baseline data collected in the field was augmented and supported with:

 Fish distribution reports, and lake, stream, and stocking reports from the provincial Fisheries Inventory Summary System (FISS), Fisheries Inventory Data Query (FIDQ), EcoCat, FishWizard, and HabitatWizard databases;  Species summary and status reports from the BC Conservation Data Center (BC CDC);  Freshwater and anadromous fish and fish habitat in the North Coast. North Coast LRMP Background report (Gordon and Bahr, 2003)  Final Watershed Report for selected watersheds in DFO Areas 3, 4, 5, 6, & 7 (Rolston and Proctor 1999) from DFO’s WAVES on-line library;

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 Fisheries and habitat assessments conducted prior to re-starting of the mine in 1981 (i.e., McCart and Withler 1980; Lea and Goddard 1975; O’Connell 1976); and  Fish life history and habitat use syntheses (e.g., Ford et al. 1995; Haas 1998; Roberge et al. 2002; McPhail 2007.

6.7.2.5.2 Regional Baseline Clary Creek (downstream of the waterfalls) and the Illiance River were not sampled as part of baseline field investigations for Dolly Varden in 2009 and 2010. Instead, information regarding the distribution and relative abundance of Dolly Varden in these two systems was derived from a desktop review of existing baseline information from past or current environmental impact assessments, past monitoring reports for the previous Kitsault mining operations, and published grey and primary literature available for the watersheds included within the RSA. All available information was reviewed and summarised. When identified documents were not available online, government agencies were contacted directly to request reports.

6.7.2.6 Detailed Baseline for Dolly Varden

The following baseline information is based on summer and fall field programs conducted in the Lime Creek watershed by Rescan Environmental Limited in 2009 and by AMEC Earth & Environmental in 2010.

6.7.2.6.1 Genetics Genetic analysis of samples collected from charr captured in Lime Creek in 2009 confirmed that these fish were Dolly Varden (Salvelinus malma) and not bull trout (Salvelinus confluentus). Similar genetic analysis was not conducted in 2010 and it was assumed that all charr captured in 2010 were Dolly Varden.

6.7.2.6.2 Distribution and Catch-Per-Unit-Effort A total of 25 Dolly Varden were captured in Lime Creek downstream of the waterfall in 2009 (Table 6.7.2-1). Most (80%) of these fish were adult fish captured angling in the pool below the waterfall in late September during the Dolly Varden spawning period. Only four Dolly Varden were captured electrofishing in July; all of these fish were juveniles <180 mm long.

Despite over 9,300 seconds of backpack electrofishing in Lime and Patsy creeks above the waterfalls, no Dolly Varden (or any other fish species) were captured above the waterfalls. These 8 m high waterfalls are upstream limit of Dolly Varden in the Lime Creek watershed.

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Table 6.7.2-1: Summary of Fish Captured and Average Catch-Per-Unit-Effort, By Season and Gear Type, in Lime and Patsy Creeks in 2009

Total Catch and CPUE

1 Total # of Dolly Average Creek Season Method 2 3,4 SE effort Varden CPUE Lime Creek below falls Summer EF 740 4 0.54 - Fall EF 186 1 0.54 - AG 1.0 20 20.00 - VO 3 - - Total below falls EF 926 5 0.54 0.00 AG 1.0 20 20.00 - VO 3 - - Lime Creek above falls Summer EF 1,500 0 0.00 0.00 Fall EF 3,250 0 0.00 0.00 Patsy Creek Summer EF 2,242a 0 0.00 0.00 Fall EF 2,355 0 0.00 0.00 Total above falls EF 9,347 0 0.00 0.00 Note: 1 AG - angling; CPUE - catch-per-unit-effort; EF - backpack electrofishing; SE - standard error; VO - visual observed dead on creek margin 2 total effort for backpack electrofishing is in seconds; total effort for angling is in rod-hours 3 average CPUE for backpack electofishing is in fish/100 seconds 4 average CPUE for angling is in fish/rod-hour a includes 438 seconds of backpack electrofishing on a Patsy Lake tributary Source: Rescan 2010a.

In contrast to 2009, 138 Dolly Varden were captured in Lime Creek between Alice Arm and the waterfalls in 2010 (Table 6.7.2-2). This greater catch was due to the greater amount of fishing effort put into the reaches of Lime Creek downstream of the waterfalls in 2010 than in 2009. For example, over 20,000 seconds of backpack electrofishing was conducted in Lime Creek downstream of the waterfalls in 2010. Less than 1,000 second of backpack electofishing was conducted in these same reaches in 2009. This difference in effort, and subsequent catch, was due to the differences in study objectives between the two years: the focus of sampling efforts for in 2009 was to determine the fish-bearing status of streams and lakes upstream of the waterfalls while the focus of sampling in 2010 was to determine the relative abundance, distribution, and age and length frequency distributions, and to attempt a population estimate of Dolly Varden in Lime Creek downstream of the waterfalls.

Dolly Varden were captured in all four reaches of Lime Creek downstream of the waterfalls in 2010. This included the two reaches (reaches 1 and 2) located between Alice Arm and the first impediment to upstream fish passage in Lime Creek, an approximately 3 metre high bedrock cascade located approximately 268 metres upstream from Alice Arm. Dolly Varden

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KITSAULT MINE PROJECT ENVIRONMENTAL ASSESSMENT FRESHWATER AQUATIC RESOURCES were captured in the two reaches (reaches 3 and 4) upstream of this cascade in both 2009 and 2010. These included spawning adult Dolly Varden in Reach 4 at the base of the waterfalls in fall 2009 and juvenile Dolly Varden throughout reaches 3 and 4 in the summer of 2010. The presence of adult Dolly Varden in Reach 4 in fall 2009 indicates that the bedrock cascade is not a barrier to the upstream migration of adult Dolly Varden.

Table 6.7.2-2: Summary of Fish Captured and Catch-Per-Unit-Effort, by Season, Reach, and Gear Type, in Lower Lime Creek in 2010 Catch and Catch-per-unit-effort Season Reach Method1 Effort2 Sampling # of fish CPUE SE events captured Early July 2 EF 1,566 1 4 0.26 - 3 EF 725 1 3 0.41 - 3 MT 46.7 1 0 0.00 - 4 EF 3,959 6 33 0.89 0.43 4 MT 118.3 1 3 0.03 - 4 AG 0.8 3 2 2.33 1.20 Season total 45 Late July 1,2 EF 1,389 2 4 0.29 0.02 3 EF 573 1 5 0.87 - 3 AG 0.4 1 0 0.00 - 4 EF 6,718 8 72 1.00 0.20 4 AG 0.1 1 0 0.00 - Season total 81 Early 1,2 EF 1,100 1 1 0.09 - September 1,2 MT 237.5 3 0 0.00 0.00 4 EF 3,366 1 9 0.27 - Season total 10 Early 1,2,3 AG 8.9 5 0 0.00 0.00 October 4 EF 1,243 2 2 0.14 0.14 4 AG 2,8 5 0 0.00 0.00 Season total 2 Total by 1,2 EF 4,055 4 9 0.23 0.05 reach 3 EF 1,298 2 8 0.64 0.23 4 EF 15,286 17 116 0.81 0.19 Total by 1,2,3,4 EF 20,639 23 133 0.69 0.15 method 1,2,4 MT 402.5 5 3 0.03 0.01 1,2,3,4 AG 13.0 15 2 0.47 0.32 Grand Total 138 Note: 1 AG - angling; CPUE - catch-per-unit; EF - backpack electrofishing; MT - minnow trapping 2 Average catch-per-unit-effort is in fish per 100 seconds of electrofishing; average catch-per-unit-effort for minnow trapping and angling is in fish per trap-hour and fish per rod-hour, respectively

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Total average electrofishing catch-per-unit-effort (CPUE) for Dolly Varden in Lime Creek over all seasons and reaches in 2010 was 0.69 fish/100 seconds (Table 6.7.2-2). Average electrofishing CPUE for Dolly Varden was higher in Reach 4 (0.81 fish/100 seconds) than in reach 3 (0.64 fish/100 seconds) or reaches 1 and 2 combined (0.23 fish/100 seconds) (Table 6.7.2-2). Lower densities of Dolly Varden in reaches 1 and 2 may be due to increased competition for space and prey from the presence of coho salmon parr, coastrange sculpin, and prickly sculpin, and by predation by large prickly sculpin. Prickly sculpin >130 mm were captured in reaches 1 and 2 in 2010 and adult prickly sculpin of this size can be significant predators on salmonine fry (Berejikian 1995; Patten 1962; McPhail 2007).

Average electrofishing CPUE for Dolly Varden in Reach 4 (the longest reach of habitat upstream of the cascade impediment) in early July (0.89 fish/100 seconds) and late July (1.00 fish/100 seconds) was higher than in early September (0.27 fish/100 seconds) or early October (0.14 fish/100 seconds) (Table 6.7.2-2). This difference was most likely due to the lower catchability of Dolly Varden by electrofishing in September and October due to the higher water velocities and rising water levels after the increasingly frequent and intense rain events.

6.7.2.6.3 Length, Weight, and Condition Average length, weight, and condition factor of Dolly Varden in Lime Creek in 2009 and 2010 is provided in Table 6.7.2-3. A weight-length relationship for Dolly Varden in Lime Creek, based on all fish captured in 2009 and 2010, is described by the formula:

LnWt = 3.05LnLt-11.67

Where LnWt is the natural logarithm of weight in grams and LnLt is the natural logarithm of fork length in millimetres. The sample size for this equation was 150 fish and the equation had a r2 of 0.99.

Table 6.7.2-3: Average Length, Weight, and Condition Factor for Dolly Varden Captured in Lime Creek in 2009 and 2010

Year

2009 2010 Length (mm) n 27 134 Mean 203.0 97.1 S.E. 12.7 3.5 range 71-320 24-175 Weight (g) n 22 128 Mean 86.3 15.6 S.E. 13.0 1.3 Range 5.1-240 0.2-64.1

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Year

2009 2010 Condition factor n 22 128 Mean 1.11 1.10 S.E. 0.03 0.02 Range 0.94-1.42 0.44-1.62 Note: n - sample size ; S.E - standard error

Dolly Varden captured in 2009 were significantly (F1=120.17, p<0.001) larger than Dolly Varden captured in 2010. This was an artefact of the different sampling periods and gear types used between the two years. In 2009, all but five of the 25 Dolly Varden captured were caught angling in September during the Dolly Varden spawning period. In 2010, all but two of the 138 Dolly Varden captured were caught electrofishing in July or early September before the Dolly Varden spawning period.

This difference in size of Dolly Varden captured in 2009 and 2010 is clearly shown in the length-frequency distributions (Figure 6.7.2-3). Dolly Varden in 2009 ranged in length between 71 and 320 mm. However, the majority (85%) of these fish were > 140 mm (mean length of 222 mm (±10.1 mm)). The four fish <120 mm were all captured electrofishing in July (average length of 89 mm (±10.1 mm). In contrast, Dolly Varden captured in 2010 ranged in length between 24 and 175 mm with the majority (85%) of fish <140 mm in length. All but two of these fish were captured in July or September.

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18 16 2010, n=138 14 2009, n=27 12 10 8

Frequency 6 4 2 0

Length class (mm)

Figure 6.7.2-3: Length-Frequency Distribution of Dolly Varden Captured in Lower Lime Creek in 2009 and 2010

A distinct separation of young-of-the-year Dolly Varden from older (1+, 2+) juveniles is present in the 2010 length-frequency distribution (Figure 6.7.2-3). Young-of-the-year Dolly Varden were <60 mm long while yearling and older juveniles were >70 mm long.

6.7.2.6.4 Age, Growth, and Maturity Dolly Varden captured in Lime Creek in 2009 and 2010 ranged in age from 0+ to 4+ years old (Figure 6.7.2-4). However, there were significant differences in the mean age of fish captured in the two years; mean age of Dolly Varden captured in 2009 was 2.8 years old while mean age of Dolly Varden captured in 2010 was 1.3 years old. This difference in mean age between years was again due to the different sampling gears used and the different sampling periods sampled in 2009 and 2010.

In 2009, over 83% of all Dolly Varden captured were 3+ or 4+ years old (Figure 6.7.2-4). All of these older fish were all captured in September 2009 and all but two of these fish were identified as mature or ripe adults preparing to spawn (Table 6.7.2-4). Of these 3+ and 4+ fish, 80% were >180 mm long and many of the males had pronounced kipes (Rescan 2010b). The other four 3+ year old fish were less than <180 mm but two of these fish were also identified as mature spawners. These smaller mature fish may actually be older

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KITSAULT MINE PROJECT ENVIRONMENTAL ASSESSMENT FRESHWATER AQUATIC RESOURCES juveniles that were preparing to spawn next year, may be individuals with a “sneaker” or “jack” life history, or may simply be sea-run fish that matured younger than most.

In contrast, the majority (87%) of Dolly Varden captured in 2010 were less than 3+ years old (Figure 6.7.2-4). All of these 0+, 1+, and 2+ fish were <180 mm long and all were identified as juveniles. All eleven 3+ fish captured in 2010 were also <180 mm long and were also identified as juveniles. While the timing of their capture in July and early September made external identification of sexual maturity difficult, internal examination of fish sacrificed for tissue metals analysis in both periods indicated that fish of this size and age were immature in 2010.

70

60

50

40

30 2010 2009 % Frequency % 20

10

0 01234 Age (years)

Figure 6.7.2-4: Age-Frequency Distributions of Dolly Varden Captured in Lower Lime Creek in 2009 And 2010

Average length, weight, and condition factor, at age, for Dolly Varden captured in 2009 and 2010 is presented in Table 6.7.2-5. On average, Dolly varden had reached 81 mm, 103 mm, 124 mm, 184 mm, and 258 mm by their first, second, third and fourth years, respectively. Similar growth has been observed in the Keogh River on Vancouver Island (Smith and Slaney, 1980). On average, Dolly Varden in the Keogh River smolt in their third summer (at about 140 mm) where upon they almost double in size before returning to the river after about 100 days in the ocean (Smith and Slaney, 1980). This difference in growth rates between the stream rearing juveniles and the ocean foraging adults is the reason why a von Bertallanfy growth equation could not be fit to the length-at-age data for the Lime Creek Dolly Varden. Instead, a four parameter logistic growth function was the best fit to all of the length-at-age data for Lime Creek Dolly Varden (Figure 6.7.2-5). This difference in stream and ocean growth is evident in the length-at-age data between the juvenile fish captured in 2010 and the adult fish captured in 2009 (Figure 6.7.2-6).

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400 Y = 81 + ((317.0164) / (1 + exp(3.7496 ‐ X) / 0.9821)) 350 300 250 (mm) 200 150 Length 100 50 0 0 1 2 3 4 5 Age (years)

Figure 6.7.2-5: Growth Curve for Dolly Varden Captured in Lime Creek in 2009 and 2010

350

300

250

200

150 2010

Length (mm) 2009 100

50

0 012345 Age (years)

Figure 6.7.2-6: Length-at-Age for Dolly Varden Captured in Lime Creek in 2009 and 2010

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Table 6.7.2-4: Percent Maturity, by Age, for Female and

Both sexes combined Females Males Age n % mature n % mature n % mature 0+ 0 - 0 - 0 - 1+ 2 50.0 0 - 1 0.0 2+ 0 - 0 - 0 - Male Dolly Varden Captured in Lime Creek in Fall 2009 3+ 15 80.0 5 100.0 6 100.0 4+ 5 100.0 1 100.0 2 100.0 Total 22 6 9 Note: n - sample size; SE - standard error; % - percentage

Table 6.7.2-5: Average Length, Weight, and Condition Factor at Length (mm) Weight (g) Condition Age n Mean SE range n Mean SE range n Mean SE range 0+ 4 81.0 2.3 76-87 4 6.3 0.5 5.2-7.2 4 1.18 0.05 1.09-1.32 1+ 32 103.1 4.2 73-175 32 14.5 2.4 4.7-63.0 32 1.11 0.02 0.82-1.43 2+ 42 124.0 2.9 83-170 40 22.5 1.5 5.8-55.5 40 1.12 0.02 0.91-1.62 3+ 26 183.5 8.2 127-280 24 65.4 7.6 24.7-146.7 24 1.09 0.02 0.84-1.26 Age for Dolly Varden Captured in Lime Creek in 2009 and 2010 4+ 5 258.0 18.3 204-310 3 161.4 41.8 97.2-240 3 1.11 0.02 1.07-1.14 Total 109 103 103 Note: n - sample size; SE - standard error

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6.7.2.6.5 Diet Dipteran (true flies) larvae and adults comprised the largest proportion (34%) of identifiable prey items found in 12 Dolly Varden stomachs in 2009 (Figure 6.7.2-7). This was followed by, in order of abundance, fish eggs (20%), tricopteran (caddisflies) larvae (13%), adult and larval hymenopterans (ants, bees, and wasps) (9%), adult lepidopterans (moths and butterflies) (7%), ephemeroptera (mayflies) larvae (5%), and plecopteran (stoneflies) larvae (4%). All other prey items comprised <4% of the total prey items consumed.

Of the 339 prey items consumed, only 53% were adults or larvae of freshwater origin (i.e., insects on the bottom or drifting in Lime Creek). The other 47% were adults or larvae of terrestrial origin that were eaten when they fell into Lime Creek, presumably from the riparian vegetation and tree canopy. These included 68% of all hymenopterans, 89% of all dipterans, 93% of all coleopterans, and 100% of all lepidopterans consumed.

4% 20% Coleoptera Diptera Ephemeroptera 0.3% 34% Hymenoptera 4% Lepidoptera Plecoptera Trichoptera 13% Arachnida Oligochaeta

4% 5% Fish eggs 7% 9% n=339 prey items

Figure 6.7.2-7: Relative Abundance of Prey Items in Dolly Varden Stomachs Captured in 2009

Fish eggs comprised the largest proportion (46%) of the total wet weight of prey items eaten by Dolly Varden in 2009 (Figure 6.7.2-8). These were followed by, in order of percentage of total wet weight, trichopteran larvae (16%), unidentifiable insect parts (10%), adult lepidopterans (9%), and adult and larval dipterans (5%). All other prey taxa comprised <5% of the total wet weight of prey items consumed by Dolly Varden in 2009.

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2% 10% 5% 2% 4% Coleoptera Diptera 9% Ephemeroptera Hymenoptera

3% Lepidoptera Plecoptera Trichoptera Arachnida 46% 16% Fish eggs Insect parts 2% n= 9.76 g total wet weight Oligochaeta =<1% of total wet weight

Figure 6.7.2-8: Relative Percentage of Total Wet Weight of Prey Items, by Taxa, in Dolly Varden Stomachs Captured in 2009

Although the sample sizes were smaller, there was a substantial difference in diet between Dolly Varden >180 mm (n=8 fish) and Dolly Varden <180 mm (n=4 fish) in 2009. The diet of larger fish was comprised largely of terrestrial and aquatic insects with dipterans, trichopterans, hymenopterans, lepidopterans, and plecopterans comprising 83% of total prey items consumed by these larger fish (Figure 6.7.2-9). These dietary items comprised 81% of the total wet weight of prey items consumed by these eight fish (Figure 6.7.2-10). In contrast, fish eggs were the primary food item of Dolly Varden <180 mm in length, comprising 32% of the total prey items consumed (Figure 6.7.2-11). These eggs comprised 62% of the total wet weight of prey items consumed in these smaller fish (Figure 6.7.2-12). Fish eggs comprised only 6% of the total wet weight of prey items consumed by the larger fish (Figure 6.7.2-10).

Such a difference in diet between these two size groups of Dolly Varden in 2009 provides evidence that Dolly Varden <180 mm are juveniles that had not yet migrated to Alice Arm. These smaller fish were feeding opportunistically on the eggs laid by the returning adults. In contrast, the largely insect diet, coupled with their larger size, and older mean age (all eight fish were 3+ or 4+ years old), and sexual maturity indicates that the other eight fish were adults returning to Lime Creek spawn and had likely be in the creek for only a short period.

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1% 1% 2% 6% Coleoptera 17% Diptera Ephemeroptera Hymenoptera 32% 7% Lepidoptera Plecoptera Trichoptera

11% Arachnida Oligochaeta 7% Fish eggs n=137 prey items 16%

Figure 6.7.2-9: Relative Abundance of Prey Items in Adult Dolly Varden (>180 mm) Stomachs Captured in 2009

10% 3% 8% Coleoptera 6% 5% Diptera 1% Ephemeroptera 3% 7% Hymenoptera Lepidoptera Plecoptera Trichoptera 16% Arachnida 32% Oligochaeta Fish eggs 8% n=2.77 g total wet weight Insect parts

Figure 6.7.2-10: Relative Percentage of Total Wet Weight of Prey Items, by Taxa, in Dolly Varden (>180 mm) Stomachs Captured in 2009

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3% Coleoptera Diptera 32% Ephemeroptera 35% Hymenoptera Lepidoptera Plecoptera Trichoptera 0% Arachnida 5% Oligochaeta 3% Fish eggs 11% 4% n= 202 prey items 1% 5%

Figure 6.7.2-11: Relative Abundance of Prey Items in Dolly Varden (<180 mm) Stomachs Captured in 2009

1% 11% 1% 4% 3% Coleoptera 6% Diptera 0.3% Ephemeroptera Hymenoptera 10% Lepidoptera Plecoptera 1% 0% Trichoptera Arachnida Oligochaeta Fish eggs 62% Insect parts n=6.99 g total wet weight

Figure 6.7.2-12: Relative Percentage of Total Wet Weight of Prey Items, by Taxa, in Dolly Varden (<180 mm) Stomachs Captured in 2009

6.7.2.6.6 Energy Storage and Energy Use Dolly Varden in 2009 had a significantly (p<0.005) higher hepatosomatic index (HSI) than Dolly Varden captured in 2010 (Table 6.7.2-6). This difference was due to the significantly

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KITSAULT MINE PROJECT ENVIRONMENTAL ASSESSMENT FRESHWATER AQUATIC RESOURCES larger fish captured in 2009 than in 2010 and the residual correlation between HSI and fish weight even after liver weight was standardised by fish weight to calculate the HSI (Figure 6.7.2-13). The liver serves as a major storage site for glycogen and the HSI can, therefore, provide an indication of the nutritional state of the fish (Adams and McLean 1985). The increasing relationship between HSI and fish length indicates that liver weight increases faster than body weight as Lime Creek Dolly Varden grow and, therefore, the nutritional state of Dolly Varden increases as the grow.

Table 6.7.2-6: Mean Hepatosomatic Indices for Dolly Varden Captured in Lime Creek in 2009 and 2010

Hepatosomatic index Year n Average SE 2009 12 1.568 0.135 2010 5 0.621 0.164 Note: n – sample size; SE - standard error

1.5

1 y = 0.5478x - 2.0942 R² = 0.5153 0.5

0 0123456 -0.5

Ln Hepatosomatic Ln Hepatosomatic index -1

-1.5 Ln Weight (g)

Figure 6.7.2-13: Relationship Between Hepatosomatic Index and Body Weight for Dolly Varden Captured in Lime Creek in 2009 and 2010

Including all five female fish captured, female Dolly Varden had a significantly (p<0.05) higher gonadosomatic index than male Dolly Varden in 2009 (Table 6.7.2-7). This difference is even more pronounced (p<0.001) if the one immature female Dolly Varden

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KITSAULT MINE PROJECT ENVIRONMENTAL ASSESSMENT FRESHWATER AQUATIC RESOURCES captured in 2009 is removed from the comparison. This difference in GSI between sexes is not unexpected given that ovaries of spawning females are typically larger and heavier than testes of spawning males. As Figure 6.7.2-14 shows, even when gonad weight is standardised by body weight for the GSI, gonads of female Dolly Varden increase in weight faster than body weight significantly faster than males as they grow and mature. This shows the much higher energy input females put into reproduction than males.

Table 6.7.2-7: Mean Gonadosomatic Indices, by Sex, for Dolly Varden Captured in Lime Creek in 2009 and 2010

Gonadosomatic index Year Sex n Average SE 2009 Female 5a 9.846 2.199 Female 4b 11.949 0.828 Male 6 4.407 0.485 2010 Immature 4 3.883 1.412 Note: n – sample size; SE - standard error a includes one immature (140 mm) fish b excludes one immature (140 mm) fish

16 Male (n=6) 14 Female (n=5) y = 21.118x - 101.93 R² = 0.4922 12

10

8

6 y = 3.462x - 17.237 R² = 0.8667 4

Ln Gonadosomatic Ln Gonadosomatic index 2

0 5 5.2 5.4 5.6 5.8

Ln Length (mm)

Figure 6.7.2-14: Relationship Between Gonadosomatic Index and Body Length (mm) of Male and Female Dolly Varden Captured in Lime Creek in 2009

There was no significant (p>0.05) difference in gonadosomatic indices between Dolly Varden captured in 2009 and 2010. Such a result is somewhat surprising given that most fish captured in fall 2009 were adult spawners while all fish captured in summer 2010 were

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KITSAULT MINE PROJECT ENVIRONMENTAL ASSESSMENT FRESHWATER AQUATIC RESOURCES immature juveniles. This result can likely be partially explained by the relatively small sample sizes used in the comparison but may also be due to a larger proportion of female Dolly Varden included in the 2010 data (75%) than in the 2009 data (45%).

6.7.2.6.7 Life History Dolly Varden are known to exhibit three distinct life histories: 1) an anadromous form which spawns in their natal freshwater stream, spends the first 1 to 4 years rearing in freshwater, and then migrates to the ocean to grow and mature; 2) a resident stream form which conducts all of its life history requirements in freshwater streams; and 3) an adfluvial form which has the same general life history as the anadromous form but migrates downstream to lakes instead of to the ocean.

The difference in age, length, and maturity between the fish captured in fall 2009 and in summer 2010, coupled with the difference in diet between fish smaller or greater than 180 mm in 2009, indicates that there is a single anadromous population of Dolly Varden in Lime Creek. Mature adults of this population enter Lime Creek from the ocean in mid to late September. Spawning likely occurs at water temperatures near 6°C (McPhail 2007). Juvenile Dolly Varden appear to remain in Lime Creek for one to three years with the majority of juveniles appearing to leave Lime Creek by their third summer.

In watersheds without accessible lakes (such as the Lime Creek watershed), adult Dolly Varden emigrate from their natal streams after spawning, re-enter the ocean, and either overwinter in the ocean or in freshwater lakes in nearby watersheds (Armstrong 1970 and 1974; Bernard et al., 1995). Once a Dolly Varden selects a lacustrine watershed (i.e., a watershed with accessible lakes), they continue to use that watershed as their freshwater, winter habitat (Bernard et al..,1995); in their study, Bernard et al. (1995) found very little straying (<2% of tagged fish) of tagged fish between watersheds in different years. While the number of accessible lakes in other watersheds within the Alice Arm, Hastings Arm, and Observatory Inlet areas is unknown and maybe low given the steep topography in the area, post-spawn Dolly Varden from Lime Creek must overwinter in these lakes or in the ocean, most likely within Alice Arm, as the pools in lower Lime Creek which provide overwintering habitat for juvenile Dolly Varden are too small to provide overwintering habitat for adults.

Although numbers of returning adults observed or captured in fall were limited, it appears that Dolly Varden in Lime Creek first reach sexual maturity at 3 years of age with all fish reaching sexual maturity in their fourth year (Table 6.7.2-4). Similar growth and maturity rates have been observed in Keogh River Dolly Varden on Vancouver Island (Smith and Slaney, 1980).

6.7.2.6.8 Tissue Residual Metals Mean total mercury concentration in juvenile (<180 mm) Dolly Varden in lower Lime Creek (0.041 mg/Kg) was lower than the Canadian Action Level guideline for the protection of human health (0.5 mg/kg; CFIA 2009) (Table 6.7.2-8). None of the fish captured had total mercury concentrations higher than this guideline. However, the mean total mercury

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KITSAULT MINE PROJECT ENVIRONMENTAL ASSESSMENT FRESHWATER AQUATIC RESOURCES concentration in these 14 fish was greater than the provincial and federal screening value for the protection of piscivorous wildlife (0.033 mg/kg; BC MOE 2001a; CCME 2000). Only two individual juvenile Dolly Varden had total mercury concentrations lower than this guideline.

Mean total mercury concentration in adult (>180 mm) Dolly Varden in lower Lime Creek (0.054 mg/Kg) was lower than the Canadian Action Level guideline for the protection of human health (0.5 mg/Kg; CFIA 2009) (Table 6.7.2-9). None of the fish captured had total mercury concentrations higher than this guideline. However, the mean total mercury concentration in these eight fish was greater than the provincial screening value for the protection of piscivorous wildlife (0.033 mg/Kg; BC MOE 2001a; CCME 2000). Only two individual adult Dolly Varden had total mercury concentrations lower than this guideline. Based on these data, mercury in juvenile and adult Dolly Varden in lower Lime Creek may be a chemical of concern for the health of piscivorous wildlife under current baseline conditions.

The provincial guideline for the protection of piscivorous wildlife is based on the Canadian Council of Ministers of Environment (CCME 2000) guidelines for methlymercury, the form of mercury that poses the greatest risk to aquatic biota, wildlife and human because of its tendency to bioaccumulate (USEPA 1997a, b). Although mean, minimum and maximum total mercury concentrations are presented for Dolly Varden captured in Lime Creek, methylmercury contributes at least 90% of the total mercury concentration values in fish tissues and other aquatic biota (Rai et al., 2002, Lasorsa and Allen-Gil, 1995), so the comparison to this guideline is appropriate.

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Table 6.7.2-8: Metal Concentrations in Juvenile Dolly Varden Muscle Tissue

Screening Value for Protection of Screening Value for Protection of Metal Frequency of Detection Mean Standard Error Minimum Maximum Human Health Piscivorous Wildlife Aluminum 0/14 1.0 0.0 1.0 1.0 n/a n/a Antimony 0/14 0.005 0.000 0.005 0.005 n/a n/a Arsenic 14/14 0.055 0.011 0.022 0.194 n/a n/a Barium 14/14 0.033 0.005 0.013 0.077 n/a n/a Beryllium 0/14 0.05 0.00 0.05 0.05 n/a n/a Bismuth 0/14 0.015 0.000 0.015 0.015 n/a n/a Cadmium 14/14 0.085 0.017 0.007 0.185 n/a n/a Calcium 14/14 290 20 150 404 n/a n/a Chromium 4/14 0.1 0.1 0.1 0.5 n/a n/a Cobalt 13/14 0.069 0.012 0.010 0.181 n/a n/a Copper 14/14 0.6 0.1 0.4 1.4 n/a n/a Iron 4/4 5.3 0.6 0.0 6.9 n/a n/a Lead 0/14 0.010 0.000 0.010 0.010 n/a n/a Lithium 0/14 0.050 0.000 0.050 0.050 n/a n/a Magnesium 14/14 242 13 181 320 n/a n/a Manganese 14/14 0.257 0.032 0.136 0.605 n/a n/a Mercury 14/14 0.041 0.003 0.027 0.063 0.5c 0.033a Molybdenum 7/14 0.013 0.004 0.005 0.038 n/a n/a Nickel 5/14 0.106 0.039 0.050 0.270 n/a n/a Phosphorus 4/4 2,650 27 0 2,690 n/a n/a Potassium 4/4 4,518 72 0 4,660 n/a n/a Selenium 14/14 0.67 0.03 0.51 0.89 n/a 1.0b Silver 0/14 0.005 0.000 0.005 0.005 n/a n/a Sodium 4/4 340 30 0 399 n/a n/a Strontium 14/14 0.68 0.1 0.2 1.1 n/a n/a Sulfur 4/4 2,258 15 0 2,300 n/a n/a Thallium 3/14 0.007 0.002 0.005 0.016 n/a n/a Tin 4/14 0.044 0.016 0.025 0.101 n/a n/a Titanium 0/4 0.05 0.00 0.000 0.050 n/a n/a Uranium 0/14 0.001 0.000 0.001 0.001 n/a n/a Vanadium 0/14 0.050 0.000 0.050 0.050 n/a n/a Zinc 14/14 12.4 1.1 6.4 18.2 n/a n/a Note: All metal concentrations are in milligrams of total metal per kilogram of wet weight fish tissue (mg/kg ww muscle filet); n/a - not applicable (no published Canadian screening value exists); Descriptive statistics were calculated using metal concentration data for juvenile (<180 mm) Dolly Varden with a mean (± 1 SE) length of 128 ± 7.9 mm and mean weight of 27 ± 4.0 g; Grey highlights represent chemical that may be of potential concern to the health of piscivorous wildlife. Refer to Section 6.12 for discussion of potential ecological health risks. n/a - not applicable Source: a BC MOE guideline for methylmercury (BC MOE 2001a, based on CCME 2000); b BC MOE guideline for total selenium (BC MOE 2001b), c Canadian Action Level for contaminants in fish and fish products (CFIA 2009)

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Table 6.7.2-9: Metal Concentrations in Adult Dolly Varden Muscle Tissue

Screening Value for Protection of Screening Value for Protection of Metal Frequency of Detection Mean Standard Error Minimum Maximum Human Health Piscivorous Wildlife Aluminum 0/8 1 0 1 1 n/a n/a Antimony 1/8 0.006 0.001 0.005 0.011 n/a n/a Arsenic 8/8 0.073 0.024 0.037 0.242 n/a n/a Barium 8/8 0.058 0.025 0.024 0.234 n/a n/a Beryllium 0/8 0.05 0.00 0.05 0.05 n/a n/a Bismuth 0/8 0.015 0.00 0.015 0.015 n/a n/a Cadmium 6/8 0.006 0.001 0.003 0.010 n/a n/a Calcium 8/8 221 35 90 375 n/a n/a Chromium 4/8 0.28 0.18 0.05 1.55 n/a n/a Cobalt 4/8 0.017 0.003 0.010 0.025 n/a n/a Copper 8/8 0.535 0.030 0.412 0.663 n/a n/a Iron 8/8 6.95 0.88 4.75 12.80 n/a n/a Lead 0/8 0.01 0 0.01 0.01 n/a n/a Lithium 0/8 0.05 0.00 0.05 0.05 n/a n/a Magnesium 8/8 306 5 291 330 n/a n/a Manganese 8/8 0.191 0.012 0.141 0.242 n/a n/a c a Mercury 8/8 0.054 0.009 0.010 0.077 0.5 0.033 Molybdenum 2/8 0.016 0.008 0.005 0.065 n/a n/a Nickel 1/8 0.15 0.10 0.05 0.83 n/a n/a Phosphorus 8/8 2,670 42 2,510 2,890 n/a n/a Potassium 8/8 4,744 70 4,410 5,050 n/a n/a b Selenium 8/8 0.723 0.070 0.410 0.905 n/a 1.0 Silver 0/8 0.005 0.000 0.005 0.005 n/a n/a Sodium 8/8 291 13 238 341 n/a n/a Strontium 8/8 0.432 0.079 0.168 0.768 n/a n/a Sulfur 8/8 2,186 35 2,050 2,360 n/a n/a Thallium 6/8 0.011 0.001 0.005 0.016 n/a n/a Tin 0/8 0.025 0.000 0.025 0.025 n/a n/a Titanium 0/8 0.05 0.00 0.05 0.05 n/a n/a Uranium 0/8 0.001 0.000 0.001 0.001 n/a n/a Vanadium 0/8 0.05 0.00 0.05 0.05 n/a n/a Zinc 8/8 5.5 0.3 4.7 7.5 n/a n/a Note: All metal concentrations are in milligrams of total metal per kilogram of wet weight fish tissue (mg/kg ww muscle filet); n/a - not applicable (no published Canadian screening value exists); Descriptive statistics were calculated using metal concentration data for adult (>180 mm) Dolly Varden with a mean (± 1 SE) length of 218 mm ± 11 mm and mean weight of 119 g ± 19 g; Grey highlights represent chemical that may be of potential concern to the health of piscivorous wildlife. Refer to Section 6.12 for discussion of potential ecological health risks. n/a - not applicable Source: a BC MOE guideline for methylmercury (BC MOE 2001a, based on CCME 2000); b BC MOE guideline for total selenium (BC MOE 2001b), c Canadian Action Level for contaminants in fish and fish products (CFIA 2009)

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Mean total selenium concentration in juvenile Dolly Varden in lower Lime Creek (0.7 mg/Kg) was lower than the BC MOE guideline for the protection of piscivorous wildlife (1.0 mg/Kg; BC MOE 2001b) (Table 6.7.2-8). No individual juvenile Dolly Varden had a total selenium concentration above this guideline. Similarly, mean total selenium concentration in adult Dolly Varden in lower Lime Creek (0.7 mg/Kg) was lower than the BC MOE guideline for the protection of piscivorous wildlife (1.0 mg/Kg; BC MOE 2001b) (Table 6.7.2-9). No individual adult Dolly Varden had a total selenium concentration above this guideline.

A summary of mean metal concentrations and significant differences in juvenile and adult Dolly Varden muscle tissues from Lime Creek are presented in Table 6.7.2-10. Metals are not listed in this table if they were not detected in at least one fish from either of the adult or juveniles size classes.

Of the ten metals with significance differences between the mean concentrations in juvenile and adult Dolly Varden, all ten were significantly higher in juvenile Dolly Varden muscle tissue than in adult Dolly Varden muscle tissue. These include significantly higher concentrations of cadmium, calcium, cobalt, copper, manganese, sodium, strontium, sulfur, tin, and zinc in juvenile Dolly Varden than in adult Dolly Varden.

Table 6.7.2-10: Test for Significance Differences in Mean Metal Concentrations between Adult and Juvenile Dolly Varden Muscle Tissue in Lower Lime Creek

Juvenile Significance Parameter Adult Concentrations Concentrations (p-value) Arsenic 0.073 0.055 n.s. Barium 0.058 0.033 n.s. Cadmium 0.006 0.085 <0.001 Calcium 221 290 0.005 Chromium 0.28 0.1 n.s. Cobalt 0.017 0.069 <0.001 Copper 0.535 0.6 0.03 Iron 6.95 5.3 n.s. Magnesium 306 242 n.s. Manganese 0.191 0.257 0.001 Mercury 0.054 0.041 n.s. Molybdenum 0.016 0.013 n.s. Nickel 0.15 0.106 n.s. Phosphorus 2,670 2,650 n.s. Potassium 4,744 4,518 n.s. Selenium 0.723 0.67 n.s. Sodium 291 340 0.04 Strontium 0.432 0.68 <0.001

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Juvenile Significance Parameter Adult Concentrations Concentrations (p-value) Sulfur 2,186 2,258 0.004 Thallium 0.011 0.007 n.s. Tin 0.025a 0.044 <0.001 Zinc 5.5 12.4 <0.001 Note: a Not detected in any of the eight adult Dolly Varden sampled in 2009. Mean tin concentration represents half of the laboratory detection limit All metal concentrations are in milligrams of total metal per kilogram of wet weight fish tissue (mg/kg ww muscle filet) Grey highlights represent significant differences; n.s. – non-significant; p-value – probability that the test statistic (observed t-value) is greater than the critical t-value (tabulated value)

6.7.2.7 Cultural, Ecological or Community Knowledge

The Kitsault Project is within the Nass Area and the Nass Wildlife Area (NWA) as defined by the Nisga’a Final Agreement (NFA). The Nisga’a Nation has a right to harvest fish within the Nass Area for domestic, ceremonial, and cultural purposes within limits of conservation, health, and safety measures. While the NFA does not specifically indicate or determine allocations for Dolly Varden, the species is of importance to the Nisga’a Nation. Dolly Varden are tagged at various Nisga’a fish wheels for purposes of monitoring and management. Additional information on Nisga’a fish rights and management are provided in Part C (Sections 13) of the Kitsault EA Application.

Schedule D of Chapter 9 in the NFA designates rivers for Nisga’a guide angling activities. Although salmon, halibut, and steelhead are the principle target fish species for guides and their clients, Dolly Varden would be considered desirably by-fish. Dolly Varden in two of the 15 designated rivers proximate to the mine site are important to the Nisga’a Nation because of guiding entitlements in the NFA. These rivers include the Kitsault River and the Illiance River.

There are five potentially affected Aboriginal groups that have interests in harvesting and managing Dolly Varden, including Metlakatla First Nation, Kitsumkalum First Nation, Kitselas First Nation, Gitanyow Hereditary Chiefs and Gitxsan Chiefs. Metlakatla First Nation has an asserted territory that overlaps with the Kitsault mine site; whereas the other four Aboriginal groups overlap with the Kitsault transportation route, including Highway 37, Highway 113, and Nass Forest Service Road (FSR). Desk-based research of publicly available sources indicates the following specific Aboriginal interests related to Dolly Varden:

 Metlakatla First Nation: Desk-based research did not result in any specific information on Kitsumkalum interests related to Dolly Varden. Ongoing future consultation may provide additional information and understanding into their interests;

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 Kitselas First Nation has interests in fishing for Dolly Varden, which is important for subsistence, economic, and cultural purposes;  Kitsumkalum First Nation: Kitsumkalum Lake has a good Dolly Varden fishery. Kitsumkalum members fish for Dolly Varden as an important source of food;  Gitanyow Hereditary Chiefs have an interest in harvesting, preserving, and managing Dolly Varden. In particular, Gitanyow Fisheries Authority captures Dolly Varden in smolt fences along the migration to Kitwancool Lake, recording population numbers, length, and weight; and  Gitxsan Chiefs have and continue to participate in ice-fishing activities, primarily for steelhead, but also char, Dolly Varden, and whitefish.

6.7.2.8 Past, Present or Future Projects / Activities

Tables 6.7.2-11, 6.7.2-12 and 6.7.2-13 below present a review of the historical land use, present land use and reasonably foreseeable projects, respectively, which have been identified within the Dolly Varden CESA. This information was taken from the final Project Inclusion List for the cumulative effects assessment (CEA). These past, present, and reasonably foreseeable land use activities have been identified within the cumulative effects study area for Dolly Varden because they have the potential to overlap spatially or temporally with potential residual effects to Dolly Varden from the Kitsault Project. Potential cumulative effects of these other projects and activities outside of the immediate Lime Creek area are largely facilitated by the migratory behaviour of Dolly Varden once they reach the ocean and the amphidromous behaviour (i.e., migrations between salt and freshwater not associated with spawning) of juvenile Dolly Varden in British Columbia (Myers 1949 in McPhail 2007).

Table 6.7.2-11: Historical Land Use Activities in Biophysical Cumulative Effects Assessment Study Area

Project / Description Activity Kitsault Mine Exploration, which appears to have begun in the area in 1911, identified the and exploration presence of an orebody in late 1964. The mine was owned by B.C. Molybdenum, a subsidiary of KEL from 1963 to 1972 and by Climax Molybdenum Company of British Columbia (CMC) and affiliates from 1973 to 1998. Between January 1968 and April 1972, approximately 9.3 million tonnes of ore were produced with about 22.9 million pounds of molybdenum recovered. CMC returned the mine to production in 1981 but production was terminated again because of low metal prices in 1982.

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Project / Description Activity Kitsault Townsite The Kitsault Townsite, built in the 1970s and opened in 1981 to support the Kitsault Mine, was occupied for less than two years. The Kitsault Townsite, which is located approximately 5 km from the proposed Project, was purchased by Kitsault Resort Ltd. in 2005 and has been, and continues to be, maintained by caretakers. Alice Arm Booming mining town in the 1920s and 1930s until the nearby silver mine shut Townsite down. In the 1960s, workers commuted by boat from Alice Arm to work the neighboring mines. Townsite continues to be occupied year-round and includes a sport fishing lodge and homes used by seasonal residents. Illy Mine Operated from 1919-1923. High grade silver-lead-zinc mine located along the west bank of the Illiance River, located approximately 16 km northeast of Alice Arm upstream of impassable barrier in Iliance River location approximately 1.6 km upstream of Alice Arm. Macy Mine Macy Mine operated from 1916-1920. Silica mine located less than 10 km south of Alice Arm. Tidewater Mine Operated from 1916-1931. Molybdenum, silver, gold, lead, zinc, copper mine located approximately 3 km east of Alice Arm. Esperanza Mine Operated from 1911-1948. High grade silver ore with associated gold, copper and lead located approximately 1 km north of Alice Arm. Wolf Mine Operated sporadically from 1925-1953. High grade gold-silver-copper-lead-zinc located approximately 400 metres north-northwest of the centre of Alice Arm. Dolly Varden Located approximately 0.3 kilometres west of the Kitsault River, 22.5 kilometres Mine north of Alice Arm. The mine produced high-grade silver ore periodically between 1919 and 1940. One glory hole, is located 300 metres west of the Kitsault River, 22.5 kilometres north of Alice Arm. La Rose Mine Located on the east flank of Tsimstol Mountain west of the Kitsault River, approximately 9.75 kilometres north-northwest of Alice Arm. A few small shipments of high grade ore were made from this deposit between 1918 and 1927. North Star Adit portal is located on the west bank of the Kitsault River, 23 kilometres north of the town of Alice Arm. Between 1919 and 1921 a small tonnage of silver ore was mined from this deposit. Torbrit Located on the east bank of the Kitsault River, approximately 23.5 kilometres north of the town of Alice Arm. Between 1949 and 1959 Torbrit Silver Mines Ltd. produced 1,249,942 tonnes of ore containing silver, lead, zinc and gold. Anyox Slag Mine tailings from former Anyox copper mine and smelter deposited in Granby Heap Bay at the head of Observatory Inlet between 1914 and 1936 by Granby Consolidated Mining. Mine tailings cover approximately 51 acres of nearshore marine habitat and are thought to be the source of elevated copper, zinc, cadmium, and iron concentrations in the nearshore marine sediments. Past mine Tiger - The Tiger vein occurs 0.4 kilometres east of the Kitsault River, 24 exploration kilometres due north of the town of Alice Arm. This prospect has been extensively explored since 1916 for silver. Kitsol - Located on the west bank of the Kitsault River, 24 kilometres north of Alice Arm. The South Musketeer (103P 019), probably an extension of the Kitsol, lies just across the river on the east bank. The Kitsol prospect was extensively

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Project / Description Activity explored by Dolly Varden Mines in the early 1970s. Wolf - Lowermost portal, on the east side of the Kitsault River, 25.5 kilometres north of the town of Alice Arm. Extensive diamond drilling and underground development between 1960 and 1980 by various operators has defined moderate sized reserves of low grade silver-lead-zinc ore. Moose-climax - The Moose-Climax occurrence is situated 0.5 kilometres east of the Kitsault River, 26.5 kilometres north of the town of Alice Arm. This vein has been extensively explored since 1916 for its silver- lead-zinc mineralisation. Victory - Adit portal, 1.25 kilometres east of the Kitsault River, 27.5 kilometres north of the town of Alice Arm. Drilling between 1963 and 1975 has outlined moderate sized reserves of ore for this silver-bearing vein. Robin - Located along Blue Bird Creek in the Upper Kitsault Valley, 28.5 kilometres north of the town of Alice Arm. Zones containing argentiferous galena have been extensively explored by trenching and diamond drilling since 1918. Vangaurd Copper - located 500 metres southwest of Homestake Creek in the Upper Kitsault Valley, about 29 kilometres north of Alice Arm. A zone of copper mineralisation has been ex- tensively investigated, since 1916, by trenching and tunnelling. Sault - Located just south of Kitsault Lake, approximately 30.5 km north of Alice Arm. This zinc showing has been extensively investigated since its discovery in 1966. Note: B.C. - British Columbia; CMC - Climax Molybdenum Company of British Columbia; KEL - Kennco Exploration (Western) Ltd.

The historical land use with the greatest potential to cumulatively affect Dolly Varden is the past mining activities at the Kitsault Mine site. During the first mining operation, between 8 and 11 milllion tonnes of mine tailings were deposited directly into Lime Creek between 1963 and 1972. During the second mining operation, waste rock dumps were adjacent to Patsy Creek and in the upper headwaters of the Patsy Creek watershed. While the high discharge and energy of Lime Creek has likely removed all of these tailings from Lime Creek and deposited them in Alice Arm, any residual effects of this past deposition and any residual effects of the former waste rock dumps is reflected in the baseline characterisation of the Lime Creek Dolly Varden population presented in the Appendix 6.7-A and summarised in Section 6.7.2-6 above. Therefore, any past residual effects of the former Kitsault mine operations on Dolly Varden are automatically accounted for in the current baseline.

Construction of the Kitsault Townsite required the armouring and channelising of the lower 260 metres of Lime Creek. This effectively replaced the braided natural channels of the creek delta with a single, straight channel. While the effects of this habitat alteration on Dolly Varden are unknown, baseline characterisation of the Dolly Varden population summarised in Section 6.7.2-6 above is assumed to reflect any past residual effects of this channelisation on Dolly Varden.

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The town of Alice Arm is located directly across Alice Arm from the Town of Kitsault. The town is inhabited year-round and provides tourism and recreation operations for seasonal residents. There is no potential cumulative interaction between any residual effects of the Kitsault Project on Dolly Varden and any past, current, or future occupation of Alice Arm because any residual effects on the water quality, stream flows, or habitat used by Dolly Varden in the past, present or future are expected to be negligible (Table 6.7.2-14).

Previous mining operations have occurred in the Alice Arm area that have the potential to interact with Dolly Varden in combination with residual effects from the Kitsault Project. These include the former Illy Mine in the Illiance River watershed, the former Macy, Esperanza, Wolf, and Tidewater mines in the Alice Arm foreshore areas, the former La Rose, Dolly Varden, North Star, and Torbrit mines in the upper Kitsault River watershed, and the Anyox Slag Heap in Granby Bay at the head of Observatory Inlet. All of these former mines operated at least 40 years ago and most operated over 80 years ago. Because of their age, information on these past mines is limited. However, it is assumed that each of these mines may have residual effects on water quality in the streams draining their pits or waste rock areas that could result in cumulative effects on Dolly Varden; a potential cumulative interaction is possible (Table 6.7.2-14).

Extensive past mine exploration has occurred in the Alice Arm area. Most of these explorations occurred in the 1960s and 1970s but some, including the San Diego deposit in the Dak River watershed, have been drilled as late as 2003. Similar to past mines, it is assumed that these past exploration activities have potentially changed water quality in the watersheds in which they are located and, therefore, have the potential to cumulatively affect Dolly Varden; a potential cumulative interaction is possible (Table 6.7.2-14).

Table 6.7.2-12: Present Land Use Activities in Biophysical Cumulative Effects Assessment Study Area

Project / Activity Description

Transportation and access Within the CESA, Highways 113 and 37 are used by local residents and tourists as well as commercial / industrial traffic associated with activities such as exploration. The Nass Forest Service Road (FSR) and Alice Arm Road currently provides access to the Kitsault exploration camp and reclamation area, and access to the town of Kitsault and Alice Arm. Mining exploration Mining exploration activities are ongoing in the CESA. These include exploration of the Bell Moly and Roundy Creek Molybdenum deposits by The proponent and exploration of the Big Bulk, Clone, and Homestake Ridge deposits. A number of private claims are surrounded by The proponent’s Kitsault mineral tenure area.

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Project / Activity Description

Trapping and guide outfitting The proposed Project footprint falls within one trap line tenure area that is routinely used in the winter. The eastern section of the access road leading from Highway 37 falls within another trap line tenure area. The Land Use RSA (and Wildlife RSA) falls within the boundaries of one Guide Outfitter. Nisga’a Nation hunting, trapping, Nisga’a Nation has guiding entitlements in the Kitsault and fishing, and other uses Illiance Rivers under the Nisga’a Final Agreement. Aboriginal hunting, trapping, fishing and other uses Note: CESA - Cumulative Effects Study Area; FSR - Forest Service Road; RSA - Regional Study Area

Highway 37, the Nass FSR, and the Alice Arm Road currently provide access to lakes and streams known to support Dolly Varden, including Lime Creek where the Kitsault Project is located. However, none of these roads would be upgraded and no new roads would be built for the Kitsault Project that would increase access to Dolly Varden bearing streams. No potential cumulative interaction between existing transportation and access with the Kitsault Project exists (Table 6.7.2-14).

Exploration in the Bell Moly deposit in the Clary Creek watershed and exploration of the Roundy Creek deposit in the Roundy Creek watershed has the potential to alter water quality and stream flows that may cumulatively affect any Dolly Varden from Lime Creek that moves into these watersheds or into their estuaries to forage, rear, or spawn. Modern exploration operations must follow strict government permit requirements which include best management practices to reduce or eliminate potential effects to fish-bearing habitat downstream. Thus, an interaction is possible but this is not considered a key interaction (Table 6.7.2-14). Current exploration of the Big Bulk, Clone, and Homestake Ridge deposits are considered to have less potential to cumulatively effect Dolly Varden than exploration at the Bell Moly and Roundy deposits because of their greater distance from the Kitsault Project.

There is a potential cumulative interaction between residual effects of the Kitsault Project on Dolly Varden any residual effects from trapping or guide outfitting (Table 6.7.2-14). The Nisga’a Nation has angling guide tenures on the Illiance and Kitsault rivers under the NFA. Thus, a potential interaction exists because Dolly Varden from Lime Creek may move into either river and be captured by guided anglers. This would remove these fish from the pool of potential Lime Creek spawners. Conversely, any Dolly Varden captured by guided anglers in the Illiance and Kitsault Rivers would no longer be eligible to stray into Lime Creek to spawn. For similar reasons, a cumulative interaction is possible to Dolly Varden because of recreational fishing in the Alice Arm area by non-guided recreational fishermen (Table 6.7.2-14). Neither of these activities are considered a key interaction because

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KITSAULT MINE PROJECT ENVIRONMENTAL ASSESSMENT FRESHWATER AQUATIC RESOURCES salmon, halibut, and steelhead and not Dolly Varden are the primary target species of anglers fishing in Alice Arm and in the Illiance and Kitsault rivers.

Table 6.7.2-13: Reasonably Foreseeable Projects in Biophysical Cumulative Effects Assessment Study Area

Project / Activity Construction Operation Area and Rationale Northwest Spring 2011 - 2013 Unknown – with The Northwest transmission line is a Transmission routine 287 KV 335 km transmission line Line Project maintenance it between the Skeena substation would operate into (near Terrace) and Bob Quinn Lake. the foreseeable future Note: km - kilometre; kV - kilovolt

There are no potential interaction to Dolly Varden from residual effects from the Northwest Transmission Line Project and residual effects from the Kitsault Project. This is because the Northwest Transmission Line Project does not cross any watersheds draining into Alice Arm.

Although there are several hydropower projects proposed in the Alice Arm area (i.e., Alice Arm, Upper Kitsault Valley, and Kitsault River / Homestake Creek) available information indicates that these projects will not proceed in the reasonably foreseeable future. Therefore, these projects have not been included for consideration in the CEA.

Table 6.7.2-14 summarises potential interactions between Dolly Varden and historic, present, and reasonably foreseeable land use activities.

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Table 6.7.2-14: Assessment of Linkages between Other Projects,

Reasonably Representative Current and Future Varden Historical Land Use Foreseeable Land Use Projects

Freshwater Aquatic Resources VC Human Activities and Reasonable Foreseeable Projects with Dolly uses uses uses a’a Nation a’a Nation access access Project outfitting outfitting Northwest Northwest (on-going) (on-going) operations operations exploration exploration exploration exploration Previous mine Previous mine Nisg Kitsault Mine and Kitsault Townsite Townsite Kitsault fishing, and other fishing, and oterh fishing, and hunting, trapping, hunting, trapping, Transmission Line Transmission Mining exploration Mining exploration Alice Arm townsite townsite Alice Arm Transportation and Transportation Aboriginal hunting, Aboriginal hunting, Trapping and guide Trapping and Dolly Varden - - NI - o NI o o - o NI Note: Interaction definitions: o - interaction; - - key interaction; + - benefit; NI - no interaction

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6.7.2.9 Potential Effects of the Proposed Project and Proposed Mitigation

This section presents the likelihood that different Project components and activities would have a direct, indirect, or combined effect on Dolly Varden during the construction, operations, closure / decommissioning and post-closure phases of the Kitsault Project. It does so by:

 Identifying each potential direct, indirect, and combined effect that may occur to Dolly Varden during each phase of the Project;  Identifying any direct, indirect, or combined effects on Dolly Varden that may indirectly effect other Valued Components (e.g., human health), including other Freshwater Aquatic Resource VCs;  Identifying any potential direct, indirect, or combined effects on Dolly Varden that are eliminated through implementation of changes to the Project design; these potential effects are not carried forward in the assessment;  Identifying and rating the likelihood of mitigation measures that would be implemented to reduce or eliminate potential direct, indirect, or combined effects on Dolly Varden; potential effects where mitigation measures are determined to complete break the linkage between the Project component or activity and the VC are not carried forward in the assessment.

Those direct, indirect, and combined effects carried forward in the effects assessment are presented and rated for their significance to the health, growth, survival, and / or recruitment of Dolly Varden in Section 6.7.2.10.

6.7.2.9.1 Identification and Analysis of Potential Project Effects 6.7.2.9.1.1 Potential Direct Effects on Dolly Varden For the purposes of this assessment, direct effects to Dolly Varden were considered to occur from those Project components or activities that would result in the direct mortality of individual Dolly Varden or the direct loss of their habitat under the Project footprint. Based on this definition, there are only two potential direct effect of the Kitsault Project on Dolly Varden: 1) blasting within the Kitsault Pit and 2) increased fishing pressure due to the presence of anglers within the Kitsault mine workforce (Table 6.7.2-15).

No other direct effects of the Kitsault Project on Dolly Varden would occur during any phase of the project. This is because Dolly Varden are located only in the lower 1.6 kilometers of Lime Creek downstream of the impassable waterfalls while the Project footprint is located in the non-fish-bearing headwaters of Lime Creek within the Patsy Creek watershed. For this reason, none of the other Project components or activities required for the construction, operation, closure / decommissioning or post-closure of the Kitsault Project would result in the direct mortality of Dolly Varden or Dolly Varden eggs or result in the direct loss of habitat used by Dolly Varden for spawning, rearing, foraging, or overwintering.

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Table 6.7.2-15: Potential Direct Project Effects on Dolly Varden

Project Project Phase Potential Direct Project Effect Likelihood of Component Occurrence Blasting Construction, operations Potential increase in fish mortality Unlikely due to sound overpressures and increased particle velocities Firearms, Construction, operations, Potential increase in fishing pressure Likely fishing, and closure / due to presence of anglers in Kitsault hunting decommissioning, post- Mine workforce closure

6.7.2.9.1.1.1 Blasting The use of explosives has the potential to impact fish and fish eggs in two ways. First, detonation of explosives produces post-detonation compressive shock waves characterised by a rapid rise to a high peak pressure followed by a rapid decay to below ambient hydrostatic pressure (Wright and Hopky 1998). Overpressures greater than 100 kPa can result in rupture of internal organs of fish, particularly the swim-bladder, and the rupture of fish eggs (Wright 1982). Second, detonation of explosives increases peak acoustic particle velocities. Elevated peak acoustic particle velocities greater than 13 mm/sec can damage fish eggs in a spawning bed (Wright and Hopky 1998).

The likelihood of potential direct effects of blasting on Dolly Varden and their eggs during construction and operations in the Kitsault Pit is negligible (Table 6.7.2-15). This is because the distance between the Kitsault Pit where the blasting would occur and the habitat used by Dolly Varden in Lime Creek is at least two orders of magnitude greater than the setback distance guideline for the protection of fish from overpressure changes due to detonation of a 100 Kg charge in solid rock (50.3 metres) and at least 40 times the setback distance guideline for the protect of fish eggs from increased peak acoustic particle velocities from a similar sized detonation (150.9 metres) as outlined in the “Guidelines for the Use of Explosives in or near Canadian Fisheries Waters” (Wright and Hopky 1998).

The Kitsault Pit is located in the lower Patsy Creek watershed. In this location, the Kitsault Pit is approximately six kilometres upstream from the impassable waterfall in Lime Creek and, therefore, at least six kilometeres from habitat inhabited by Dolly Varden and used by Dolly Varden for spawning. Based on equations in Wright and Hopky (1998), the size of the charge needed to create overpressures greater than 100 kPa in Dolly Varden swimbladders and particle velocities greater than 13 mm/second in Dolly Varden spawning beds in lower Lime Creek would need to be 1.4 million kilograms and 158,000 kilograms, respectively. Charges of these sizes far exceed any that would be reasonably used for mining in the Kitsault Pit. For this reason, potential effects of blasting on Dolly Varden is not carried forward in this assessment.

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6.7.2.9.1.1.2 Firearms, Fishing, and Hunting The Kitsault Project would require a workforce of approximately 500 people during construction and a workforce of approximately 360 people during operations. Many of these people would be anglers wishing to fish for Dolly Varden or other fish species in the creeks and rivers in the vicinity of the Kitsault Project during their free time. Recreational anglers can have a significant impact on local fish populations (Radomski et al. 2001; Post et al. 2002; Lewin et al. 2006) and, if this fishing is unchecked, can lead to the extirpation of local populations even if fishing regulations are in place to protect the species or population. Although not every person in the workforce would be a recreational angler, some percentage would be and, given the number of people required to build and operate the mine and the relatively easy access to lower Lime Creek at the Town of Kitsault, the presence of these anglers could result in the direct mortality of individual Dolly Varden in Lime Creek and could potentially extirpate the local population over time. This potential direct effect is, therefore, carried forward in this assessment (Table 6.7.2-15).

Work-force sizes would decrease substantially during closure / decommissioning and post- closure / maintenance phases of the Project. However, there would still be more people on- site than at present and these people could continue to apply fishing pressure on Dolly Varden in Lime Creek, should the population persist. This potential effect is therefore carried forward for all Project phases.

6.7.2.9.1.2 Potential Indirect Effects on Dolly Varden For the purposes of this assessment, indirect effects to Dolly Varden were considered to occur from those Project components or activities that had the potential to indirectly affect the health, growth, survival or recruitment of Dolly Varden through direct Project effects to other VCs. The primary VCs through which indirect effects to Dolly Varden could occur are changes in surface water quality and hydrology (i.e., stream flows).

Indirect effects to Dolly Varden due to changes in surface water quality included direct effects from mine effluent discharge and seepage, changes in groundwater quality or quantity, and changes in air quality (e.g., dust deposition and contaminants from burning of fossil fuels). Indirect effects to Dolly Varden due to changes in hydrology included direct effects on stream flows due to changes in upstream catchment areas, diversion of streams, capture of run-off for use during operations or closure of the mine, and annual release of excess accumulated run-off.

Other potential indirect effects to Dolly Varden are also possible from direct Project effects on air quality, riparian vegetation, and wildlife (both those upon which Dolly Varden are known to feed and those whom are known to feed on Dolly Varden). All potential indirect effects on Dolly Varden were identified after review of the residual effects sections of the hydrology (Section 6.5), surface water quality (Section 6.6), vegetation (Section 6.10), atmospheric environment (Section 6.2), and wildlife (Section 6.11) effects assessments. Table 6.7.2-16 summarises all of the potential indirect effects of the Kitsault Project, before mitigation, on Dolly Varden during all phases of the Project.

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Table 6.7.2-16: Potential Indirect Project Effects on Dolly Varden

Project Likelihood of Project Component Potential Indirect Effect Phase Occurrence Land clearing, top-soil stripping, C Potential increase in suspended Likely and grading of land for mine solids in Lime Creek decreases infrastructure installations, ore growth and survival of Dolly stockpiles, and waste rock Varden and their eggs management facilities (WRMFs) Soil and till salvage, handling and C, O Potential increase in suspended Likely storage, including locations, solids in Lime Creek decreases volumes and impacted areas growth and survival of Dolly Varden and their eggs Emissions and dust generation C,O, Potential increase in suspended Unlikely (fugitive emissions, equipment D/C, solids in Lime Creek decrease operation and movement) PC growth and survival of Dolly Varden and their eggs Mine infrastructure installations C Potential increase in suspended Unlikely including processing plant, camp, solids in Lime Creek decrease equipment washing facility, and growth and survival of Dolly primary crusher, conveyor systems, Varden and their eggs and pipelines Pre-stripping of Kitsault Pit C Potential increase in suspended Likely solids and blasting residues in Lime Creek; potential change in stream flows in Lime Creek; potential decrease growth and survival of Dolly Varden and their eggs Development of south embankment C, O Potential increase in suspended Likely of Tailings Management Facility solids and potential decrease in (TMF) development stream flow in Lime Creek; potential decrease in growth and survival of Dolly Varden and their eggs Development of south water C Potential increase in suspended Likely management pond solids and potential decrease in discharge in Lime Creek; potential decrease in growth and survival of Dolly Varden and their eggs Coffer dams, sumps, pump C, O, Potential increase in suspended Likely systems, and diversion ditches D/C solids in Lime Creek; potential decrease in growth and survival of Dolly Varden and their eggs Water management including C, O, Potential change in water Likely dewatering, diversions, and D/C temperature and discharge in downstream discharges Lime Creek; potential decrease in growth and survival of Dolly Varden and their eggs Waste-water and sewage C, O, Potential change in water quality Likely

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Project Likelihood of Project Component Potential Indirect Effect Phase Occurrence management D/C of Lime Creek; potential decrease in growth and survival of Dolly Varden and their eggs East WRMF development and O, D/C Potential change in water quality, Likely reclamation water temperature, and discharge of Lime Creek; potential decrease in growth and survival of Dolly Varden and their eggs TMF development and reclamation O, D/C, Potential change in water quality, Likely PC water temperature, and discharge of Lime Creek; potential decrease in growth and survival of Dolly Varden and their eggs TMF seepage management and O, D/C, Potential change in water quality Likely reclamation PC of Lime Creek; potential decrease in growth and survival of Dolly Varden and their eggs Ore stockpiles development and O, D/C Potential change in water quality Likely reclamation of Lime Creek; potential decrease in growth, and survival of Dolly Varden and their eggs Surface water management and O, D/C, Potential change in water quality Likely diversion systems PC and discharge of Lime Creek; potential decrease in growth and survival of Dolly Varden and their eggs Groundwater management O, D/C, Potential change in water quality, Likely PC water temperature, and discharge of Lime Creek; potential decrease in growth and survival of Dolly Varden and their eggs Pit dewatering O Potential change in water quality Likely of Lime Creek; potential decrease in growth and survival of Dolly Varden and their eggs Storm-water run-off measures O Potential change in suspended Likely sediments and discharge of Lime Creek; potential decrease in growth and survival of Dolly Varden and their eggs TMF surplus and contact water O, D/C, Potential change in water quality Likely discharge (including blasting PC and water temperature of Lime residues) Creek; potential decrease in growth and survival of Dolly Varden and their eggs Metal Leaching and Acid Rock D/C, Potential change in water quality Likely Drainage (ML/ARD) management PC of Lime Creek; potential decrease in growth and survival of Dolly

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Project Likelihood of Project Component Potential Indirect Effect Phase Occurrence Varden and their eggs Decommissioning and removal of D/C Potential increase in suspended Likely all processing facilities, solids in Lime Creek; potential infrastructure, and ancillary facilities decrease in growth and survival of Dolly Varden and their eggs Kitsault Pit reclamation including D/C, Potential change in water quality, Likely Kitsault Pit re-filling and over-flow PC water temperature and discharge of Lime Creek; potential decrease in growth and survival of Dolly Varden and their eggs Surface water and groundwater D/C, Potential change in water quality, Likely management PC water temperature, and discharge of Lime Creek; potential decrease in growth and survival of Dolly Varden and their eggs Note: C - construction; D/C - decommissioning and closure; O - operations; TMF - Tailings Management Facility; PC - post-closure; WRMF - Waste Rock Management Facilities

Without mitigation, the only mine components or activities during construction, operation, closure / decommissioning phases unlikely to result in adverse effects on Dolly Varden in Lime Creek were: 1) emission and dust generation (during all phases of the Project); and 2) installation of mine infrastructure during the construction phase. These two mine activities are not carried forward in this assessment. All maintenance and monitoring activities scheduled to occur during the post-closure phase were also omitted from further assessment. The rationale for their exclusion is provided below.

6.7.2.9.1.2.1 Emissions and Dust Generation Emissions from burning of fossil fuels in trucks, shovels, and generators and dust generated from blasting, drilling, loading trucks, and driving machinery on mine roads would not affect Dolly Varden for two reasons. First, emissions such as SOx and NOx, which have the potential to create acidic conditions in freshwater, would not accumulate in Lime Creek. Lime Creek is a fast flowing stream and it would not have a headwater lake after construction (i.e., Patsy Lake would be covered by the TMF). Instead, any of these emissions falling onto the Lime Creek watershed would be quickly carried downstream to Alice Arm before having a opportunity to accumulate. Second, the sources of dust and emissions would all be located in the Patsy Creek watershed far above lower Lime Creek where Dolly Varden are found. It is highly unlikely that any of these emissions or dust would be deposited this far downstream, especially in the wet climate on the north coast of BC.

Mitigation measures such as use of low sulphur diesel fuel, regular maintenance of machinery, using a dust collection system during bulk materials loading and unloading, regular dust suppression on mine roads, and maintaining the operational supernatant pond

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KITSAULT MINE PROJECT ENVIRONMENTAL ASSESSMENT FRESHWATER AQUATIC RESOURCES in the TMF to ensure that tailings beaches are saturated (see Section 6.2, Atmospheric Environment) would all further reduce the likelihood of these effects on Dolly Varden.

6.7.2.9.1.2.2 Installation of Mine Infrastructure Installation of the mine infrastructure was considered unlikely to adversely affect Dolly Varden in Lime Creek. This was because it was assumed that these activities would involve physical disruption of land in the upper Lime Creek watershed. Instead, this activity was assumed to involve only the placement or removal of buildings, pipelines, and conveyors on the land. Clearing, excavating, or grading of the land prior to installation or removal of these infrastructure components was assumed to be the activity with the potential to impact Dolly Varden through changes in surface water quality due to potential increased suspended sediment loading. This activity was carried forward in the assessment but installation of mine infrastructure was not.

6.7.2.9.1.2.3 Post-Closure Monitoring and Maintenance None of the monitoring and maintenance activities during the post-closure phase of the project were carried forward in this assessment. This was because it was assumed that none of these activities would result in an adverse effect to Dolly Varden in Lime Creek. Instead, all of these activities were assumed to maintain or improve site conditions over time such that surface water quality and stream flows in Lime Creek would improve or would remain unchanged after closure of the mine. As a result, these activities were assumed to create no new effects to Dolly Varden and were instead considered only to be potential benefits to Dolly Varden in Lime Creek. These potential benefits were not assessed because of the uncertainty associated with assessing their effects this far forward into the future.

6.7.2.9.1.2.4 Other Project Components and Activities That Could Indirectly Affect Dolly Varden Through Changes to Surface Water Quality and Stream Flows in Lime Creek Besides emissions and dust generation, and installation and decommissioning of mine infrastructure, all other mine components and activities during construction, operations, closure / decommissioning phases of the Project were carried forward in this assessment. This was because, unmitigated, all of these other mine components and activities had the potential to indirectly affect Dolly Varden through:

 Direct changes to surface water quality in Lime Creek;  Direct changes to stream flow in Lime Creek;  Direct changes to water temperatures in Lime Creek; or  Direct changes to surface water quality, water temperatures, and stream flow in Lime Creek.

Although these components and activities were carried forward into the effects assessment, this does not imply that these mine components or activities would necessarily cause an

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KITSAULT MINE PROJECT ENVIRONMENTAL ASSESSMENT FRESHWATER AQUATIC RESOURCES adverse effect to Dolly Varden. It only implies that, without mitigation, these mine component and activities have the potential to adversely affect Dolly Varden. The likely effectiveness of the various mitigation measures available to minimise or eliminate these potential effects on Dolly Varden were assessed in Section 6.7.2.9. The significance of any residual effects to Dolly Varden were assessed in Section 6.7.2.10.

6.7.2.9.1.3 Potential Combined Effects Potential combined effects to Dolly Varden were considered those indirect effects that would occur simultaneously or through time in the same waterbody or stream to potentially change the growth, survival, health, and / or recruitment of Dolly Varden in Lime Creek. Table 6.7.2.17 summarises the potential combined effects on Dolly Varden due to potential indirect Project effects to surface water quality, stream flow, and water temperatures in Lime Creek, and the potential change in the benthic macro-invertebrate community which may result. Any change in the benthic macro-invertebrate community in Lime Creek has the potential to directly affect Dolly Varden because they are their primary food source. Such a change in prey would create the potential for a combined effect on Dolly Varden health, growth, survival and recruitment with concurrent effects on Dolly Varden due to changes in water quality, stream flow and water temperature.

Changes in surface water quality, stream flow, and water temperature in Lime Creek would be expected to occur simultaneously as the mine Water Management Plan was enacted. Any change in the benthic macro-invertebrate community would be expected to occur soon after (i.e., within weeks and months) these physical and chemical changes in Lime Creek occurred. Benthic macro-invertebrates are better indicators of stressors in the aquatic environment than fish and, therefore, any effects on benthic macro-invertebrate due to changes in water quality, stream flows, and water temperatures would likely occur well within the stream residency period of the anadromous Dolly Varden population in Lime Creek (i.e., 2 to 3 years).

Finally, a potential combined effect exists between the potential stressors placed on Dolly Varden due to changes in surface water quality, stream flows, water temperatures, and the benthic macro-invertebrate community in Lime Creek and the additional stressor placed on Dolly Varden due to increased fishing pressure. The abundance of Dolly Varden in Lime Creek may be reduced through all of these potential effects.

Table 6.7.2-17: Potential Combined Project Effects by Project Phase on Dolly Varden

Potential Indirect Project Project Likelihood of Potential Combined Project Effect Effect Phase Occurrence Change in surface water Change in Dolly Varden health, growth, C, O, Likely quality in Lime Creek survival and recruitment in Lime Creek due D/C, to combined effect with potential changes PC in stream flow, water temperatures, and resulting change in their benthic macro- invertebrate prey Change in stream flow in Change in Dolly Varden health, growth, C, O, Likely

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Potential Indirect Project Project Likelihood of Potential Combined Project Effect Effect Phase Occurrence Lime Creek survival and recruitment in Lime Creek due D/C, to combined effect with potential changes PC in surface water quality, water temperatures, and resulting change in their benthic macro-invertebrate prey Change in water Change in Dolly Varden health, growth, C, O, Likely temperature in Lime Creek survival and recruitment in Lime Creek due D/C, to combined effect with potential changes PC in stream flow, and resulting change in their benthic macro-invertebrate prey Change in benthic macro- Change in Dolly Varden health, growth, C, O, Likely invertebrate community in survival and recruitment in Lime Creek due D/C, Lime Creek to combined effect with potential changes PC in surface water quality, stream flow, and water temperatures Change in fishing pressure Change in the abundance of Dolly Varden C, O, Likely due to presence of work- in Lime Creek due to combined effect with D/C, force potential changes in surface water quality, PC stream flow, water temperature and benthic macro-invertebrate prey Note: C - construction; D/C - decommissioning and closure; O - operations; PC - post-closure

6.7.2.9.1.4 Potential Indirect Effects on Other Valued Components Potential direct, indirect, or combined effects on Dolly Varden have the potential to indirectly affect other Valued Components (Table 6.7.2-18). These include potential indirect effects on piscivorous wildlife that eat Dolly Varden (e.g., Grizzly bears, otters, or eagles), on marine biota that eat Dolly Varden (e.g., seals and sea-lions), on other Freshwater Aquatic Resource VCs (e.g., coho salmon and benthic macro-invertebrates) that co-exist with Dolly Varden in Lime Creek and on humans that harvest and eat Dolly Varden opportunistically as recreational fishermen. The potential effects identified in Table 6.7.2-18 represent those that could occur without considering the likely effectiveness of mitigation measures to reduce or eliminate them.

There is no potential interaction between potential changes in Dolly Varden health, growth, survival or recruitment with any other biophysical VC other than those identified and rationalised in Table 6.7.2-18. All other biophysical VCs (e.g., air quality, hydrogeology, soil and vegetation) have the potential to interact indirectly with Dolly Varden through changes in surface water quality and hydrology but the reverse linkage from Dolly Varden to these other VCs is not valid (e.g., changes in Dolly Varden health, growth, survival, and recruitment cannot affect air quality).

There is no potential interaction between potential changes in Dolly Varden health, growth, survival or recruitment with any other socio-economic VCs besides Nisga’a Nation Land Use. This is because, unlike salmon, Dolly Varden are not an economically valuable sport

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KITSAULT MINE PROJECT ENVIRONMENTAL ASSESSMENT FRESHWATER AQUATIC RESOURCES or commercial fish species in the Alice Arm area and because none of the identified Aboriginal groups are known to fish in Lime Creek, in Alice Arm, or in any other tributary to Alice Arm that Dolly Varden from Lime Creek may stray into. A summary of the potential interactions between potential direct, indirect, and combined effects of the Project on Dolly Varden and other biophysical and socio-economic VCs is provided in Table 6.7.2-19 below.

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Table 6.7.2-18: Potential Indirect Proj

Carried Direct Project, Indirect, or Forward Combined Effect (adverse or Project Phase Potential Indirect Project Effect Rationale positive) (yes / no) ect Effects on Other Valued Components Potential change in abundance of Construction, Change in the number of Dolly Yes Change in the number of Dolly Varden in Lime Dolly Varden in Lime Creek due to operations, Varden in Lime Creek may affect Creek has the potential to effect Nisga’a increased fishing pressure decommissioning, post- Nisga’a Nation Land Use guiding entitlements in the Kitsault and Illiance closure rivers. Potential change in health, growth, Construction, Change in tissue metal Yes Elevated tissue metal concentrations in Dolly survival and recruitment of Dolly operations, concentrations and size and Varden may increase despite commitment to Varden due to changes in water decommissioning, post- abundance of Dolly Varden in Lime meet water quality objectives throughout the quality, water temperature, and closure Creek may affect piscivorous mine life. Such increases may result in acute stream flow in Lime Creek wildlife and / or chronic toxicity to piscivorous wildlife, especially for those metals known to bioaccumulate in higher trophic levels (e.g., mercury). Reduced size and abundance of Dolly Varden in Lime Creek may indirectly reduce the health, growth, survival and abundance of piscivorous wildlife that rely on Dolly Varden for all or part of their dietary needs. Change in the tissue metal Yes Elevated tissue metal concentrations may concentrations in Dolly Varden in increase despite commitment to meet water Lime Creek may affect human quality objectives throughout the mine life. health Such increases may result in acute and / or chronic toxicity humans, especially for those metals known to bioaccumulate in higher trophic levels (e.g., mercury). Change in the fish tissue metal Yes Elevated tissue metal concentrations may concentrations and size and increase despite commitment to meet water number of Dolly Varden in Lime quality objectives throughout the mine life. Creek may affect piscivorous Such increases may result in acute and / or marine biota chronic toxicity to marine biota that feed on Dolly Varden, especially for those metals known to bioaccumulate in higher trophic levels (e.g., mercury).

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Carried Direct Project, Indirect, or Forward Combined Effect (adverse or Project Phase Potential Indirect Project Effect Rationale positive) (yes / no) Change in the fish tissue metal Yes Elevated tissue metal concentrations may concentrations and size and increase despite commitment to meet water number of Dolly Varden in Lime quality objectives throughout the mine life. Creek may affect environmental Such increases may result in acute and / or health chronic toxicity in freshwater, marine, and terrestrial animals, especially for those metals known to bioaccumulate in higher trophic levels (e.g., mercury). Change in size and abundance of Yes Change in the health, size and abundance of Dolly Varden in Lime Creek may Dolly Varden has the potential to influence the affect other Freshwater Aquatic size and abundance of coho salmon which Resource VCs in Lime Creek (e.g., compete with Dolly Varden for food and space. coho salmon and benthic macro- Such a change may also influence the density, invertebrates) distribution, and community composition of benthic macro-invertebrates upon which Dolly Varden and coho salmon feed. Change in the fish tissue metal Yes Elevated tissue metal concentrations and concentrations and size and change in the size and number of Dolly Varden number of Dolly Varden in Lime in Lime Creek has the potential to effect Creek may affect Nisga’a Nation Nisga’a guiding entitlements in the Kitsault and Land Use Illiance rivers. Note: VC - Value Component

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Table 6.7.2-19: Summary of Potential In

Direct, Indirect, or Combined Project teraction Between Project Effects on Dolly Varden and Other Valued Components Use Use Social Health Health

Effect on Dolly Varden Habitat Change Change Heritage Heritage Land Use Land Use Resource Resource Economic Economic Terrestrial Terrestrial a’a Nation Land a’a Nation Marine Biota Marine Biota Environment Hydrogeology Hydrogeology Freshwater and Freshwater Sediment Quality Wildlife and Their Wildlife and Aboriginal Groups Aboriginal Groups Surface Hydrology Hydrology Surface Freshwater Aquatic Aquatic Freshwater Noise and Vibration Vibration Noise and Nisg Groundwater Quality Quality Groundwater Marine Water Quality Quality Marine Water Environmental Health Environmental Health Air Quality and Climate Potential change in health, NI NI NI NI NI NI - NI o NI - - NI NI NI - o NI growth, survival, recruitment, and abundance of Dolly Varden in Lime Creek Note: Interaction definitions: o - interaction; - - key interaction; + - benefit; NI - no interaction

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6.7.2.9.1.5 Potential Project Effects Carried Forward for Assessment A summary of the potential Project effects on Dolly Varden that were carried forward into the assessment is presented in Table 6.7.2-20. These include:

 The one potential direct Project effect on Dolly Varden (i.e., increased fishing);  All Project components and activities that, combined, have the potential to indirectly affect Dolly Varden by altering surface water quality in Lime Creek;  All Project components and activities that, combined, have the potential to indirectly affect Dolly Varden by altering stream flows in Lime Creek;  All Project components and activities that, combined, have the potential to indirectly affect Dolly Varden by altering water temperatures in Lime Creek; and  All Project components and activities that, combined, have the potential to indirectly affect Dolly Varden by altering the benthic macro-invertebrate community in Lime Creek.

Effects on Dolly Varden due to potential changes in surface water quality were assessed based on results from a surface water quality model that predicted metal, ion, cation, and nutrient concentrations in Lime Creek downstream of the waterfalls. Similarly, effects on Dolly Varden due to potential changes in stream flows were assessed based on results of a watershed model that predicted annual, monthly, peak instantaneous, and 7-day low flows at the same location. Both models incorporated all of the various mine activities and components that could potentially affect surface water quality and stream flow in Lime Creek during each phase of the Project (i.e., all activities, components, and mitigation measures included in the Project Water Management Plan). Thus, the assessment of potential changes in surface water quality and stream flow on Dolly Varden were based on the likelihood that predicted changes in water quality parameters and predicted changes in stream flow in lower Lime Creek would adversely affect Dolly Varden at specific points in time during the development of the Kitsault Project and not on the likelihood that any individual mine component or activity would adversely affect Dolly Varden in Lime Creek.

Because neither model explicitly linked any single mine component or activity to a predicted change in water quality or stream flow during any phase of the Project (e.g., increase in watershed area and re-filling of the Kitsault Pit during closure), neither could the explicit indirect effects of any single mine component or activity be linked to Dolly Varden. This did not limit the credibility or accuracy of the assessment on Dolly Varden but it did limit the ability of the assessment to explicitly identify which mine component or activity was most likely to the cause the predicted change in water quality or stream flow, and hence effect on Dolly Varden.

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Table 6.7.2-20: Summary of Potential Project Effects to be Carried Forward Into the Assessment for Dolly Varden

Adverse Effects / Positive Effects Project Direction Phase Firearms, hunting and fishing C, O, D/C, PC Negative Potential change in surface water quality in Lime Creek C, O, D/C, PC Negative Potential change in hydrology in Lime Creek C, O, D/C, PC Negative Potential change in water temperature in Lime Creek C, O, D/C, PC Negative/Positive Potential change in benthic macro-invertebrate community in Lime Creek C, O, D/C, PC Negative Note: C - construction; D/C - decommissioning and closure; O - operations; PC - post-closure

6.7.2.9.2 Mitigation Measures Mitigation measures to reduce or eliminate each of the potential direct, indirect, and combined effects of the Project on Dolly Varden in Lime Creek are described in the sections below. Potential effects and the measures that would be employed to mitigate these potential effects are presented by Project phase where appropriate.

6.7.2.9.2.1 Firearms, Hunting, and Fishing The Fish and Wildlife Branch of the Environmental Stewardship Division of the BC Ministry of Environment sets regional daily catch quotas, possession quotas, and annual catch quotas for sport fish species in British Columbia. In the Skeena Region where Lime Creek is located, there is no annual catch quota for Dolly Varden, the possession limit is twice the daily catch quota, and the daily catch quota is five trout / charr but no more than:

 One fish >50 cm;  Two fish from streams; and  Three Dolly Varden, bull trout, and lake trout combined.

This means that no more than two Dolly Varden could be harvested from Lime Creek by any one angler on any one day and that no angler could have more than four Dolly Varden in their possession at any given time. The only other recreational fishing regulation set by the province is that all anglers must use single, barbless hooks when fishing in streams within the Skeena Region boundaries.

Monitoring and enforcement of these regulations is the responsibility of the BC Fish and Wildlife Branch. However, given the limited resources of the department, the remoteness of Lime Creek in relation to the closest Ministry of Environment office in Terrace, and the number of potential anglers that could begin fishing for Dolly Varden in Lime Creek if and when the mine proceeds to construction and operations, it is unlikely that these regulations would protect the Lime Creek Dolly Varden population from extirpation. As a result, a no fishing policy would be enacted by The proponent for all workers and contractors while on- site. While poaching may still occur, this mitigation measure would effectively eliminate this

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6.7.2.9.2.2 Change in Surface Water Quality in Lime Creek Potential changes in surface water quality in Lime Creek may occur during all phases of the Kitsault Project (Table 6.5-2-20). The primary mitigation measures to eliminate or minimise these potential changes in Lime Creek surface water quality are: 1) implementation of the mine’s Water Management Plan; and 2) construction and operation of a water treatment facility during the post-closure phase if required. The Water Management Plan is presented in detail in Appendix 6.4-B. Details of the proposed water treatment facility are described in the Section 6.6.2.6 of the Surface Water Quality assessment.

The objective of the Water Management Plan is to manage water in a manner that provides sufficient water to support the milling process while mitigating environmental effects to downstream lakes and streams. To do this, the plan strives to:

 Maximise the diversion of clean non-contact water around project components;  Capture all run-off from disturbed areas (i.e., contact water) throughout the site; and  Maximise the recycling of process water between the TMF and mill.

These objectives are supported by strategies and specific design elements at all stages of the Project. Strategies included in the plan to mitigate changes in surface water quality in Lime Creek include:

 An operational water management strategy which includes: o Utilising water within the proposed Project area to the maximum practicable extent by collecting and managing site runoff from disturbed areas; o Maximising the recycling of process water; o Storing surplus water within the TMF for use in the milling process; and o Releasing accumulated surplus water in the TMF in excess of mill processing requirements to Lime Creek if it meets water quality objectives (WQOs).  A sediment and erosion control strategy which: o Minimises erosion in disturbed areas; o Prevents release of sediment laden water to receiving environments by the following types of activities:  Installing sediment controls prior to land disturbance;  Limiting land disturbance to the maximum extent practical;  Reducing water velocities across the ground;

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 Progressively rehabilitating disturbed land;  Ripping areas to promote infiltration;  Constructing appropriate sediment control devices such as collection and diversion ditches, holding ponds, sediment traps, and sediment basins;  Constructing surface drainage controls to intercept surface run-off; and  Restricting access to rehabilitated areas.

o Using Best Management Practices (BMPs) prior to, and during, construction activities  An Environmental Protection Strategy which: o Monitors groundwater quality to indicate when additional groundwater seepage recovery mechanisms are necessary; o Ensures the release of contact water to Lime Creek only if it meets WQOs; o A reclamation plan that strives to:  Return, where practical, all disturbed areas to acceptable land use and capability;  Return, where practical, all affected watercourses and catchment areas to their pre- mine condition, size, and routing;  Maintain long-term water quality in Lime Creek downstream of decommissioned operations;  Maintain long-term stability of engineered structures including the WRMFs, the Kitsault Pit and the TMF;  Maintain long-term stability of all exposed erodible surfaces; and  Maintain a self-sustaining vegetative cover on all disturbed or engineered structures.

Each of these strategies, and the specific design elements included in the Water Management Plan for their implementation, are summarised and are assessed for their likely effectiveness to eliminate or minimise changes in surface water quality, and hence potential effects on Dolly Varden, in Lime Creek. This was done by project phase in the sections below.

6.7.2.9.2.2.1 Construction Phase Increased suspended sediments and sedimentation in Lime Creek are the primary potential effect on surface water quality, and hence on the health, growth, survival, and recruitment of Dolly Varden, in Lime Creek during the construction phase. Such increases in suspended sediments would occur primarily due to:

 To clearing of land for mine infrastructure installations, ore stockpiles, the TMF, and the waste rock management facilities;

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 Pre-stripping of the Kitsault Pit;  Dewatering and development of the south embankment of the TMF; and  Preparing top-soil stockpile areas and placement and storage of top-soil in these areas.

Increased suspended sediments from these sources have the potential to directly and indirectly affect Dolly Varden in Lime Creek (Newcombe and Macdonald 1991; Birtwell 1999; Robertson et al., 2006). Increases in suspended sediments can directly affect Dolly Varden (and other fish species) by reducing respiration function (Berg and Northcote 1985), damaging gills (Sigler et al. 1984; Servizi and Martens 1987; Bergstedt and Bergersen 1997; Lake and Hinch 1999), reducing resistance to disease (Redding et al., 1987), inhibiting gas exchange and removal of toxic metabolites from eggs and larvae in spawning redds (Reiser and White 1988; Chapman 1988; Argent and Flebbe 1999), and decreasing foraging efficiency (Breitburg 1988; Reid et al., 1999; Sweka and Hartman 2001). Increases in suspended sediments can indirectly affect Dolly Varden (and other fish species) by reducing production or altering periphyton (Barko and Smart 1986; Lloyd et al., 1987) and benthic macro-invertebrate communities (Rosenberg and Meins 1978; Culp et al., 1986; Wood and Armitage 1997; Shaw and Richardson 2001)

Mitigation measures to eliminate or reduce potential increases in suspended sediments and other potential changes to surface water quality in Lime Creek during the construction phase of the Project are presented in Table 6.7.2-21 below.

Mitigation measures for the construction of the South Water Management Pond (SWMP), construction of coffer dams, pump systems and diversion ditches, and other aspects of the construction phase Water Management Plan are not included in this table because each of these Project components is itself a mitigation measure designed to eliminate or reduce effects on surface water quality during construction of other mine infrastructure (e.g., TMF embankments, top-soil storage facilities). Temporary erosion and sediment control features or “Best Management Practices” would be used during the implementation of these mitigation measures to eliminate potential downstream effects. These measures are expected to be highly successful in reducing increases in total suspended sediments in Lime Creek.

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Table 6.7.2-21: Potential Indirect Project Effects on Dolly Va

Project Effect Mitigation / Enhancement Measure Mitigation Success Rating During Construction Phase Potential increase in suspended solids in Implement erosion control measures such as diversion ditches, High prevention / reduction Lime Creek due land clearing, top-soil run-off collection ditches, sediment collection ponds around all stripping, and grading of land for mine areas to be disturbed prior to construction and before any infrastructure installations, ore stockpiles, earthworks proceed and waste rock management facilities Sediment collection pondrden built through downstream Changes of inPatsy Surface Waste Water Rock Quality Medium and prevention Mitigation / reductionMeas Dump prior to its movement from its current position for use as construction materials for the South Embankment of the TMF Potential increase in suspended solids in Implement erosion control measures such as diversion ditches, High prevention / reduction Lime Creek due soil and till salvage, run-off collection ditches, sediment control ponds around soil handling and storage and till salvage and storage areas prior to construction and before any earthworks proceed Potential increase in suspended solids Sediment control pond built within the Kitsault Pit footprint, Medium prevention / reduction and blasting residues in Lime Creek due down-gradient of the pre-stripping area ures pre-stripping of Kitsault Pit Pumping of water in sediment control pond to Patsy Creek (if it Medium prevention / reduction meets WQOs) or to the TMF if it is not Potential increase in suspended solids in Cofferdams and pumping systems built to store and divert non- High prevention / reduction Lime Creek due to development of the contact water from Patsy Creek around south embankment south embankment of the TMF footprint during dewatering Construction of a sediment control pond downstream of the High prevention / reduction south embankment prior to construction (Stage 1A) Construction of the South Diversion Channel along the southern High prevention / reduction part of the Patsy Creek catchment to divert non-contact water to Patsy Creek downstream of embankment construction area Pumping system installed to dewater the embankment footprint High prevention / reduction in case of large storm event Construction of the South Water Management Pond and Medium prevention / reduction pumping system downstream of the south embankment prior to construction (Stage 1B and 1C). Water would either be pumped back to the TMF or discharged to Patsy Creek via the Water Box Construction of Water Box to handle excess water in the TMF Medium prevention / reduction

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Project Effect Mitigation / Enhancement Measure Mitigation Success Rating prior to discharge to Patsy Creek Potential change in surface water quality Modular sewage treatment plant, sized for 700 persons, would High prevention / reduction due to waste-water and sewage treatment be installed for the construction camp Sewage treatment plant effluent discharged to TMF High prevention / reduction

Note: BOD - biochemical oxygen demand; NH3 - ammonia; WQOs - water quality objectives; TMF - Tailings Management Facility; TSS - total suspended solids

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6.7.2.9.2.2.2 Operations Phase Project components and activities that have the potential to alter surface water quality in Lime Creek during operations of the mine include:

 On-going pit dewatering and management of site contact water;  Collection and release of excess water in the TMF to Lime Creek;  Flooding of organic soils within TMF footprint (potential source of methlymercury);  Seepage from the south embankment of the TMF;  Seepage and contact water from ore stockpiles;  Groundwater seepage in the Kitsault Pit; and  Collection, treatment, and release of waste-water and sewage effluent

Mitigation measures to eliminate or reduce potential increases in suspended sediments and other potential changes to surface water quality (i.e., increases or decreases in dissolved metal concentrations and dissolved nutrient concentrations) in Lime Creek during the construction phase of the Project is presented in Table 6.7.2-22 below.

Mitigation measures for the operation and maintenance of coffer dams, pump systems and diversion ditches, and other aspects of the operations phase Water Management Plan (i.e., surface water management and diversion systems) are not included in this table because each of these Project components is itself a mitigation measure designed to eliminate or reduce effects on surface water quality during operations of other mine infrastructure (e.g., TMF embankments, top-soil storage facilities).

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Table 6.7.2-22: Potential Indirect Project Effects on Dolly Va

Project Effect Mitigation / Enhancement Measure Success Rating During Operations Phase Potential increase in suspended solids in Diversion ditches, run-off collection ditches, sediment control High prevention / reduction Lime Creek due soil and till salvage, ponds around soil and till salvage and storage areas handling and storage maintained throughout operations Potential increase in suspended solids in South Water Management Pond and pumping system Medium prevention / reduction Lime Creek due to development of the downstream of the southrden embankment through Changes is maintained in Surface Water Quality and Mitigation Meas south embankment of the TMF throughout operations. Water would either be pumped back to the TMF or discharged to Patsy Creek via the Water Box South Diversion Channel maintained to divert non-contact High prevention / reduction water to Patsy Creek downstream of embankment construction area Potential increase in suspended solids South Water Management Pond and pumping system Medium prevention / reduction and decrease in water quality in Lime downstream of the south embankment is maintained during Creek due to development of the East Years 1 to 13 of operations. Water would either be pumped WRMF back to the TMF or discharged to Patsy Creek via the Water ures Box South Water Management Pond decommissioned in Year 14 High prevention / reduction to allow run-off from East WRMF to fill Open Pit South Diversion Channel maintained to divert non-contact High prevention / reduction water to Patsy Creek downstream of East WRMF throughout operations Potential change in water quality due to Diversion ditches convey all water within the TMF catchment High prevention / reduction development of the TMF to the TMF All process water discharged to TMF High prevention / reduction Potential change in water quality due to Tailings beaches developed along embankments to create low Medium prevention / reduction TMF seepage management permeability zone to minimise seepage Low permeability core incorporated into the design of the Medium prevention / reduction starter dam for the South embankment South Water Management Pond and pumping system High prevention / reduction downstream of the south embankment is maintained throughout operations.

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Project Effect Mitigation / Enhancement Measure Success Rating Potential change in water quality due to Low Grade Stockpile (LGS) diversion ditches and sediment Medium prevention / reduction ore stockpile development control pond collect all contact water; pumps convey excess water to Water Box for release to Lime Creek or is pumped to TMF (Years 1 to 13 of operations) Run-off from LGS diverted to Open Pit during Years 14 to 16 High prevention / reduction of operations Ore in LGS would be processed and tailings placed in TMF; High prevention / reduction any waste rock would be placed in East WRMF or Kitsault Pit Potential change in water quality due to Pumping system conveys contact water to TMF or to holding Medium prevention / reduction Kitsault Pit dewatering tank before release to Lime Creek during Years 1 to 13 of operations Pumping system decommissioned in Year 14 of operations to High prevention / reduction allow Kitsault Pit to fill with water Patsy Creek Diversion Ditch built on upper bench of Kitsault High prevention / reduction Pit to convey non-contact run-off from South Diversion Ditch around Kitsault Pit to Lime Creek Potential change in surface water quality Groundwater collection and monitoring wells used to Medium prevention / reduction due to groundwater management determine if additional seepage recovery is necessary Depressurisation wells installed in open pit to improve stability Medium prevention / reduction of pit slopes; water from these wells would be pumped to the TMF or to a holding tank, mixed with other contact water and released to Lime Creek if it meets WQOs (Years 1 to 13 of operations) Groundwater used to fill Open Pit during Years 14 to 16 of High prevention / reduction operations Potential change in surface water quality The South Diversion Ditch and the Patsy Diversion Ditch are High prevention / reduction due to storm-water run-off measures designed for 1:200 year return period floods. The design for other diversion ditches would be developed in the detailed design phase to manage return period events consistent with their function All pumping systems designed to handle design storm events High prevention / reduction Crest elevation of south embankment of TMF designed to High prevention / reduction

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Project Effect Mitigation / Enhancement Measure Success Rating provide sufficient free-board to contain run-off from PMP storm assuming all diversion systems fail Emergency spillway in south embankment designed to handle Medium prevention / reduction run-off from design storm events over the entire upstream catchment Potential change in surface water quality Surplus water in TMF pumped to Water Box and released to Medium prevention / reduction due to TMF surplus and contact water Lime Creek during Years 1 to 13 of operations; dedicated discharge (including blasting residues) pump system in TMF allows variable pumping rates All contact water in Kitsault Pit collected in sediment control High prevention / reduction pond and pumped to TMF during Years 1 to 13 of operations Potential change in surface water quality Same as during construction phase High prevention / reduction due to waste-water and sewage treatment

Note: BOD - biochemical oxygen demand; LGS - low grade stockpile; NH3 - ammonia; PMP - Probable Maximum Precipitation; WQOs - water quality objectives; TMF - Tailings Management Facility; TSS - total suspended solids; WRMF - Waste Rock Management Facilities

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6.7.2.9.2.2.3 Closure / Decommissioning Phase Project components and activities that have the potential to alter surface water quality in Lime Creek during the closure / decommissioning phase of the mine include:

 Allowing the Kitsault Pit to fill with accumulated water from direct precipitation, groundwater inflows, East WRMF and LGS stockpile run-off;  Reclamation of the South TMF embankment;  Reclamation of the East WRMF;  Reclamation of Low Grade Stockpile; and  Maintenance of South Diversion, Patsy Creek Diversion, and South Water Management Pond.

The primary mitigation measures to reduce or eliminate change in surface water quality in Lime Creek during the closure / decommissioning phase are to maintain the south diversion channel and Patsy Creek diversion channel so that they continue to convey non-contact water from the upper catchment areas around the TMF, the East WRMF and the Kitsault Pit to Patsy Creek. Maintenance of these diversion channels extends the duration of the Kitsault Pit re-fill period from 5 years to approximately 17 years. However, the benefits of this mitigation measure to Dolly Varden (and other aquatic biota) in lower Lime Creek are the minimisation of flow reductions and the maximisation of Lime Creek’s capacity to dilute treated surplus water from the TMF discharged to Lime Creek via the Water Box.

Similarly important, maintenance of the South Water Management Pond during closure / decommissioning allows contact water from run-off from the East WRMF and seepage from the TMF to be collected and diverted to the Open Pit. Diversion of this contact water to the Pit reduces metals and nutrient loadings to Lime Creek during the closure / decommissioning period.

Mitigation measures to eliminate or reduce potential increases in suspended sediments and other potential changes to surface water quality (i.e., increases or decreases in dissolved metal concentrations and dissolved nutrient concentrations) in Lime Creek during the closure / decommissioning phase of the Project are presented in Table 6.7.2-23 below.

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Table 6.7.2-23: Potential Indirect Project Effects on Dolly Varden Through Changes in Surface Water Quality

Project Effect Mitigation / Enhancement Measure Success Rating During Closure / Decommissioning Phase Potential change in water quality due to South Water Management Pond and pumping system High prevention / reduction water management including dewatering, downstream of the south embankment is maintained during diversions, and downstream discharges closure. Water would continue to either be pumped back to the TMF or allowed to flow into the Kitsault Pit South Diversion Channel maintained during closure to divert High prevention / reduction non-contact water to Patsy Creek downstream of embankment construction area Patsy Creek Diversion Channel maintained to divert non- High prevention / reduction contact water to Patsy Creek downstream of Kitsault Pit Potential change in water quality in Lime Downstream slope of East WRMF would be re-sloped to 2:1, High prevention / reduction Creek due to reclamation of East WRMF covered with top-soil and growth medium and seeded with and Mitigation Measures native species Potential change in water quality in Lime Surplus water in TMF pumped to Water Box and released to Medium prevention / Creek due to reclamation of the TMF Lime Creek; dedicated pump system in TMF allows variable reduction pumping rates Selective discharge of scavenger tailings around the TMF to High prevention / reduction establish a final tailings beach that would facilitate surface water management and reclamation Potential change in water quality due to South Water Management Pond and pumping system High prevention / reduction TMF seepage management downstream of the south embankment is maintained during closure. Water would continue to either be pumped back to the TMF or allowed to flow into the Kitsault Pit Potential change in water quality due to Diversion ditches and sediment control pond decommissioned High prevention / reduction ore stockpile reclamation only after all ore in the LGS has been processed and all waste rock moved to East WRMF or Kitsault Pit Potential change in water quality due to No release of pit over-flow during closure / decommissioning High prevention / reduction Kitsault Pit reclamation including re-filling phase. All contact water from South Water Management and over-flow Pond contained within Pit

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Project Effect Mitigation / Enhancement Measure Success Rating Pit filled only with contact water; all non-contact water from High prevention / reduction upper Patsy Creek catchment diverted around Kitsault Pit to Patsy Creek downstream of Pit via South Diversion Channel and Patsy Creek Diversion Channel Potential change in water quality due to Groundwater allowed to accumulate in Kitsault Pit; no High prevention / reduction groundwater management groundwater released downstream during closure / decommissioning phase Potential change in water quality due to Surplus water in TMF pumped to Water Box and released to Medium prevention / TMF surplus and contact water discharge Lime Creek; dedicated pump system in TMF allows variable reduction (including blasting residues) pumping rates Potential change in water quality due to All Kitsault Pit contact water allowed to fill Kitsault Pit; no High prevention / reduction Metal Leaching and Acid Rock Drainage release of pit contact water during closure / decommissioning (ML/ARD) management phase Potential change in water quality due to All disturbed surfaces would be re-graded, capped with top- High prevention / reduction decommissioning and removal of all soil, fertilised and re-seeded with native species processing facilities, infrastructure, and Best Management Practices would be used during High prevention / reduction ancillary facilities reclamation of all disturbed surfaces Potential change in surface water quality Same as during construction and operations phase High prevention / reduction due to waste-water and sewage treatment Note: LGS - Low Grade Stockpile; ML/ARD - metal leaching /acid rock drainage; TMF - Tailings Management Facility; WRMF - Waste Rock Management Facility

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6.7.2.9.2.2.4 Post-Closure Phase Project components and activities that have the potential to alter surface water quality in Lime Creek during the post-closure phase of the mine include:

 Allowing the Kitsault Pit to over-flow to Lime Creek;  Decommissioning of the South Water Management Pond;  Decommissioning of all seepage collection pump-back systems;  Construction of a spillway in the South embankment of the TMF to allow TMF overflow to drain into the Kitsault Pit;  Potential Metal Leaching and Acid Rock (ML/ARD) drainage from the East WRMF and un-reclaimed upper benches of the Kitsault Pit; and  Decommissioning of the upper South Diversion Channel to allow run-off from the upper Patsy Creek catchment area to drain into the TMF.

The principle mitigation measure to eliminate or reduce potential changes in surface water quality in Lime Creek during the post-closure phase is implementation of the post-closure Water Management Plan. This plan is designed to divert all seepage, contact water, and any ML/ARD drainage that develops in the future to the end-pit lake within the Kitsault Pit. This Water Management Plan allows:

 All sediments and any metals bound to organic and inorganic particles to drop out of the water column and remain at the bottom of the lake for perpetuity;  There to be only one discharge point to Lime Creek; and  Monitoring of effluent discharge to determine if WQOs are being met.

As a contingency in the event that WQOs are not met at any time during the post-closure period, a Water Treatment Facility would be constructed and operated to remove any metals or nutrients in exceedence of WQOs. Details of this Water Treatment Facility are described in Section 6.6.2.6.2.2 of the Surface Water Quality assessment (Section 6.6).

Mitigation measures to eliminate or reduce potential increases in suspended sediments and other potential changes to surface water quality (i.e., increases or decreases in dissolved metal concentrations and dissolved nutrient concentrations) in Lime Creek during the closure / decommissioning phase of the Project are presented in Table 6.7.2-24 below.

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Table 6.7.2-24: Potential Indirect Project Effects on Dolly Va

Project Effect Mitigation / Enhancement Measure Success Rating During Post-closure Phase Potential change in water quality due to All contact water, TMF overflow, TMF seepage, groundwater Medium prevention / water management including dewatering, seepage, and ML/ARD drainage diverted to Kitsault Pit reduction diversions, and downstream discharges Upper portion of South Diversion Channel decommissioned to High prevention / reduction allow non-contact water to drain into TMF Lower portion of Southrden DiversionThrough ChannelChanges maintained in Surface for Water QualityHigh and prevention Mitigation / reductionMeas perpetuity to divert run-off around East WRMF to the Kitsault Pit Patsy Creek Diversion Channel decommissioned to divert non- High prevention / reduction contact water to the Kitsault Pit Potential change in water quality in Lime Spillway constructed in south embankment to allow TMF surplus Medium prevention / Creek due to reclamation of the TMF water to drain to Kitsault Pit reduction Potential change in water quality due to TMF South Water Management Pond and pumping system High prevention / reduction seepage management downstream of the south embankment is maintained until monitoring shows that WQOs can be attained. ures Potential change in water quality due to Spillway constructed in Kitsault Pit to allow discharge to Patsy Low prevention / reduction Kitsault Pit reclamation including re-filling Creek downstream of pit and over-flow Water treatment plant built if necessary to reduce concentrations High prevention / reduction of metals and nutrients that exceed WQOs Potential change in water quality due to Groundwater allowed to accumulate in Kitsault Pit Low prevention / reduction groundwater management Potential change in water quality due to TMF Spillway constructed in south embankment to allow TMF surplus Medium prevention / surplus and contact water discharge water to drain to Kitsault Pit reduction (including blasting residues) South Water Management Pond and pumping system High prevention / reduction downstream of the south embankment is maintained until monitoring shows that WQOs can be attained. Water treatment plant built if necessary to reduce concentrations High prevention / reduction of metals and nutrients that exceed WQOs

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Project Effect Mitigation / Enhancement Measure Success Rating Potential change in water quality due to All Kitsault Pit contact water captured in Kitsault Pit Medium prevention / Metal Leaching and Acid Rock Drainage reduction (ML/ARD) management Water treatment plant built if necessary to reduce concentrations High prevention / reduction of metals and nutrients that exceed WQOs Note: WQOs - site-specific water quality objectives; TMF - Tailings Management Facility; WRMF - Waste Rock Management Facility

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6.7.2.9.2.2.5 Surface Water Quality Model Results The likely effectiveness of the mitigation measures listed above to eliminate or reduce potential changes to surface water quality, and hence to reduce potential effects to Dolly Varden in Lime Creek, was determined by comparing surface water quality concentrations in lower Lime Creek predicted from a mass balance mixing model to provincial and federal water quality guidelines for the protection of aquatic life. Details of the mass balance mixing model are provided in Appendix 6.6-B of the Surface Water Quality assessment. In brief, this model incorporated, at all phases of the Project:

 Baseline surface water quality and groundwater quality source terms;  All predicted contaminant loading concentrations from all potential sources (e.g., Waste Rock Facilities, ore stockpiles, TMF, exposed Kitsault Pit surface) (SRK 2011);  All elements of the site water balance (Knight Piésold 2011,Appendix 6.4-A);  All potential changes to natural catchment areas and stream discharges; and  All Water Management Plan mitigation measures list above.

The model output included water quality predictions at four locations in the Lime Creek watershed: 1) within the TMF; 2) at the Patsy Creek discharge point; 3) in Lime Creek immediately downstream of the Patsy Creek confluence; and 4) in lower Lime Creek downstream of the impassable waterfall. Only water quality predictions in lower Lime Creek were relevant to the assessment of potential effects on Dolly Varden as these fish are only present in Lime Creek downstream of the impassable waterfalls.

Guidelines and standards for comparison with the model output at the lower Lime Creek node were as follows:

 BC MOE water quality guidelines (approved) for the protection of Fresh Water Aquatic Life (BC MOE 2006a, 2006b): o The Maximum Acceptable limits (Max); and o The 30 Day Average limits (30 Day Average);  BC MOE ambient aquatic life guideline for iron (BC MOE 2008);  BC MOE Water Quality Guidelines for Nitrogen (Nitrate, Nitrite, Ammonia) (BC MOE 2009); and  CCME (2007) guideline for the protection of aquatic life (freshwater).

Table 6.7.2-25 summarises these provincial and federal guidelines. Where specific guidelines are dependent on other water quality parameters (e.g., hardness, pH, temperature), guideline values for lower Lime Creek were calculated using equations provided in the relevant guideline and baseline water quality parameters documented during baseline water quality sampling in Lime Creek conducted in 2009 and 2010.

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Table 6.7.2-25: Summary of Provincial and Federal Water Quality Guidelines for the Protection of Freshwater Aquatic Life in Lower Lime Creek

BC Water Quality Guideline Canadian Environmental Parameter 30 day average (mg/L) Maximum (mg/L) Quality Guideline (mg/L) Chloride 150 600 Fluoride 0.3a Sulphate 100 Nitrate (as N) 31.3 13.0 Ammonia (total) 1.8 to 2.05b,c 6.98 to 23.1 b,c Aluminum 0.05b 0.1b 0.1b,g Antimony 0.02 0.005 Arsenic 0.005 0.005 Barium 5.0 Beryllium 0.0053 Boron 1.2 Cadmium 0.000023d 0.000023d Chromium III 0.0089 0.0089 Chromium VI 0.001 0.001 Cobalt 0.004 0.11 Copper 0.002/0.005/0.002/0.004e,f 0.008/0.014/0.073/0.12e,f 0.002/0.003/0.002/0.003e,f Iron (total) 1.0 Iron (dissolved) 0.35 0.3 Lead 0.005/0.008/0.005/0.007e,f 0.042/0.112/0.039/0.087e,f 0.002/0.004/0.002/0.003e,f Mercury 0.00002 0.000026 Molybdenum 1.0 2.0 0.073 Nickel 0.065d 0.065d Selenium 0.002 0.001 Silver 0.00005d 0.001d 0.0001 Thallium 0.0003 0.0008 Uranium 0.3 0.015 Vanadium 0.006 Zinc 0.008/0.036/0.008/0.019e,f 0.033/0.062/0.033/0.044e,f 0.03 Note: a assumed hardness of > 50 mg/L CaCO3; b assumed pH = 7; c assumed mid-winter and mid-summer temperatures of 1°C and 12°C, respectively; d assumed hardness of 65 mg/L CaCO3; e assumed mean hardness during construction, operations, closure, and post-closure of 59, 128, 56, and 105 mg/L CaCO3, respectively; f guideline reported in construction, operations, closure, and post-closure phases, respectively based on average hardness values for each phase; g total aluminum concentration

Based on the BC MoE 30-day average and maximum guidelines (2006, 2008 and 2009) and the CCME (2007) guidelines listed above, the following water quality parameters are predicted to exceed one, two, or all three of the guideline concentrations during the construction, operations, closure, and / or post-closure phases of the Project:

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 Fluoride;  Sulphate;  Aluminum;  Cadmium;  Chromium VI;  Copper;  Mercury;  Molybdenum;  Selenium; and  Zinc.

Table 6.7.2-26 summarises which parameter exceeds which provincial and / or federal water quality guideline for the protection of freshwater aquatic biota for each phase of the Project.

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Table 6.7.2-26: Summary of Predicted Exceedences of Provincial and Federal Water Quality Guidelines for the Protection of Fresh

Construction Operations Closure Post-closure Canadian Canadian Canadian BC WQG 30 Canadian BC WQG BC WQG 30 BC WQG BC WQG 30 BC WQG BC WQG BC WQG Environmental Parameter Environmental Environmental day Environmental 30 day day average Maximum day average Maximum Maximum Maximum Quality Quality Guideline Quality Guideline average Quality Guideline average (mg/L) (mg/L) (mg/L) (mg/L) (mg/L) (mg/L) Guideline (mg/L) (mg/L) (mg/L) (mg/L) (mg/L) (mg/L) Fluoride     Sulphate   Aluminum         Cadmium         Chromium VI         Copper       Lead Mercury     Molybdenum   water Aquatic Life in Lower Lime Creek  Selenium   Zinc    Note: BC WQG - British Columbia Water Quality Guideline

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Water quality predictions in lower Lime Creek during the construction phase were driven by the seepage through the construction material for the South Embankment (historic Patsy Waste Rock Dump) and runoff within the Open Pit disturbed catchment. Water quality in Lime Creek during the construction phase was characterised by low hardness (average of

59 mg/L CaCO3) and low total alkalinity (average of 25 mg/L CaCO3). During the construction phase, modelled water quality results for lower Lime Creek showed predicted exceedences of guidelines for:

 Aluminum (BC MOE 30-day average only);  Cadmium (BC MOE maximum and 95th percentile exceedence of CCME guidelines);  Chromium IV (BC MOE maximum and CCME guidelines);  Molybdenum (CCME guideline); and  Zinc (BC MOE 30-day average only).

Water quality predictions in Lower Lime Creek during the operations phase were driven by Open Pit dewatering, LGS seepage collection pond water, and surplus TMF water, which is in turn, driven predominantly by seepage through the waste rock. All modelled parameters followed an increasing trend through operations Years 1 through 13, with some parameters decreasing in Years 14 through 15, when the SWMP water is directed towards the Open Pit and the Open Pit is no longer being dewatered. During the Operations Phase, modelled water quality results for lower Lime Creek showed predicted exceedences of guidelines for:

 Fluoride (BC MOE maximum);  Sulphate (BC MOE maximum);  Aluminum (all three guidelines);  Cadmium (BC MOE maximum and 95th percentile exceedence of CCME guidelines);  Chromium IV (BC MOE maximum and CCME guidelines);  Copper (all three guidelines);  Mercury (BC MOE 30-day average and CCME guidelines);  Molybdenum (CCME guideline); and  Selenium (CCME guideline only).

Closure water quality predictions in Lime Creek were driven by TMF water quality. This was because all other mine contact water sources within the Lime Creek watershed were directed towards the Open Pit at this time. Conversely, TMF surplus water is directed to Lime Creek during this phase until the Open Pit is full. During the Closure Phase, modelled water quality results for lower Lime Creek showed predicted exceedences of guidelines for:

 Fluoride (BC MOE maximum only);

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 Aluminum (BC MOE 30-day average only);  Cadmium (BC MOE maximum and 95th percentile exceedence of CCME guideline);  Chromium IV (BC MOE maximum and CCME guideline);  Molybdenum (CCME guideline); and  Zinc (BC MOE 30-day average guideline only).

Post-closure water quality in Lime Creek is immediately loaded with water that has been accumulating in the Open Pit during closure. There is an initial peak in concentration of almost every modelled parameter which is directly linked to Open Pit water discharge. There is a rapid decrease in concentration over the first 13 years of post-closure as the water in the Open Pit reaches a new equilibrium and all parameters appear to completely stabilise by Year 23. During the Post-closure Phase, modelled water quality results for lower Lime Creek showed predicted exceedences of guidelines for:

 Fluoride (BC MOE maximum);  Sulphate (BC MOE maximum);  Aluminum (all three guidelines);  Cadmium (BC MOE maximum and 95th percentile exceedence of CCME guidelines);  Chromium IV (BC MOE maximum and CCME guidelines);  Copper (all three guidelines);  Mercury (BC MOE 30-day average and CCME guidelines);  Selenium (CCME guideline only); and  Zinc (BC MOE 30-day average only).

Each of these guideline exceedences in Lime Creek are created because there would be a release of mine effluent and / or mine contact water during all phases of the Project. While Project design has attempted to minimise the Project footprint and locate all project infrastructures in the Patsy Creek above fish-bearing waters in Lime Creek and while the Water Management Plan has attempted to capture and separate all contact water from non- contact water, annual precipitation at the Project site exceeds 2000 mm per year. Annual precipitation volumes of this magnitude causes the mine site water balance to operate with a water surplus in all years except during the closure phase when the Kitsault Pit is re-filling. During mine operations for example, this water surplus is predicted to be on the order of 10 Mm3 of water per year; this excess water necessitates a release of water from the site.

Predicted surface water quality exceedences of provincial and federal guidelines during all phases of the Project indicates that mitigation measures included in the Water Management Plan are insufficient to eliminate all potential effects to Dolly Varden due to changes in water quality in Lime Creek. Because the water quality model factored all loading sources,

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KITSAULT MINE PROJECT ENVIRONMENTAL ASSESSMENT FRESHWATER AQUATIC RESOURCES changes in watershed areas and diversions together, it did not allow the effectiveness of individual mitigation measures to be assessed separately. Regardless, the cumulative change in water quality in Lime Creek and its potential effects on Dolly Varden during all phases of the Project are carried forward to the residual effects assessment section below.

6.7.2.9.2.3 Change in Hydrology in Lime Creek Potential changes in hydrology in Lime Creek may occur during all phases of the Kitsault Project (Table 6.7-2-16). These potential changes would occur primarily due to: 1) changes to the upstream catchment areas; 2) capture of upstream catchment run-off in the TMF for start-up processing requirements and management of mine tailings; 3) diversion of streams; and 4) filling of the Kitsault Pit at closure. The primary mitigation measures to eliminate or minimise these potential changes in hydrology in Lime Creek are: 1) implementation of the mine’s Water Management Plan (Appendix 6.4-B; and 2) filling the Kitsault Pit over an extended period instead of filling the pit as quickly as possible (Appendix 6.5-C).

The objective of the Water Management Plan is to manage water in a manner that provides sufficient water to support the milling process while mitigating environmental effects to downstream lakes and streams. To minimise flow changes in Lime Creek, the plan includes an operational water management strategy that:

 Maximises the diversion of clean non-contact water around project components to Lime Creek during construction, operations, closure, and post-closure phases;  Maximises the recycling of process water between the TMF and mill during operations;  Releases accumulated surplus water in the TMF to Lime Creek if it meets water quality objectives (WQOs) during operations;  Fills the Kitsault Pit over a period of 15 to 17 years during closure to minimise the magnitude of flow reductions in lower Lime Creek by continuing to divert non-contact run-off from the upper Patsy Creek watershed around the TMF, East WRMF, and open pit to Lime Creek; and  Re-establishes stream flows in Lime Creek to near baseline conditions during post- closure by allowing all accumulated run-off in the Patsy Creek watershed to once again to report to Lime Creek.

The specific design elements included in the Water Management Plan are summarised and are assessed for their likely effectiveness to eliminate or minimise changes in stream flows, and hence potential effects on Dolly Varden, in Lime Creek. This was done by project phase in the sections below.

6.7.2.9.2.3.1 Construction Phase Potential changes in stream flows in lower Lime Creek during the construction phase occur primarily due to:

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 Dewatering and development of the south embankment of the TMF;  Installation of coffer dams, sumps, pump systems, and diversion ditches including development of the South Diversion Channel;  Development of the South Water Management Pond;  Dewatering of the Kitsault Pit during pre-stripping; and  Discharge of surplus water in the developing TMF to Lime Creek via the Water Box.

The primary mitigation measures to eliminate or reduce potential changes in stream flows in Lime Creek during the construction phase of the Project are:

 Construction and operation of coffer dams and pumping system to dewater and divert accumulated run-off around the south embankment footprint to Patsy Creek downstream;  Construction of the South Diversion Channel to divert non-contact water from the upper Patsy Creek catchment around the south embankment footprint;  Construction and operation of the South Water Management Pond and associated pumping systems downstream of the south embankment to capture and pump seepage from the south embankment back to the TMF or to Patsy Creek downstream;  Construction and operation of a sediment control pond and associated pumping system in the Kitsault Pit to capture and pump collected groundwater and run-off to Patsy Creek downstream; and  Construction and operation of a Water Box to collect and discharge surplus water in the TMF to Patsy Creek downstream.

An assessment of the likely effectiveness of mitigation measures that would be implemented to eliminate or reduce the potential effects of each of the Project component or activity that have the potential to effect stream flows in lower Lime Creek are presented in Table 6.7.2-27 below.

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Table 6.7.2-27: Potential Indirect Project Effects on Dolly Varden

Project Effect Mitigation / Enhancement Measure Mitigation Success Rating Measures During Construction Phase Potential change in hydrology in lower Lime Cofferdams and pumping systems built to store and divert non-contact High prevention / reduction Creek due to dewatering and development of the water from Patsy Creek around south embankment footprint to Lime Creek south embankment of the TMF during footprint dewatering Construction of the South Diversion Channel along the southern part of the High prevention / reduction Patsy Creek catchment to divert non-contact water to Patsy Creek downstream of embankment through construction Changes area in Hydrology in Lower Lime Creek and Mitigat Construction of the South Water Management Pond and pumping system Medium prevention / reduction downstream of the south embankment prior to construction (Stage 1B and 1C). Water would either be pumped back to the TMF or discharged to Patsy Creek via the Water Box Potential change in hydrology in lower Lime SWMP built prior to construction of the South embankment of the TMF. Medium prevention / reduction Creek due to development of the South Water Water would either be pumped back to the TMF discharged to Patsy Creek Management Pond (SWMP) via the Water Box Potential change in hydrology in lower Lime Sediment control pond built within the Kitsault Pit footprint, down-gradient of Medium prevention / reduction Creek due to pre-stripping of the Kitsault Pit the pre-stripping area. Water pumped to Patsy Creek if it meets WQOs or ion to the Water Box in the TMF Potential change in hydrology in lower Lime Excess water in the TMF pumped to Water Box prior to discharge to Patsy Medium prevention / reduction Creek due to water management including Creek dewatering, diversions, and downstream South Diversion Channel along the southern part of the Patsy Creek High prevention / reduction discharges catchment diverts non-contact water to Patsy Creek downstream of south embankment construction area Potential change in hydrology in lower Lime Coffer dams and pumping systems installed during Stage 1A of south High prevention / reduction Creek due to installation of coffer dams, sumps, embankment construction diverts run-off from upper Patsy Creek catchment pumping systems, and diversion ditches around south embankment footprint to Lime Creek South Diversion Channel along the southern part of the Patsy Creek High prevention / reduction catchment diverts non-contact water to Patsy Creek downstream of south embankment construction area Pumping system installed to dewater the embankment footprint in case of Medium prevention / reduction large storm event. Water pumped to Patsy Creek. Note: WQO - site-specific water quality objective; SWMP - South Water Management Pond; TMF - Tailings Management Facility

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6.7.2.9.2.3.2 Operations Phase Project components and activities that have the potential to alter hydrology in Lime Creek during the operations phase include:

 On-going pit dewatering;  On-going management of site contact water;  Storage of run-off from the upper Patsy Creek watershed in the TMF;  Release and potential treatment of excess water in the TMF to Lime Creek;  Management of seepage and contact water from ore stockpiles; and  Management of groundwater seepage in the Kitsault Pit.

The primary mitigation measures to eliminate or reduce potential changes in stream flows in Lime Creek during the operations phase of the Project are:

 Recycling of tailings supernantant water for mill processing requirements;  Maintenance of the South Diversion Channel to divert non-contact water from the upper Patsy Creek catchment around the south embankment and East WRMF to Patsy Creek downstream;  Construction and operations of the Patsy Creek Diversin Channel in the upper bench of the Kitsault Pit to convey non-contact run-off from the South Diversion Channel to Patsy Creek downstream;  Operation of the South Water Management Pond and associated pumping systems to capture and pump seepage from the south embankment back to the TMF or to Patsy Creek downstream;  Operation of a sediment control pond and associated pumping system in the Kitsault Pit to capture and pump collected groundwater and run-off to Patsy Creek downstream; and  Operation of the Water Box to collect and discharge surplus water in the TMF and run-off from the LGS to Patsy Creek downstream.

An assessment of the likely effectiveness of mitigation measures that would be implemented to eliminate or reduce the potential effects of each of the Project component or activity that have the potential to effect stream flows in lower Lime Creek are presented in Table 6.7.2-28 below.

Mitigation measures for the operation and maintenance of South Water Management Pond, pump systems and diversion ditches, and other aspects of the operations phase Water Management Plan (i.e., surface water management and diversion systems) are not included in this table because these Project components are themselves a mitigation measure

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Table 6.7.2-28: Potential Indirect Project Effects on Dolly Varden

Project Effect Mitigation / Enhancement Measure Success Rating Measures During Operations Phase Potential change in hydrology in Lime South Water Management Pond and pumping system downstream of Medium prevention / Creek due to development of the south the south embankment is maintained during Years 1 to 13 of reduction embankment of the TMF operations. Water would either be pumped back to the TMF or discharged to Patsy Creek via the Water Box South Water Management Pond decommissioned in Year 14 to allow Low prevention / reduction run-off from south embankment through and East Changes WRMF in to Hydrology fill Open Pit in Lower Lime Creek and Mitigat South Diversion Channel maintained to divert non-contact water to High prevention / reduction Patsy Creek downstream of embankment construction area via the Patsy Diversion Channel Potential change in hydrology in Lime As above As above Creek due to development of the East WRMF Potential change in hydrology in Lime Diversion ditches convey all water within the TMF catchment to the Low prevention / reduction Creek due to development and TMF ion operation of the TMF Recycling of TMF supernatant water to meet mill processing High prevention / reduction requirements Surplus water in TMF pumped to Water Box and released to Lime Medium prevention / Creek during Years 1 to 13 of operations; dedicated pump system in reduction TMF allows variable pumping rates Potential change in hydrology in Lime Low Grade Stockpile (LGS) diversion ditches and sediment control Medium prevention / Creek due to ore stockpile development pond collect all contact water; pumps convey excess water to Water reduction Box for release to Lime Creek or is pumped to TMF (Years 1 to 13 of operations) Run-off from LGS diverted to Open Pit during Years 14 to 16 of Low prevention / reduction operations Potential change in hydrology in Lime Pumping system conveys contact water to TMF or to holding tank Medium prevention / Creek due to Kitsault Pit dewatering before release to Lime Creek during Years 1 to 13 of operations reduction Pumping system decommissioned in Year 14 of operations to allow Low prevention / reduction Kitsault Pit to fill with water

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Project Effect Mitigation / Enhancement Measure Success Rating Patsy Creek Diversion Ditch built on upper bench of Kitsault Pit to High prevention / reduction convey non-contact run-off from South Diversion Ditch around Kitsault Pit to Lime Creek Potential change in hydrology in Lime Groundwater collection and monitoring wells used to determine if Medium prevention / Creek due to groundwater management additional seepage recovery is necessary reduction Depressurisation wells installed in open pit to improve stability of pit Low prevention / reduction slopes; water from these wells would be pumped to the TMF or to a holding tank, mixed with other contact water and released to Lime Creek if it meets WQOs (Years 1 to 13 of operations) Groundwater used to fill Open Pit during Years 14 to 16 of operations Low prevention / reduction Potential change in hydrology in Lime The South Diversion Ditch and the Patsy Diversion Ditch are designed High prevention / reduction Creek due to storm-water run-off for 1:200 year return period floods. The design for other diversion measures ditches would be developed in the detailed design phase to manage return period events consistent with their function All pumping systems designed to handle design storm events High prevention / reduction Crest elevation of south embankment of TMF designed to provide High prevention / reduction sufficient free-board to contain run-off from PMP storm assuming all diversion systems fail Emergency spillway in south embankment designed to handle run-off Medium prevention / from design flood events over the entire upstream catchment reduction Potential change in hydrology in Lime Surplus water in TMF pumped to Water Box and released to Lime Medium prevention / Creek due to TMF surplus and contact Creek during Years 1 to 13 of operations; dedicated pump system in reduction water discharge TMF allows variable pumping rates Surplus water in TMF pumped to Water Box and released to Lime Medium prevention / Creek during Years 14 to 16 of operations reduction All contact water in Kitsault Pit collected in sediment control pond and Low prevention / reduction pumped to TMF during Years 1 to 13 of operations Pumping system decommissioned in Year 14 of operations to allow Low prevention / reduction Kitsault Pit to fill with contact water Note: LGS - Low Grade Stockpile; TMF- Tailings Management Facility; WRMF - Waste Rock Management Facility; PMP - Probable Maximum Precipitation; WQO - site-specific water quality objective

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6.7.2.9.2.3.3 Closure / Decommissioning Phase The principle project activity that has the potential to alter hydrology in Lime Creek during the closure / decommissioning phase of the mine is the filling of the Kitsault Pit with water. Sources of water that would be used to fill the Kitsault Pit at closure include (Knight Piésold 2011):

 Direct precipitation into the pit;  Pit wall run-off;  Groundwater inflows within the pit;  Run-off from the undisturbed catchment surrounding and contributing to the pit;  Seepage and run-off from the south embankment of the TMF and East WRMF;  Seepage and run-off from the LGS stockpile.

The primary mitigation measure to reduce or eliminate changes in hydrology in Lime Creek during the closure / decommissioning phase is to extend the open pit filling period from a minimum possible filling period of 5 years if all upstream run-off was diverted to the open pit to a maximum possible filling period between 15 and 17 years by maintaining the South Diversion Channel and Patsy Creek Diversion Channel to continue conveying water downstream to Patsy Creek while the pit fills (Knight Piésold 2011). The potential benefits of this mitigation measure to Dolly Varden (and other aquatic biota) in lower Lime Creek are the minimisation of magnitude of potential flow reductions and the maximisation of Lime Creek’s capacity to dilute treated surplus water from the TMF discharged to Lime Creek via the Water Box. However, this mitigation measure would extend the period of potential flow alterations in lower Lime Creek by 10 to 12 years.

An assessment of the likely effectiveness of mitigation measures that would be implemented to eliminate or reduce the potential effects of each of the Project component or activity that have the potential to effect stream flows in lower Lime Creek are presented in Table 6.7.2-29 below.

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Table 6.7.2-29: Potential Indirect Project Effects on Dolly

Project Effect Mitigation / Enhancement Measure Success Rating Measures During Closure / Decommissioning Phase Potential change in hydrology in Lime Creek South Water Management Pond and pumping system Low prevention / reduction due to water management including downstream of the south embankment is maintained during dewatering, diversions, and downstream closure. Water would continue to either be pumped back to the discharges TMF or allowed to flow into the Kitsault Pit South DiversionVarden Channel through maintained Changes during in closure Hydrology to divert in Lowernon- LimeHigh Creek prevention / reduction contact water to Patsy Creek downstream of embankment construction area Patsy Creek Diversion Channel maintained to divert non-contact High prevention / reduction water to Patsy Creek downstream of Kitsault Pit Potential change in water quality due to Kitsault pit filled only with direct precipitation, groundwater Medium prevention / Kitsault Pit reclamation including re-filling seepage, run-off from surrounding catchment, seepage and run- reduction and over-flow off from the south embankment of the TMF and East WRMF and and Mitigation seepage and run-off from the LGS stockpile All contact water from South Water Management Pond diverted to Medium prevention / Pit reduction Non-contact water from upper Patsy Creek catchment diverted High prevention / reduction around Kitsault Pit to Patsy Creek downstream of Pit via South Diversion Channel and Patsy Creek Diversion Channel Potential change in hydrology in Lime Creek Groundwater allowed to accumulate in Kitsault Pit; no Low prevention / reduction due to groundwater management groundwater released downstream during closure / decommissioning phase Potential change in hydrology in Lime Creek Surplus water in TMF pumped to Water Box and released to Lime Medium prevention / due to TMF surplus and contact water Creek; dedicated pump system in TMF allows variable pumping reduction discharge rates Note: LGS - Low Grade Stockpile;TMF- Tailings Management Facility; WRMF - Waste Rock Management Facility

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6.7.2.9.2.3.4 Post-Closure Phase Once the Kitsault Pit has filled with water, all accumulated run-off and groundwater seepage from the reclaimed Patsy Creek watershed upstream of the pit, plus the additional run-off from the small portion of the Clary Creek watershed captured within the TMF footprint, would be conveyed to Lime Creek through a spillway channel in the pit’s downstream face. This is the principle mitigation measure designed to minimise potential changes in hydrology in lower Lime Creek during the Post-closure Phase. The objective of this water post-closure water management plan is to restore the magnitude, duration, frequency, and timing of stream flows in lower Lime Creek, as closely as possible, to pre-mine, baseline conditions.

Implementation of this post-closure water management plan involves the following specific design features:

 Construction of a spillway in the downstream face of the Kitsault Pit to allow the end- pit lake to overflow into Lime Creek;  Decommissioning the upper portion of the South Diversion Channel to allow run-off from the upper Patsy Creek catchment area to drain into the TMF;  Decommissioning the South Water Management Pond to allow seepage from the south embankment of the TMF and the East WRMF to drain into the Kitsault Pit;  Decommissioning all seepage collection pump-back systems; and  Construction of a spillway in the South embankment of the TMF to allow TMF overflow to drain into the Kitsault Pit.

An assessment of the likely effectiveness of the specific mitigation measures that would be implemented to eliminate or reduce the potential effects of each of these Project component or activities on stream flows in lower Lime Creek are presented in Table 6.7.2-30 below.

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Table 6.7.2-30: Potential Indirect Project Effects on Do

Project Effect Mitigation / Enhancement Measure Success Rating Measures During Post-closure Phase Potential change in hydrology in Lime Creek All contact water, TMF overflow, TMF seepage, groundwater High prevention / reduction due to water management including seepage, and ML/ARD drainage diverted to Kitsault Pit dewatering, diversions, and downstream Upper portion of South Diversion Channel decommissioned to High prevention / reduction discharges allow non-contactlly Varden water Throughto drain into Changes TMF in Hydrology of Lime Creek Lower portion of South Diversion Channel maintained for High prevention / reduction perpetuity to divert run-off around East WRMF to the Kitsault Pit Patsy Creek Diversion Channel decommissioned to divert non- High prevention / reduction contact water to the Kitsault Pit Potential change in hydrology in Lime Creek Spillway constructed in south embankment to allow TMF surplus High prevention / reduction due to reclamation of the TMF water to drain to Kitsault Pit Potential change in hydrology due to TMF South Water Management Pond and pumping system High andprevention Mitigation / reduction seepage management downstream of the south embankment is maintained until monitoring shows that WQOs can be attained. South WMP is then decommissioned to allow TMF and East WRMF seepage and run-off to drain to the Kitsault Pit Potential change in hydrology in Lime Creek Spillway constructed in Kitsault Pit to allow end-pit lake overflow to High prevention / reduction due to Kitsault Pit reclamation including re- discharge to Patsy Creek filling and over-flow Potential change in hydrology in Lime Creek Groundwater allowed to accumulate in Kitsault Pit Low prevention / reduction due to groundwater management Potential change in hydrology in Lime Creek Spillway constructed in south embankment to allow TMF surplus High prevention / reduction due to TMF surplus and contact Water water to drain to Kitsault Pit discharge South Water Management Pond decommissioned once High prevention / reduction monitoring shows that WQOs can be attained which allows TMF and East WRMF seepage and run-off to drain to the Kitsault Pit Note: ML/ARD - metal leaching / acid rock drainage; TMF - Tailings Management Facility; WMP - Waste Management Pond; WRMF - Waste Rock Management Facility

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6.7.2.9.2.3.5 Watershed Modelling

6.7.2.9.2.3.5.1 Modelling Methods The likely effectiveness of the mitigation measures listed above to eliminate or reduce potential changes to stream flows, and hence to reduce potential effects to Dolly Varden in Lime Creek, was determined by: 1) comparing predicted monthly average, monthly minimum, monthly maximum, annual, peak instantaneous, and 7-day low flow discharges in lower Lime Creek during each phase of the Project to similar flow statistics during pre-mine, baseline conditions; and 2) comparing predicted monthly discharges during each phase of the Project to the instream flow guideline threshold as calculated using the BC Instream Flow Guidelines (BCIFG) for Fish (Hatfield et al., 2003).

Baseline discharges in lower Lime Creek were predicted from a watershed model developed to estimate the long-term (70 year period of record) surface water and groundwater flow patterns in the Lime Creek watershed calibrated with stream gauge data obtained from Lime Creek during the 2009 and 2010 field seasons. This calibrated model was then used to predict discharges in lower Lime Creek (at watershed model node LCK-H2; Figure 6.7.2-15) for each stage of the Project by superimposing key mine components on the modelled catchment area. Percent change in monthly, annual, peak instantaneous, and 7-day low flow discharges in lower Lime Creek were then calculated for each mine phase. These phases included:

 Construction (Phase 1): run-off from the upper Patsy Creek catchment is pumped to Lime Creek from behind temporary coffer dams to dewater the south embankment footprint;  Construction (Phase 2 and 3): run-off from the upper Patsy Creek catchment is stored behind the south embankment of the TMF;  Operations (Year 13): non-contact water from the upper Patsy Creek catchment is diverted around the TMF, East WRMF, and open pit via the South Diversion and Patsy Diversion channels and contact water from the LGS and surplus water from the TMF is discharged to Lime Creek via the Water Box;  Operations (Year 15): Patsy Creek diversion is maintained to divert non-contact water around TMF, East WRMF and open pit to Lime Creek; Kitsault Pit is filled with direct precipitation and seepage and run-off from the South WMP and LGS sediment control pond; TMF surplus water is discharged to Lime Creek via the Water Box;  Closure: all contact water and groundwater seepage is diverted to the Kitsault Pit and all non-contact water from the upper Patsy Creek watershed is diverted around the TMF, East WRMF, and open pit to Lime Creek (i.e. pit re-fill scenario A which fills the pit in 15 to 17 years (Knight Piésold 2011 Appendix 6.5-C);  Post-closure: all upstream contact and non-contact water reports to the Kitsault Pit and is ultimately discharged to Lime Creek via the pit spillway channel.

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The BC Instream Flow Guideline Threshold for lower Lime Creek was calculated using the methods described in Hatfield et al. (2003) and a 20 year daily flow record for Lime Creek (1976 to 1996) obtained from a previously operated Water Survey of Canada (WSC) stream gauge in lower Lime Creek (WSC gauge #08DB010). The instream flow threshold for fish- bearing streams under the BCIFG is a seasonally-adjusted threshold for alterations to natural stream flows designed to protect fish and fish habitat. Flow thresholds using the BCIFG are calculated as percentiles of the natural mean daily flows for each calendar month. These percentiles vary throughout the year to ensure a higher protection during low flow months than high flow months (Hatfield et al. 2003). Predicted monthly discharges that exceeded the calculated monthly minimum instream flow threshold were assumed to be protective of Dolly Varden in lower Lime Creek. Conversely, predicted monthly discharges that fell below the calculated monthly minimum instream flow threshold were assumed to be potentially harmful to Dolly Varden and, therefore, were carried forward to the residual effects assessment below (Section 6.7.2-10).

6.7.2.9.2.3.5.2 Modelling Results Table 6.7.2-31 provides a comparison of the baseline monthly average, minimum, and maximum, and annual discharge in lower Lime Creek to the discharges predicted to occur during each of the six mine phases indicated above. These data are derived from Knight Piésold (2011; Kitsault Mine Project-Surface Water Hydrology Flow Changes report).

On an annual basis, potential changes in discharge in lower Lime Creek were predicted to be greatest during Year 15 of operations and during the closure phase (Table 6.7.2-31). During both of these phases, average annual discharge in lower Lime Creek is predicted to be reduced by 20% and 17%, respectively. These reductions increase to 28% annually during a 1:40 year dry condition.

Average annual and monthly flow changes during Phase 1 of construction were assumed zero (Table 6.7.2-31) because all run-off captured behind the temporary coffer dams would be pumped downstream around the south embankment footprint construction area. Average annual flow changes during Phase 2 and 3 of construction were predicted to be 20% lower than baseline in an average year, 29% lower during a 1:70 year dry return period, and 9% lower during a 1:70 year wet return period.

Average annual flows in lower Lime Creek during the post-closure phase were predicted to increase during an average year (2% increase) and during a 1:70 year wet return period (3% increase) but predicted to decrease during a 1:70 year dry return period (8% reduction). The increase in annual discharge predicted in lower Lime Creek during the post-closure phase is due to the increased run-off from the encroachment of the TMF into the headwaters of the adjacent Clary Creek watershed; run-off from the headwaters of Lake 901 would report to Lime Creek post-closure.

Although the seasonal distribution of flows were not expected to change during any phase of the Project (see Section 6.5.2.7.3 of the Hydrology assessment), reductions in average monthly discharge were consistently predicted to be greatest during May and June during

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KITSAULT MINE PROJECT ENVIRONMENTAL ASSESSMENT FRESHWATER AQUATIC RESOURCES construction (Phase 2 and 3), operations (Years 13 and 15), and closure phases of the Project (Figure 6.7.2-16). This timing corresponds to the spring freshet in Lime Creek. On average, monthly May and June flows in lower Lime Creek were predicted to be approximately 25%, 19%, 26%, and 24% lower during the construction (Phase 2 and 3), operations (Year 13), operations (Year 15), and closure phases, respectively, compared to baseline (Table 6.7.2-31).

Monthly flow changes during critical months for Dolly Varden spawning (October), rearing (August), and egg incubation / overwintering (November to March) were also predicted to occur (Figure 6.7.2-16). Monthly flows during October when Dolly Varden spawn in lower Lime Creek were were predicted to be, on average, 17%, 13%, 21%, and 18% lower than baseline during construction (Phases 2 and 3), operations (Year 13), operations (Year 15), and closure, respectively (Table 6.7.2-31). On average, monthly flows in August were predicted to range between 8% lower during closure to 17% lower during construction (Phase 2 and 3). Monthly flow reductions during the winter low flow period (November to March) were predicted to be greatest during operations (Year 15) and closure phases when the Kitsault Pit is re-filling: 13% to 18% reduction in discharge during operations (Year 15) and 18% to 23% reduction in discharge during closure (Figure 6.7.2-16).

During the post-closure phase, monthly flow increases were predicted to be greatest during the spring freshet (May and June) (Figure 6.7.2-16). However, these changes were, on average, only predicted to be 5% higher at most (Table 6.7.2-31). There was little change predicted in average monthly flows in fall (September and October) but up to 8% reduction in average winter low flows (November to March).

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Table 6.7.2-31: Baseline and Predicted Mean, Minimum, and Maxi

Flow Average Phase Units January February March April May June July August September October November December StatisticConstruction, Operations, Closure, and Post-Closure Phases of the Project Annual Pre-mine Average m3/s 0.36 0.40 0.74 1.87 4.15 4.18 3.20 2.18 2.17 2.74 1.11 0.49 1.97 Minimum m3/s 0.21 0.18 0.18 0.24 1.28 0.80 0.45 1.11 0.55 0.43 0.33 0.27 0.50 Maximum m3/s 0.75 3.02 2.69 3.8 6.23 7.64 6.47 4.42 5.26 7.90 5.23 1.79 4.60 Constrution: Average % 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% Phase 1 Minimum % 0% 0% 0% 0% 0% mum0% Monthly0% 0% and Annual 0% Discharge 0% in Lower 0% Lime Creek 0% During 0% Maximum % 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% Construction: Average % 9% -19% -16% -20% -25% -26% -22% -17% -17% -17% -9% 2% -20% Phase 2 & 3 Minimum % -29% -27% -29% -19% -27% -19% -20% -22% -22% -31% -28% -28% -29% Maximum % -9% -8% -10% -20% -26% -18% -15% -16% -15% -9% -8% -13% -9% Operations: Average % -8% -8% -9% -14% -19% -18% -12% -9% -11% -13% -4% -5% -14% Year 13 Minimum % -26% -23% -9% -3% -2% -6% -6% -20% 0% -28% -26% -26% -21% Maximum % -7% -6% -8% -8% -21% -6% -6% 0% -3% -8% -7% -8% -8% Operations: Average % -18% -18% -17% -22% -26% -25% -17% -13% -15% -21% -13% -15% -20% Year 15a Minimum % -29% -27% -28% -20% -9% -12% -16% -22% -21% -31% -28% -28% -28% Maximum % -10% -16% -20% -24% -28% -14% -14% -6% -9% -20% -17% -13% -17% Closure Average % -18% -17% -18% -21% -24% -20% -13% -8% -13% -18% -8% -5% -17% Minimum % -28% -26% -28% -19% -8% -12% -15% -21% -20% -30% -28% -28% -32% Maximum % -9% -15% -19% -11% -26% -11% -11% -1% -5% -19% -13% -13% -14% Post-closure Average % -8% -5% 1% 2% 3% 5% 3% -2% 0% 3% 4% -4% 2% Minimum % -9% -7% -8% -5% 0% -10% -15% -8% 4% -8% -10% -10% -8% Maximum % -3% 2% 3% 4% 5% 4% 5% 1% 1% 3% 4% -1% 3% Note: a Kitsault Pit filling scenario A

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5.0 4.5 4.0 3.5 /s) 3 3.0 2.5

Flow (m 2.0 1.5 1.0 0.5 0.0 Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec

Pre-mine C-P2&3 YrMonth 13 Yr 15 A C PC

Figure 6.7.2-16: Comparison of Predicted Average Monthly Discharges in Lower Lime Creek during Construction, Operations (Years 13 and 15), Closure, and Post- Closure Phases to Average Pre-Mine Conditions

A comparison of the predicted average monthly flows in lower Lime Creek during each phase1 of the Project to the calculated monthly instream flow guideline threshold2 is provided in Figure 6.7.2-17. As can be seen from this graph, predicted monthly discharges in lower Lime Creek during all phases of the Project were predicted to be below the calculated BC IFG threshold for lower Lime Creek in all months except during the spring freshet months of May and June. The largest deviations in discharge from the calculated BC IFG threshold occur in the low flow months of August, December, January, February and March. During these months, the predicted average monthly discharges in lower Lime Creek were predicted to be approximately 0.5 m3/sec lower than the corresponding BC IFG threshold discharge. These differences are largely an artefact of how the BC IFG threshold is set for low flow months. For lower Lime Creek, the BC IFG threshold was set between the 84th and 90th percentile of median daily flows for each of these months. As a result, predicted mean monthly discharges (i.e., approximately the 50th percentile flows) in lower Lime Creek

1 Average monthly discharges for each Project phase were calculated using the percentage change in monthly flows from baseline predicted by the watershed model. Pre-mine baseline monthly average discharges were calculated from the 20 year daily flow record (1976 to 1996) obtained from the Water Survey of Canada stream gauge (08DB010) in lower Lime Creek. This was done so that predicted monthly flows could be fairly compared to the BC Instream Flow Guideline threshold; the watershed model only predicts monthly flows but the BC IFG threshold must be calculated from daily flows.

2 Threshold guideline was calculated from the 20 year daily flow record (1976 to 1996) obtained from the WSC stream gauge (08DB010) in lower Lime Creek using the methods described in Hatfield et al. (2003)

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KITSAULT MINE PROJECT ENVIRONMENTAL ASSESSMENT FRESHWATER AQUATIC RESOURCES would always be below the calculated BC IFG threshold during these low flow months even during pre-mine baseline conditions. Nevertheless, the purpose of the BC IFG threshold is to provide higher protection during low flow months than high flow months (Hatfield et al. 2003). The fact that the predicted mean monthly discharge during each phase of the Project are predicted to be below the calculated BC IFG threshold in these months, particularly during the winter low flow months when Dolly Varden eggs are incubating, indicates that the mitigation measures included in the Project’s water management plan are insufficient to eliminate the potential indirect effect of predicted changes in hydrology in lower Lime Creek on Dolly Varden. As a result, this potential effect is carried forward to the assessment of residual effects (see Section 6.7.2.10).

5

4.5

4

3.5 /s) 3 3 (m

2.5

2 Discharge 1.5

1

0.5

0

Pre‐mine BC Instream Flow Minimum Threshold Construction Stage 2 & 3 Operations‐Year 13 Operations‐Year 15 Closure Post‐closure

Figure 6.7.2-17: Comparison of Predicted Average Monthly Discharges in Lower Lime Creek during Construction, Operations (Years 13 and 15), Closure, and Post- Closure Phases to Pre-Mine Average Monthly Discharge and the Calculated BC Instream Flow Guideline Threshold

Importantly for the assessment of residual effects, mean monthly discharges in lower Lime Creek during October (the month in which Dolly Varden spawning in Lime Creek roughly occurs in most years) were predicted, on average, to range from 0.01 m3/sec lower than the

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KITSAULT MINE PROJECT ENVIRONMENTAL ASSESSMENT FRESHWATER AQUATIC RESOURCES corresponding October guideline threshold during Operations-Year 13 to a maximum of only 0.23 m3/sec lower during Operations-Year 15. At post-closure, mean monthly discharges in lower Lime Creek were predicted to exceed the October BC IFG threshold during this critical month for Dolly Varden spawning.

6.7.2.9.2.4 Change in Water Temperatures in Lime Creek 6.7.2.9.2.4.1 Potential Change in Water Temperatures in Patsy and Lime Creeks Potential changes in water temperatures in Lime Creek may occur during all phases of the Kitsault Project (Table 6.7-2-18). These changes would occur primarily from: 1) ponding and release of water from the developing TMF during Construction Phases 2 and 3; 2) ponding and release of water from the TMF during mine operations and closure; and 3) ponding and release of Kitsault Pit over-flows during post-closure.

The TMF and Kitsault Pit would all occur in the Patsy Creek watershed. Subsequently, water temperatures in Patsy Creek could change when the discharge in Patsy Creek is altered from being largely determined by outflows from Patsy Lake during pre-mine conditions to being largely determined by outflows the TMF during construction, operations and closure phases and from the Kitsault Pit during the post-closure phase. Thus, these activities could ultimately result in changes in water temperatures in lower Lime Creek, particularly if:

 Water discharged from the TMF and Kitsault Pit to Patsy Creek are substantially colder or warmer than water temperatures discharged from Patsy Lake;  Water temperatures in Patsy Creek are increased or decreased such that the addition of flow from the unaffected Patsy Creek tributaries downstream of the TMF and East WRMF, from Lime Creek watershed upstream of the Patsy Creek confluence and from the additional flow contributed by downstream tributaries is insufficient to attenuate changes in Patsy Creek water temperatures.

During construction and operations, release of surplus water from the TMF has the potential to increase summer water temperatures in lower Lime Creek. This is because: 1) the surface area of the TMF supernatant pond would be larger (1.7 milliion m2) than Patsy Lake (185,803 m2) thus increasing the amount of water exposed to the sun during summer; 2) the recycled process water may contribute heat to the TMF supernatant pond; and 3) water from the TMF would be pumped from near the surface of the TMF to the Water Box (this surface water would be warmer than water at the bottom of the supernatant pond in summer).

During the post-closure phase, water released from the Pit to Patsy Creek (via the spillway) has the potential to delay the spring warm-up and fall cool-down periods compared to current temperatures in Patsy Creek. This is because of the greater surface area (660,591 m2), depth (approximately 300 m), and volume of the end-pit lake compared to that of Patsy Lake (185,803 m2 and 29 m maximum depth); the end-pit lake would be approximately 3.5 times the size and 10 times the depth of Patsy Lake.

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The potential effect of these larger, deeper waterbodies on water temperatures in Patsy Creek depends on a number of factors. These factors are potentially more complicated for the TMF in comparison to the Kitsault Pit. Considering the Kitsault Pit first, water released from the Pit to Patsy Creek (via the spillway) during the post-closure phase is likely to delay the spring warm-up and fall cool-down periods compared to current temperatures in Patsy Creek. These delays in spring warm-up and fall cool-down compared to current conditions could occur during post-closure because the end-pit lake in the Kitsault Pit would have a much larger thermal mass than Patsy Lake. More water takes longer to heat up and longer to cool-down. This greater thermal inertia means that the end-pit lake would take longer to heat and more days to thermally stratify in spring and summer than Patsy Lake but would also take longer to cool in fall.

No change in winter temperatures are expected during post-closure because, similar to Patsy Lake, the surface of the end-pit lake is expected to freeze and water temperatures drawn off the top of the lake are expected to be near zero, similar to water temperatures downstream of Patsy Lake. The potential increase in summer water temperatures and the duration of delays in spring and fall warm-up and cool-down periods in Patsy Creek in any given year during post-closure period would depend on climatic conditions (e.g., summer temperatures, precipitation, wind conditions, number of cloudy days).

While similar physical processes are expected to occur in the TMF during construction, operations, and closure phases, the situation is complicated by the: 1) recycling of water between the TMF and the mill; 2) the differences in volume of surplus water that would need to be discharge to Patsy Creek in any given month or year; 3) the duration that surplus water would be held in the Water Box before release to Patsy Creek; and 5) the uncertainty about whether the TMF would freeze in winter.

Based on the above situations, the potential exists for water temperatures in Patsy Creek and Lime Creek to be altered during all seasons and during all phases of the Project compared to water temperatures currently experienced by Dolly Varden in lower Lime Creek. Some of these potential changes in water temperature created by the Project would at least be partially attenuated by the continued influence of thermal loading provided by run-off from the unaffected upper Lime Creek watershed, run-off from the diverted upper Patsy Creek watershed, and run-off from the unaffected Lime Creek tributaries downstream of the Patsy Creek confluence.

6.7.2.9.2.4.2 Potential Effect of Water Temperature Changes on Dolly Varden Water temperature directly affects rates of feeding, metabolism, conversion efficiency, and growth of fish (Brett 1971; Wurtsbaugh and Davis 1977; Elliott 1982; Diana 1995). Water temperature can also result in direct mortaility of fish if temperatures exceed the incipient lethal water termperature of the fish species in question. Water temperature also indirectly affects fish by altering the solubitility of dissolved gases (Johnson and Jones 2000), the prevalence of water-borne diseases (Becker and Fugihara 1978) and the interactions of fish with other stream organisms (i.e., prey, predators or competitors).

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Fish are obligate poikilotherms (i.e., cold-blooded animals that take on the temperature of their surroundings) and alter their behaviour in relation to temperature in order to maximise their growth, minimise their risk of predation, and avoid, if possible, temperatures at or near their physiological tolerances. Such behaviour can occur daily (Brett 1971), seasonally (Coutant 1987), or ontogenetically (Magnuson et al. 1979, McCauley and Huggins 1979) but depends on the availability of appropriate thermal habitat, habitat that can be potentially more limited for species with relatively narrow physiological temperature requirements such as Dolly Varden.

Dolly Varden are a cold-water species with a relatively narrow range of preferred water temperatures (McPhail 2007). Table 6.7.2-32 shows the optimal and maximum water temperature tolerance ranges for different Dolly Varden life stages. Data in this table are largely based on temperature tolerances for the closely related bull trout (Salvelinus confluentus), and it is assumed that Dolly Varden would have similar temperature tolerances.

Table 6.7.2-32: Optimal and Maximum Tolerance Water Temperature Ranges for Different Dolly Varden Life stages

Optimal Water Temperature Temperature Upper Incipient Life Stage Temperature Preference Tolerance Lethal Water Range (°C) Range (°C) Range (°C) Temperature (°C) Egg incubation 2 to 4°Cc 0 to 8°Ca ≥8°C Juvenile rearing/growth <12°Cd,e 5 to 15°Ce,h 0 to 18°Cd,e ≥20°Ch Adult (growth) 0 to 13°Cb <15°Ca 0 to 20°Ca ≥20°Cf Adult spawning <9°Ca,d,g 6 to 8°Ca - - References: a McPhail (2007); b Ford et al. (1995); c McPhail and Murray (1979); d Shepard et al. (1984) in Ford et al., 1995; e Baxter and McPhail 1996; f Takami et al. (1997); g Smith and Slaney (1980); h Selong et al. (2001).

Water temperatures in lower Lime Creek are currently near optimal for juvenile Dolly Varden growth and survival in summer (Figure 6.7.2-18). Average monthly water temperatures during July and August are 11°C and 12.5°C, respectively. These temperatures are within or only slightly above the optimal thermal preference range for juvenile Dolly Varden, the only life stage present in Lime Creek in these months. Thus, a 1°C or 2°C increase in July or August water temperatures would cause water temperatures to exceed the optimal water temperature range for juvenile Dolly Varden rearing. A 3°C increase would cause July and August water temperatures to exceed the preferred temperature range upper limit of juvenile Dolly Varden (Table 6.7.2-32). Such an increase could be expected to increase metabolic rates and decrease growth of juvenile Dolly Varden rearing in lower Lime Creek with potential consequences for the survival of individual fish and / or size and health of the Lime Creek population.

Average monthly water temperatures during the winter egg incubation period range from 0.3°C and 2°C (Figure 6.7.2-18). This is lower than the optimal temperature range for Dolly

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Varden egg incubation (2°C to 4°C) but within the range of temperatures tolerated Dolly Varden eggs. Therefore, an increase in winter temperatures of 1°C or 2°C would likely reduce the egg hatching time and put winter water temperatures in Lime Creek within the optimal temperature range for Dolly Varden egg incubation. Conversely, a decrease in winter temperatures would likely delay egg hatching or could cause eggs to freeze.

20.0 Mean 18.0 Min

16.0 Max 14.0

12.0

10.0

8.0

6.0 Temperature (Temperature C) 4.0

2.0

0.0

-2.0

Date

Figure 6.7.2-18 Mean, Minimum, and Maximum Daily Water Temperatures in Lower Lime Creek in 2010 / 2011

6.7.2.9.2.4.3 Mitigation Measures No mitigation measures are proposed to specifically eliminate or reduce the potential changes in water temperatures in Lime Creek. Instead, the primary mitigation measure is the implementation of the mine’s Water Management Plan (Appendix 6.4-B). The details of this water management plan have been previously described. In essence, any mitigation measure that would reduce or eliminate potential changes in stream flows in lower Lime Creek would also serve to reduce or eliminate potential changes in water temperatures in lower Lime Creek. Of primary importance for reducing potential changes in water temperatures in lower Lime Creek would be:

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 Construction, operation, and maintenance of the South Diversion Channel and the Patsy Diversion Channel to divert non-contact water around the TMF, East WRMF, and Kitsault Pit during construction, operations, and closure phases; and  Recycling of water between the TMF and the mill to the maximum extent possible during operations.

In addition to these mitigation measures, any potential changes in water temperatures in Patsy Creek on lower Lime Creek water temperatures would be partially attenuated by run- off from the unaffected upper Lime Creek watershed and from unaffected Lime Creek tributaries downstream of the Patsy Creek confluence during all phases of the Project.

It is unclear whether these natural and water management plan mitigation measures would completely eliminate any potential changes in water temperatures in Patsy Creek and ultimately in lower Lime Creek where Dolly Varden reside. Therefore, this potential effect on Doly Varden is carried forward to the assessment of potential residual effects.

6.7.2.9.2.5 Change in Benthic Macro-Invertebrate Community in Lime Creek Juvenile Dolly Varden fed on benthic invertebrate drift. These can be larvae of aquatic insects drifting downstream or terrestrial invertebrates falling on to the water surface from overhanging vegetation.

Potential changes in abundance and composition of the benthic invertebrate community in Lime Creek due to the potential direct and indirect effects of changes in habitat, water quality, stream flow, and in water temperatures in Lime Creek are assessed in Section 6.7.5.9.3. No significant residual effects to BMI production or drift were predicted to occur. As a result, no significant residual effects to Dolly Varden due to potential changes in BMI community of Lime Creek were predicted to occur. This was because:

 If it is assumed that benthic invertebrate production across the wetted perimeter of Lime Creek is homogenous, the small change in wetted width predicted to occur due predicted flow reductions during different phases of the Project was unlikely to have a significant effect on benthic invertebrate production or on the amount of BMI drift available to juvenile Dolly Varden downstream;  The flow reductions predicted to occur in Lime Creek are unlikely to be large enough to reduce the water velocities preferred by the mayflies and stoneflies that currently dominate the benthic macro-invertebrate community of Lime Creek;  The flow reductions predicted to occur in Lime Creek are unlikely to be large enough to reduce the delivery of benthic invertebrate drift to juvenile Dolly Varden in lower Lime Creek;  The small changes in water temperatures predicted to occur are unlikely alter the benthic invertebrate community of Lime Creek in favour of prey items not preferred by juvenile Dolly Varden; and

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 Water quality of the discharge effluent from the Project would be monitored such that no water would be released downstream that didn’t meet water quality objectives designed to ensure the protection of freshwater aquatic biota in Lime Creek, including the benthic macro-invertebrate community.

This potential indirect residual effect is rated as not significant (minor). However, the level of confidence is low because of the uncertainty regarding the potential combined effects of changes in habitat, water quality, stream flows, and water temperatures due to the Project on the benthic macro-invertebrate community in Lime Creek

6.7.2.10 Potential Residual Effects and their Significance

Only those potential effects that would not be eliminated by mitigation measures included in the water management plan or committed to mitigation section above were carried forward to this assessment of potential residual effects on Dolly Varden. An assessment of the potential residual effects to Dolly Varden of each of these indirect effects is presented in the sections below. The significance of each of these potential effects is assessed in Section 6.7.2.10.2.

6.7.2.10.1 Potential Residual Effects after Mitigation 6.7.2.10.1.1 Change in Surface Water Quality in Lime Creek Modelled surface water quality in Lime Creek predicted that the following parameters would exceed provincial and / or federal water quality guidelines for the protection of freshwater aquatic biota:

 Fluoride (operations, closure, and post-closure only);  Sulphate (operations, closure, and post-closure only);  Aluminum (all four phases);  Cadmium (all four phases);  Chromium IV (all four phases);  Copper (construction and closure phases only);  Mercury (operations and post-closure phases only);  Molybdenum (all four phases);  Selenium (operations and post-closure only); and  Zinc (construction, closure, and post-closure phases only).

The potential residual effect of each of these parameters with guideline exceedences is assessed in the sections below. This is done by presenting a description of the ecological toxicity profile of the chemical (i.e., what does it do to fish at high concentrations), a summary of the potentially confounding effects of other water quality parameters that may

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The assessment of potential residual effects on Dolly Varden due to each predicted chemical with predicted guideline exceedences was conducted by: 1) reviewing how the guidelines were derived and assessing their appropriateness for the local site-conditions in Lime Creek; 2) where appropriate, proposing alternative guideline concentrations based on more recent toxicological studies (using more diverse freshwater taxa or more relevant species; e.g. salmonids such as rainbow trout) conducted since the BC or CCME guidelines were derived; 3) comparing zinc and copper concentrations predicted by the conservative water quality model (i.e., assumed no complex speciation of metals would occur) to chronic and acute concentrations predicted using a biotic ligand model (BLM) which accounted for some of these complex interactions, particularly with dissolved organic carbon; and 4) comparing predicted chemical concentrations to the concentrations found to have lethal (i.e.,

LC50) or chronic (i.e., impaired growth or health) effects on Dolly Varden or other salmonid fish species (e.g., rainbow trout, brook trout) in the published literature.

The proponent acknowledges that lethal or chronic health effects to Dolly Varden and other freshwater aquatic biota in Lime Creek due to water quality changes caused by the proposed Project would be unacceptable. As such, The proponent is committed to working with Environment Canada, the BC Ministry of Environment, and the Nisga’a Lisims Government to determine if and what water quality objectives (WQOs) would be appropriate for each chemical of concern with predicted exceedences of existing water quality guidelines for the protection of freshwater aquatic biota. The proponent is also committed to monitoring water quality in their mine effluent (as required under the Metal Mine Effluent Regulation [MMER] of the federal Fisheries Act) and in Lime Creek (as part of any future Environmental Effects Monitoring [EEM] program) and to providing water treatment of their mine effluent if required. The reader is reminded of these commitments while reading the residual effects assessments below.

6.7.2.10.1.1.1 Fluoride

6.7.2.10.1.1.1.1 Ecological Toxicity Profile Fluoride is a major ion found in freshwater and marine environments. Its primary source in natural freshwater waterbodies and streams is from leaching of fluoride-containing bedrock by groundwater. Major anthropogenic sources of fluoride include aluminum smelting and phosphate fertiliser production (CCME 2002).

Fluoride accumulates in the bone tissues of fish (Camargo 2003). In elevated concentrations, the toxic action of fluoride resides in the fact that fluoride ions act as enzymatic poisons, inhibiting enzyme activity and, ultimately, interrupting metabolic processes such as glycolysis and synthesis of proteins (Camargo 2003). Fluoride toxicity increases with increasing fluoride concentrations, exposure time, and water temperature and decreases with increasing water hardness.

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6.7.2.10.1.1.1.2 Water Quality Model Results The water quality model predicted that average annual and peak monthly fluoride concentrations in lower Lime Creek would exceed the BC MOE maximum acceptable guideline limit for fluoride (0.3 mg/L) during the operations, closure, and post-closure phases of the Project. Average annual fluoride concentrations were predicted to be 0.38 mg/L in lower Lime Creek with peak monthly fluoride concentrations frequently exceeding 0.9 mg/L during operations (Section 6.6, Surface Water Quality). Average annual and monthly peak fluoride concentrations were predicted to be higher during closure (annual average of 0.46 mg/L with monthly maximums frequently exceeding 1.0 mg/L) than during operations. This was because fluoride concentrations in the TMF remain elevated during closure until the south diversion channel is decommissioned to provide greater downstream dilution. During the closure phase, TMF surplus is released directly to Lime Creek via the Water Box with no other dilution sources. In contrast, TMF surplus during operations is mixed with LGS seepage collection pond water and water from the Open Pit.

During the post-closure phase, fluoride concentrations were predicted to have an annual average concentration of 0.19 mg/L. However, monthly maximum fluoride concentrations were predicted to exceed 0.3 mg/L for the first five years post-closure. By Year 6, average annual and monthly maximum fluoride concentrations were predicted to be below the 0.3 mg/L fluoride guideline for perpetuity.

6.7.2.10.1.1.1.3 Residual Effects Assessment Although annual average and monthly maximum fluoride concentrations during operations and closure phases and maximum fluoride concentrations during the first five years of the post-closure phase were predicted to exceed the BC MOE maximum fluoride guideline, this guideline level was considered overly conservative for the protection of Dolly Varden in Lime Creek from lethal and sub-lethal effects of fluoride. This assessment was based on the following lines of evidence:

 The guideline was incorrectly derived by BC MOE because they inadvertently applied the safety factor recommended by Pimentel and Bulkley (1983) to the

temperature adjusted LC50 concentration for rainbow trout (Angelovic et al., 1961) twice instead of once (Dr. C. Meays, Water Quality Science Specialist at the Water Protection and Sustainability Branch of the BC MOE, pers. comm. July 6, 2011).

This reduced the LC50 concentration for rainbow trout from 4.0 mg/L to 0.2 mg/L for soft water waterbodies (i.e., <50 mg/L of CaCO3) and from 6.0 mg/L to 0.3 mg/L for harder water waterbodies (i.e., >50 mg/L of CaCO3);  The technical appendix that accompanies the fluoride guideline in the Ambient Water Quality Criteria for Fluoride (Warrington 1995) notes that in inland areas where natural hardness levels and background fluoride concentrations are elevated (>50

mg/L CaCO3), a higher guideline of 0.3 mg/L was not likely to stress organisms already adapted to fluoride levels in this range; and  A fluoride guideline derived by correctly applying the recommended safety factor only once, would result in a fluoride guideline concentration of 4 mg/L which is more

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consistent with LC50 concentrations found in other studies (Pimentel and Bulkley 1983; Camargo, 2003).

Using the corrected fluoride concentration guideline (4 mg/L) for the BC MOE maximum fluoride concentration, none of the predicted fluoride concentrations in lower Lime Creek would exceed this guideline during any phase of the Project. In fact, the highest predicted peak fluoride concentrations during the Project (1.02 mg/L and 1.04 mg/L during the operations and closure phases, respectively) would be nearly four times lower than this guideline. As a result, no lethal or sub-lethal effects on Dolly Varden are expected to occur due to any of the predicted changes in fluoride concentrations in Lime Creek. No residual effect to Dolly Varden would occur.

6.7.2.10.1.2 Sulphate 6.7.2.10.1.2.1 Ecological Toxicity Profile Sulphate is ubiquitous in freshwater environments and frequently acts as the main sulphur source for production of aquatic plants and bacteria (Davies 2007). Sulphate levels in most lakes and rivers in British Columbia are naturally low (23 to 30 mg/L) but some lakes in BC have natural sulphate levels in excess of 3000 mg/L (Singleton 2000). Although data exists on sulphate’s chronic and acute toxicity levels in fish, little is known on its mechanism of action. Boge and Rigal (1982a, b) showed biochemical changes in enzyme activity in the gills and digestive system of the European eel (Anguilla anguilla) exposed to 71 mg/L of sulphate. The same tests, however, performed on rainbow trout resulted in no changes in enzyme activity (Boge and Rigal 1982c, d). Singleton (2000) suggested that these changes may be adaptive as opposed to having detrimental effects. Hobe (1987) speculated that sulphate entry may alter the rate and / or direction of other ion transfer across the gill, simply due to electron balance, as opposed to directly affecting gill function.

6.7.2.10.1.2.2 Water Quality Model Results The water quality model predicted sulphate concentrations in lower Lime Creek to exceed the BC MOE maximum acceptable limit guideline for the protection of freshwater aquatic biota (100 mg/L) only during the operations and post-closure phases of the Project. Peak sulphate concentrations were predicted to increase steadily during operations to a maximum of 212.2 mg/L in Year 13 (Section 6.6, Surface Water Quality). Each of the peak concentrations during operations were predicted to occur almost exclusively during the winter low-flow period (November to February)(Appendix 6.6-A in Knight Piésold 2011).

Monthly peak sulphate concentrations phase were predicted to be highest during Year 1 post-closure (maximum of 161.1 mg/L) when the pit first begins to over-flow and discharge to Lime Creek. After that, monthly peak sulphate concentrations were predicted to decrease exponentially to an equilibrium monthly peak sulphate concentration of about 75 mg/L by about Year 15 post-closure.

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6.7.2.10.1.2.3 Residual Effects Assessment Despite these exceedences of the BC MOE maximum acceptable limit for sulphate, predicted monthly maximums and annual average sulphate concentrations in lower Lime Creek are not expected to have an adverse residual effect on Dolly Varden (Table 6.7.2-38). The rationale for this assessment is two-fold: 1) the BC MOE guideline is conservatively high and lethal or sub-lethal effects of sulphate on Dolly Varden would not be expected at the concentrations predicted to occur during all phases of the Project; and 2) the BC MOE guideline does not factor in the role of water hardness in determining the toxicity of sulphate to freshwater aquatic biota. The assessment of no adverse residual effect to Dolly Varden from sulphate exceedences of BC MOE guidelines is based on the following lines of evidence:

 The BC MOE guideline for sulphate (Singleton 2000) is based on toxicity on the most sensitive organism tested (the common aquatic moss Fontinalis antipyretica) from a limited (<10) number of studies, some of which have been contradicted by more recent studies;  The guidelines acknowledges that the reliability of the data found in some of the laboratory tests compiled to develop the BC MOE guideline was questionable due to a variety of reasons including: 1) poor laboratory procedures; 2) failure to report crucial test procedure information; or 3) calculation errors;  A series of bioassays conducted specifically for the review of sulphate toxicity prior to promulgation of the BC MOE sulphate guideline found that the lowest sulphate effect level was 205 mg/L for a freshwater invertebrate found in soft water (Singleton 2000); and  A study (Davies et al. 2003) that repeated all of the dose-response tests of sulphate on the four aquatic organisms originally used as the basis for the BC MOE sulphate guideline (striped bass (Morone saxatilus), aquatic moss (Fontinalis antipyretica), the amphipod (Hyallela azteca), and the cladoceran (Daphnia magna)) found sulphate toxicity thresholds much higher than those found in the original studies (Hughes 1973; Frahm (1975); PESC (1996)). These differences included: o A toxicity threshold of approximately 800 mg/L in soft water (19 mg/L) for Fontinalis antipyretica (as measured by chlorophyll a concentration) found by Davies et al. (2004) compared to the toxicity threshold of 100 mg/L of sulphate found by Frahm (1975). This difference was attributed to the use of potassium sulphate by Frahm (1975) which is known to be extremely toxic to fish, plants, and invertebrates due to the toxicity of the potassium ion and not sulphate. In contrast, Davies et al. (2004) used sodium sulphate due to the relatively innocuous toxicity of sodium compared to potassium. Davies et al. (2004) found no observable effect of sulphate on Fontinalis antipyretica at concentrations up to

1500 mg/L in waters with hardness of 100 mg/L of CaCO3. o No-observable effect concentrations (NOEC) of 453 mg/L and 491 mg/L of sulphate (added as sodium sulphate) on Hyallela azteca in soft water (25 mg/L of

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CaCO3) during replicated 4-day tests conducted by Davies et al. (2004) compared to a 4-day LC50 concentration of 205 mg/L of sulphate found by PESC (1996) in similar hardness water for this same organism. This difference was attributed to the deficiency of chloride ions in the test water used by PESC (1996).  Invertebrates tend to exhibit higher sensitivity to sulphate than most fish species. For example, Mount et al. (1997) reported 48-hour LC50 concentrations to be >7960 mg/L for fathead minnow (Pimephales promelas) and 3080 mg/L for the cladoceran (Ceriodaphnia dubia).

Increasing water hardness has been shown to decrease the toxicity of sulphate to freshwater aquatic biota (PESC 1996; Davies et al. 2004; Davies 2007). For example,

PESC (1996) found that for Hyallela azteca, the LC50 for sulphate in water with a hardness of 100 mg/L of CaCO3 to be 3711 mg/L of sulphate. Davies et al., (2004) found no observable effect on Fontinalis antipyretica of sulphate at concentrations up to 1500 mg/L in water with hardness of 100 mg/L CaCO3 and also found greatly reduced toxicity of sulphate on Hyallela azteca in waters with increasing hardness. Davies et al. (2004) conclude that a new, higher, water quality guideline for the protection of aquatic biota from sulphate that incorporates the hardness of the receiving waters could be safely adopted.

Based on the evidence above and the water hardness concentrations predicted to occur during the operations (annual average of 128 mg/L as CaCO3) and post-closure phase (105 mg/L as CaCO3) in Lime Creek, the toxicity of sulphate to Dolly Varden is unlikely to create lethal or sub-lethal effects. The fact that Davies et al. (2004) found no observable effect of sulphate concentrations 15 times higher than the existing BC MOE guideline had no effect on the more sensitive Fontinalis antipyretica moss at water hardness concentrations similar to those predicted to occur in Lime Creek during operations and post- closure phases suggests as much.

6.7.2.10.1.3 Aluminum 6.7.2.10.1.3.1 Ecological Toxicity Profile Aluminum is a gill toxicant to fish and its acute and chronic effects on fish are due to a combination of ion-regulatory, osmo-regulatory, and respiratory disruption (Exley et al., 1991; Sparling and Lowe 1996; Gensemer and Playle 1999). Acute effects of aluminum toxicity include mortality due to hypoxia associated with clogging of the gill interlamellar spaces due to aluminum polymerisation on the gill surface (Poleo et al. 1994; Poleo 1995; Witters et al. 1996), disruption of ion exchange due to displacement of calcium ions from the gill membrane (Wood and Macdonald 1987; Freda et al. 1991;) and interference with gill enzyme activity (Staurnes et al. 1993). Sub-lethal effects of aluminum toxicity include reduced feeding rates, growth rates, and metabolic rates as fish respond to aluminum exposure by reducing metabolically costly activities such as routine swimming behavior to allow for the increased maintenance costs associated with acclimation and gill damage repair (Allin and Wilson 1999).

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The toxicity of aluminum to fish and other freshwater biota is dependent on a number of factors. These factors include the species of organism (different species and taxa have different tolerances for aluminum) and the confounding effects of other water quality parameters. Principle among these water quality parameters are: pH, water hardness, fluoride, and dissolved organic carbon. Aluminum becomes more soluble and more toxic in freshwaters with pH values less than 6 or greater than 8 (Gensemer and Playle, 1999). Conversely, increasing water hardness, fluoride concentration, and water hardness are known to reduce aluminum toxicity. Flouride and dissolved organic carbon bind with aluminum which reduces the amount of inorganic, monomeric aluminum species (Al3+, 2+ 2+ 4- AlOH , Al(OH) , Al(OH)3, and Al(OH) ) in the water column making toxic aluminum species less available to interact at the gill membrane surface (Gensemer and Playle 1999). Increasing water hardness reduces aluminum toxicity by increasing the availability of calcium (Ca2+) in the water column and, thereby, increasing the competition with Al3+ to bind to negatively charged gill cells (Gensemer and Playle 1999). As a result of these complex interactions, CCME (2005) aluminum guidelines for the protection of freshwater aquatic life state that:

 Aluminum concentrations should not exceed 0.005 mg/L at pH values < 6.5 and with concentrations of calcium (Ca2+) < 4 mg/L and dissolved organic carbon (DOC) <2 mg/L, or  Aluminum concentrations should not exceed 0.1 mg/L at pH values ≥ 6.5 and with concentrations of calcium (Ca2+) ≥ 4 mg/L and dissolved organic carbon (DOC) ≥2 mg/L.

6.7.2.10.1.3.2 Water Quality Model Results Aluminum concentrations in lower Lime Creek were predicted to exceed the BC MOE 30-day guideline (0.05 mg/L) during all phases of the Project. Aluminum concentrations in lower Lime Creek were predicted to exceed the BC MOE maximum allowable limit concentration (0.1 mg/L) and the CCME guideline (0.1 mg/L) only during the operations and post-closure phases of the Project. The paragraphs below summarise the water quality model results and the predicted aluminum concentrations exceedances of the provincial and federal aluminum guidelines. The reader is referred to the Surface Water Quality assessment (Section 6.6) and Appendix 6.6-B for specific details and results.

Average annual dissolved aluminum concentrations in lower Lime Creek were predicted to be below the BC MOE 30-day guideline concentration during both years of construction. However, monthly peak dissolved aluminum concentrations during these two years were predicted to exceed this 0.05 mg/L guideline limit in some months with maximum peak monthly concentrations exceeding 0.08 mg/L in October and November of the second year of construction. These exceedances were likely a result of the combined effect of high background concentration of aluminum in lower Lime Creek and contribution of dissolved aluminum loading from seepages through the south embankment starter dam material from historic Patsy waste rock.

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During operations, dissolved aluminum concentrations were predicted to steadily increase over time. Annual average concentrations were predicted to exceed the BC MOE 30-day average guideline during all years while they were predicted to exceed the BC MOE maximum acceptable limit guideline and the CCCM guideline by Year 3. Monthly maximum dissolved aluminimum concentrations were predicted to exceed all three guidelines during all 15 years of operations.

Annual average dissolved aluminum concentration were predicted to range between 0.016 mg/L to 0.077 mg/L at closure, with an annual average concentration of 0.036 mg/L over the entire closure period. At these concentrations, predicted dissolved aluminum concentrations would exceed the BC MOE 30-day guideline but not the BC MOE maximum acceptable limit guideline or the CCME guideline.

During the post-closure phase, annual average dissolved aluminum concentrations (0.061 mg/L) were predicted to exceed the BC MOE 30-day guideline for perpetuity but not the BC maximum acceptable limit guideline or the CCME guideline. However, monthly peak dissolved aluminum concentrations in October were predicted to exceed the BC maximum acceptable limit guideline and the CCME guideline in all years post-closure.

6.7.2.10.1.3.3 Residual Effects Assessment Although the above guideline exceedences were predicted to occur, potential adverse effects to Dolly Varden in Lime Creek may not necessarily occur. This likelihood exists because:

 The provincial 30-day average criterion of 0.05 mg/L was “set arbitrarily at 50% of the maximum criterion level” (Technical Appendix to the BC MOE Ambient Water quality Criteria for Aluminum (Butcher 1988));  The provincial and federal guideline levels for maximum acceptable limit for dissolved aluminum (0.1 mg/L) may be overly conservative for waters with pH, hardness, and dissolved carbon concentrations expected to occur in Lime Creek during the construction, operations, closure, and post-closure phases of the Project;  Dissolved aluminum concentrations predicted by the surface water quality model were based conservatively on a mass-balance model that assumes that dissolved components remain in solution. This is highly conservative for aluminum because aluminum speciation in natural waters is highly complex. First, aluminum solubility is dependent on pH, water temperature, and the presence of complexing ligands (Driscoll and Postek 1996; Poleo and Hytterod 2003). Second, once in solution, aluminum forms inorganic complexes with fluoride, silica, sulphate, and humic (i.e., dissolved organic carbon) and fulvic acids, the formation of which also varies with pH, the concentration of inorganic ligands, ionic strength, and water temperature (Gensemer and Playle 1999). Finally, there is an exchangeable fraction of dissolved aluminum with soils, sediments, and precipitated organic material (Driscoll and Postek 1996). Because of this complexity, lower, more realistic concentrations of dissolved aluminum in lower Lime Creek would have likely been predicted had a

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chemical equilibrium model been used that accounted for the precipitation (i.e., physical complexing with sulphate, fluoride, and oxides for example), chelation (i.e., binding to organics), and adsorption (i.e., complexing with silicates) of aluminum likely to occur in Lime Creek during all phases of the Project; and  More recent data on the toxicity of aluminum to fish within the same genus (Salvelinus) as Dolly Varden indicate that acute toxicity concentrations of aluminum to Dolly Varden are likely much higher than those used in the BC MOE maximum acceptable guideline and the CCME guideline for waters with pH >6.5.

The BC MOE maximum acceptable limit guideline and the CCME guideline for dissolved aluminum was based on one study (Minzoni 1984) that tested the mortality of three genera of zooplankton (Diaptomus, Daphnia, and Cyclops) exposed to aluminum. There are a number of flaws in this study that suggests that using its results to set WQGs for aluminum may be inappropriate. First, the pH of the test water in the study decreased to 6.0 during the experiment and the author concluded that the mortality of zooplankton was “mainly due to the low value in pH” not due directly to the concentration of aluminum in solution. As a result, the application of the study’s results to develop the WQG for surface waters with pH >6.5 is uncertain. Second, the study author acknowledges that other studies using the same test organisms found aluminum toxicity thresholds greater than three times higher than those found in their study. Third, the Technical Appendix for the Water Quality Criteria for Aluminum (Butcher 1988) recognises that water hardness and dissolved organic carbon concentrations are known to reduce the toxicity of aluminum to aquatic biota. However, the provincial and federal aluminum guideline do not account for the ameliorating effects of these water quality parameters.

Because of these deficiencies in the guideline and the proliferation of more recent studies looking into the toxicity of aluminum conducted in the last 25 years, alternative site-specific chronic and acute toxicity guidelines for aluminum that incorporate water hardness are proposed (see Appendix 6.7-B for details).

The USEPA has set acute and chronic aluminum guidelines at 0.75 mg/L and 0.087 mg/L, respectively (USEPA 1988) for freshwaters with pH in the range between 6.0 and 9.0; these guidelines are, by themselves, substantially higher than those set in BC and Canada. However, after review of the USEPA ambient water quality guidelines and an updated database that included 120 studies from the primary and grey literature for the US EPA Region IX, Parametrix (2006) recommended the following hardness-based water quality criteria for aluminum for the protection of freshwater aquatic biota:

Recommended acute aluminum criterion=e(0.8327[ lnhardness]+3.8971)

Recommended chronic aluminum criterion=e(0.8327[ lnhardness]+2.9800)

Using these equations, the proposed acute and chronic aluminum concentrations calculated for each phase of the mine based on the annual average water hardness, respectively,

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Table 6.7.2-33: Recommended Site-Specific Acute and Chronic Aluminum Guideline Criteria for the Protection of Freshwater Aquatic Life in Lower Lime Creek

Predicted Annual Acute Aluminum Chronic Aluminum Project Phase Average Hardness Toxicity Criterion Toxicity Criterion (mg/L of CaCO3) (mg/L) (mg/L) Construction 59 1.47 0.59 Operations 128 2.80 1.12 Closure 56 1.41 0.56 Post-closure 105 2.37 0.95

Note: mg/L of CaCO3 miligram per litre of CaCO3

All of the predicted dissolved aluminum concentrations in lower Lime Creek during all phases of the Project would be below these recommended alternative guideline criteria (Table 6.7.2-34). Use of these alternative guidelines is considered appropriate because dissolved aluminum concentrations in lower Lime Creek have exceeded the BC MOE 30- day average guideline (0.05 mg/L) under current baseline conditions (see Section 6.5-A Appendix 2 of the Surface Water Quality Baseline) and the Ambient Water Quality Criteria for Aluminum (BC MOE 2006) indicates that “if natural background levels exceed the 30-day average or maximum acceptable limit, then the increase in dissolved aluminum above background to be allowed, if any, should be based on site-specific conditions.” Consideration of water hardness in Lime Creek in the proposed toxicity criteria above incorporates site-specific conditions.

Table 6.7.2-34: Comparison of Median and 95 percentile Dissolved Aluminum Concentrations to Alternative Site-Specific Acute and Chronic Aluminum Guideline Criteria for Lower Lime Creek

Predicted 95th Chronic Acute Aluminum Predicted Median Percentile Aluminum Aluminum Project Phase Toxicity Aluminum Concentration Toxicity Criterion Criterion (mg/L) Concentration (mg/L) (mg/L) (mg/L) Construction 1.47 0.079 0.59 0.026 Operations 2.80 0.205 1.12 0.064 Closure 1.41 0.075 0.56 0.025 Post-closure 2.37 0.106 0.95 0.053

It is well understood that pH is the principle water quality parameter determining the toxicity of aluminum in freshwaters. In general, aluminum toxicity to fish and other aquatic biota increases significantly as pH decreases below 6.0 or increases above 8.0. Above and below these pH thresholds, aluminum solubility increases making the toxic aluminum species of aluminum more bio-available to aquatic biota (Driscoll et al. 1996; Sparling and

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Lowe 1996). At pH near 7, aluminum is relatively insoluble and gibbsite (i.e., a non-toxic form of aluminum hydroxide Al(OH)3) formation dominates (Schecher and McAvory 1992 in Gensmer and Playle 1999).

Although a similar equation that accounts for the modifying factors of dissolved organic carbon and fluoride is not available, it is possible that the concentrations of dissolved organic carbon (DOC) likely to occur and fluoride predicted to occur in lower Lime Creek would further decrease the likelihood of acute and chronic aluminum toxicity to Dolly Varden. Dissolved organic carbon was not modelled in the surface water quality model. However, total organic carbon (TOC) concentrations in Lime Creek were, on average, 1.99 mg/L under baseline conditions in 2009 and 2010 and ranged between 1.0 mg/L and 3.95 mg/L (Appendix 6.5.-A, Surface Water Quality baseline). Total organic carbon concentrations in Lime Creek are not expected to change due to the mine because no significant source of organic carbon would be added or removed during any phase of the mine. Therefore, because DOC typically comprises 90% of TOC concentrations (B.Ott pers. comm.), during months when TOC concentrations are greater than 3 mg/L, we can expect that some of the dissolved aluminum in Lime Creek would become bound to organic carbon and become less available to interact at fish gills. Gunderson et al., (1994) found that humic acid (i.e., a source of dissolved carbon) concentrations >3 mg/L reduced the sub-lethal effects (i.e., chronic 16-day tests) of aluminum toxicity on both growth and survival of rainbow trout in near neutral and weakly alkaline pH waters at aluminum concentrations up to 5 mg/L. Parkhurst et al. (1990) found that DOC concentrations >1 mg/L increased 21 day survival of brook trout (Salvelinus fontinalis) exposed to total aluminum at concentrations up to 2.76 mg/L in acidic waters with pH <5.6. Although both authors found significantly higher survival and growth in their test fish when humic acid concentrations were >4 mg/L (concentrations of dissolved organic carbon unlikely to be seen in Lime Creek) and both authors cautioned about extrapolating results using commercially produced humic acids and dissolved organic carbon sources found in natural streams, it is reasonable to assume that concentrations of dissolved organic carbon likely to occur in Lime Creek would have some ameliorating effect on aluminum toxicity to Dolly Varden.

Flouride concentrations predicted to occur in Lime Creek during construction, operations, closure, and post-closure are may also reduce potential aluminum toxicity to Dolly Varden due to predicted guideline exceedences. Fluoride forms a ligand complex with aluminum (AlF2+) that has two beneficial effects on aluminum toxicity to fish: 1) it competes with Al3+ at binding sites on the gill surface; and 2) it reduces the effects of aluminum due to aluminum precipatiation on the gills due increasing the formulation of non-toxic gibbsite at the same pH (Wood et al., 1999 in Gensemer and Playle 1999). The affinity of the AlF2+ complex to negatively charged gill surfaces is very close to that of the aluminum-gill complex however (Wilkinson et al., 1990 in Gensemer and Playle 1999). Therefore, very high AlF2+ concentrations (>10 µM F-) are necessary to show significant reductions in Al-complexing on the gill surfaces. It is unclear whether the predicted fluoride concentrations in Lime Creek during the operations, closure and post-closure phases of the Project would be sufficient to have an effect on aluminum toxicity to Dolly Varden.

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Charr of the genus Salvenilus (of which Doly Varden are apart) appear to be more tolerant of dissolved aluminum than other fish species. Wood et al. (1988 a,b) found that adult brook trout (Salvelinus fontinalis) exposed for 10 weeks in acidic (pH 5.2) water with aluminum concentrations up to 0.15 mg/L could survive and were better able to tolerate a 48 hour exposure to more acidic (pH 4.8) and higher aluminum concentrations (0.33 mg/L) than fish not previously exposed to aluminum. In a laboratory experiment conducted on seven freshwater fish species, Poleo et al., (1997) found Arctic charr (Salvelinus alpinus) to be the most tolerant fish species to dissolved aluminum concentration of 0.242 mg/L under acidic conditions (pH <5.5). In a follow-up study, Poleo and Bjerkely (2000) found that although initial morality rates were significantly higher in acidic, aluminum-rich (0.480 mg/L alumimium) water than in acidic, aluminum-poor (0.099 mg/L) water, there was a systematic decrease in mortality with increasing residence time in the acidic, aluminum-rich test water. This finding confirmed similar observations in their 1997 study and indicates that Arctic char can become acclimated to acidic-aluminum rich water. As Allin and Wilson (1999) found with rainbow trout however, such acclimation has a metabolic cost in the form of reduced feeding rates and depressed swimming behaviour.

The discussion above provides a hypothesis that the predicted exceedences of the BC and Canadian water quality guidelines for aluminum would not adversely affect the growth and survival of Dolly Varden in lower Lime Creek. The principle lines of evidence for this assessment are: 1) that the existing provincial and federal guidelines are overly conservative for the protection of aquatic life given the concentration of other water quality parameters that have direct influence on the toxicity of aluminum to freshwater biota; 2) predicted aluminum concentrations would be at least one order of magnitude lower than the alternative site-specific water quality criteria proposed for aluminum in Lime Creek; and 3) the pH of Lime Creek would be maintained near neutral throughout the life of the mine (including post-closure when a water treatment plant would be constructed if water quality objectives could not be met due to ML/ARD drainage).

6.7.2.10.1.4 Cadmium 6.7.2.10.1.4.1 Ecological Toxicity Profile Cadmium has no essential nutritional or biological value to plants or animals (Eisler 1985). Effects in freshwater biota include inhibited reproduction, reduced growth, and high mortality (Eisler 1985). Cadmium manifests greater teratogenic effects than other metals, including arsenic, copper, indium, lead, and mercury (Ferm and Layton 1981, as cited in Eisler 1985). Cadmium appears to biomagnify in lower trophic levels only, as demonstrated in tests of a freshwater food chain comprising algae (Chlorella vulgaris), cladocera (Daphnia magna) and fish (Leucospius delineatus) (Ferard et al. 1983, as cited in Eisler 1985).

In fish, tests show that cadmium affects gill, kidney, intestines, or other tissues, depending on cadmium concentration exposure duration (Eisler 1985; Beširović et al. (2010). The mode of toxic action may include induction of DNA damage (Bertin and Averbeck 2006; Viau et al. 2008), activation of proteases (Hsu et al. 2009; Lee et al. 2007), disturbance of Ca2+in ion homeostasis (Yang et al. 2007), damage to mitochondria (Belyaeva et al. 2006), and

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The bioavailability and toxicity of cadmium, and its uptake by aquatic organisms, is affected by many physical, chemical, and biological factors. In freshwater systems, cadmium predominantly occurs as the free cadmium ion (Cd2+) and as cadmium carbonate and cadmium chloride (Mantoura et al. 1978, as cited in CCME3). The mobility and bioavailability of cadmium is diminished under conditions of high pH, high water hardness, and high organic content (CCME3). At pH >9, solubility decreases and cadmium hydroxide is formed (Moore and Ramamoorthy 1984, as cited in CCME3). Also under reducing conditions, cadmium and sulphur will form insoluble cadmium sulphide (Muramoto 1982, as cited in CCME3).

The sorption processes are very important in controlling the bioavailability of cadmium (CCME3, Trivedi and Axe 1999). Cadmium is removed from suspension by replacing calcium in the lattice structure of carbonate minerals, and by co-precipitating with hydrous iron, aluminum and manganese oxides (CCME3). In the presence of organic content, cadmium will adsorb to humic substances and other organic complexing agents (U.S. EPA 1979, as cited in CCME3). Dissolved organics appear more beneficial to cladocerans than to fish in lowering the toxicity of cadmium(Geisy et al 1977, as cited in CCME3). Interaction of cadmium with zinc enhances the toxicity of cadmium in aquatic plants while selenium decreases toxicity in aquatic plants and animals (Reeder et al. 1979a, as cited in CCME3). However, selenium can increase retention and modify distribution of cadmium within organisms (CCME3). Bioaccumulation of cadmium in freshwater biota appears to increase with higher temperatures (Remacle at al.1982; Rombough and Garside 1982, as cited in CCME3) and with lower concentrations of complexing agents (e.g., dissolved organic carbon, carbonate).

6.7.2.10.1.4.2 Water Quality Model Results Dissolved cadmium concentrations in lower Lime Creek were predicted to exceed the BC MOE maximum acceptable limit and the CCME guideline level for the protection of aquatic life during all phases of the Project. This guideline (0.000023 mg/L) for lower Lime Creek was based on the assumption of a water hardness of 65 mg/L, the site-wide mean hardness determined during monthly water quality sampling conducted in 2009 and 2010. The reader is referred to the Surface Water Quality assessment (Section 6.6) and Appendix 6.6-B for specific details and results of the water quality modelling.

Mean and peak monthly dissolved cadmium concentrations were predicted to be highest during operations with average annual and monthly peak concentrations increasing steadily over the 15 year operations period to a maximum peak concentration of 0.000833 mg/L in Year 13. Annual average and monthly peak dissolved cadmium concentrations decrease and remain relatively steady while the open pit re-fills during closure. Annual average cadmium concentrations during closure were predicted to be 0.000163 mg/L.

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Cadmium concentrations during post-closure were predicted to increase sharply during the first year once the pit begins to over-flow into Lime Creek with a maximum monthly cadmium concentration of 0.000801 mg/L. Cadmium concentrations were then predicted to decrease exponentially to an average annual equilibrium in a range between 0.000039 mg/L to about 0.00056 mg/L with seasonal fluctuations.

6.7.2.10.1.4.3 Residual Effects Assessment Freshwater biota are more sensitive to cadmium toxicity than marine biota (Eisler 1985) and salmonids, such as Dolly Varden, are the most sensitive fish families to cadmium toxicity (CCME3). As the ecological toxicity profile of cadmium above shows, the potential consequences of elevated cadmium concentrations in lower Lime Creek on Dolly Varden could be chronic (i.e., reduced growth and health of individuals due to internal organ damage) or acute (i.e., reduced mortality of individuals) and could eventually lead to the extirpation of Dolly Varden from lower Lime Creek.

Such a consequence is unacceptable to the proponent and the proponent is committed to ensuring that the potentially chronic and acute toxic effects of cadmium do not affect Dolly Varden or any other fish speices or freshwater life form in Lime Creek during any phase of the Project. To do so, the proponent would commit to monitoring cadmium concentrations at the Patsy Creek discharge site, in upper Lime Creek, and in lower Lime Creek throughout the Project and would commit to corrective action, including water treatment to lower cadmium concentrations in the mine effluent, if warranted.

However, there is uncertainty regarding the cadmium concentrations predicted to occur in lower Lime Creek. This is because the cadmium concentrations in lower Lime Creek were driven by the predicted cadmium concentrations from the source loadings (i.e., waste rock factilities, process effluent). These were assumed to range between 0.00013 mg/L in the supernatant bulk tailings during operations to 0.0071 mg/L in the cyclone sand dams during operations and closure and 0.0043 mg/L in the East WRMF seepage during operations. Thus, any cadmium added to the background receiving environment (which was always >0.000015 mg/L) from the source terms always results in a predicted cadmium concentration in Lime Creek above the interim BC MoE maximum acceptable guideline and CCME guideline cadmium concentration of 0.000023 mg/L..

Additional modeling is necessary using more accurate cadmium loading concentrations before it can be determined if treatment of mine effluent would be necessary to reduce the potential effects of cadmium on Dolly Varden. The proponent is committed to doing this additional modeling and to the treatment of mine effluent for cadmium if warranted.

6.7.2.10.1.5 Chromium 6.7.2.10.1.5.1 Ecological Toxicity Profile Chromium is a naturally occurring element found in animals, rocks, plants, soil, and volcanic dust and gases (ATSDR, 2008). It can exist in nine different oxidation states with chromium II, chromium III, and chromium VI being the most common (CCME 1999).

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Trivalent chromium (chromium III) is the most stable oxidative form of chromium and is considered an essential nutrient in vertebrates at levels of 50 to 200 micrograms per day. Trivalent chromium at these rates acts as an essential co-factor in insulin production and forms complexes with protein, amino acids, and other organic acids (Eisler, 2000; Irwin, 1997). Hexavalent chromium (chromium VI) is the principle oxidative state of chromium in surface waters comprising between 10% and 60% of total dissolved chromium in unfiltered samples and between 70% and 90% of total dissolved chromium in filtered samples (CCME 1999).

Both trivalent and hexavelent chromium are known to be toxic at elevated concentrations in freshwater ecosystems and guidelines for the protection of freshwater aquatic biota from trivalent and hexavalent chromium exist in British Columbia and Canada. However, because the acute and chronic effects of hexavalent chromium to freshwater aquatic biota occur at lower concentrations than trivalent chromium and because hexavalent chromium is the principle oxidative state of chromium in freshwater, only the toxicological profile of hexavalent chromium is discussed further.

Hexavalent chromium has a high oxidising potential, is high soluble, and is easily permeates biological membranes, cells, and body walls. At elevated concentrations, the high oxidising potential of hexavalent chromium can cause DNA damage, organ damage and cancer. However, the mechanisms of chromium toxicity and carcinogenicity are very complex (ATSDR, 2008).

Hexavalent chromium can be reduced to the lower toxicity trivalent state by the presence of dissolved sulphur, iron, fulvic acid, low molecular weight organic compounds, and proteins inside organic cells (CCME 1999). In general, toxicological properties of hexavalent chromium salts to aquatic organisms, including fish and benthic macro-invertebrates, are significantly influenced by a variety of biological and abiotic factors. These include biotic variables such as the species, age, and developmental stage of the receptor organism and abiotic variables such as temperature, pH, salinity and alkalinity of the water, and the interaction of chromium with other contaminants (e.g., sulphur, iron). For example, high water hardness tends to exacerbate toxic effects of hexavalent chromium to freshwater biota (Eisler, 2000). The duration of exposure to hexavalent chromium also determines its toxicity (Irwin 1997; Eisler 2000). However, hexavalent chromium is known to have a long residence time in surface and groundwater (CCME 1999).

6.7.2.10.1.5.2 Water Quality Model Results Mean monthly total dissolved chromium concentrations in lower Lime Creek (approximately 0.0004 mg/L) were predicted to be below the interim BC MoE maximum acceptable guideline3 and CCME water quality guideline for hexavalent (0.001 mg/L) and trivalent (0.0089 mg/L) chromium for the protection of freshwater aquatic biota during all phases of the Project.

3 The BC MoE maximum acceptable limit guideline for trivalent and hexavalent chromium is currently being reviewed by the Ministry. In the interim, the BC MoE maximum acceptable limit guideline for chromium is based on the CCME guidelines.

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The maximum predicted total dissolved chromium concentrations in lower Lime Creek were predicted to range between 0.0011 and 0.0013 mg/L during November and December of each year during construction, operations, closure, and post-closure phases. If the predicted total dissolved chromium concentrations are assumed to be entire comprised of hexavalent chromium (a conservative assumption), these predicted maximum concentrations would slightly exceed the interim BC MoE maximum acceptable guideline and the CCME guideline for hexavalent chromium (0.001 mg/L).

6.7.2.10.1.5.3 Residual Effects Assessment Although the predicted maximum total chromium concentrations exceed the interim BC MoE maximum acceptable guideline and the CCME guideline for hexavalent chromium, potential adverse effects to Dolly Varden in Lime Creek may not necessarily occur. This likelihood exists for the following reasons:

 The actual concentration of bioavailable hexavalent chromium in lower Lime Creek may be lower than predicted by the water quality model. This potential exists for two reasons. First, the water quality model predicts total dissolved chromium and not individual chromium species. As mentioned above, hexavalent chromium typically comprises 10% to 60% of total dissolved chromium in unfiltered samples (CCME 1999). Therefore, if it is assumed that hexavalent chromium comprises 60% of the total dissolved chromium concentrations predicted by the model4, the maximum concentration of hexavalent chromium predicted to occur in lower Lime Creek would be 0.00078 mg/L. At this concentration, hexavalent chromium would not exceed the interim BC MoE maximum acceptable limit or the CCME guideline for hexavalent chromium (0.001 mg/L). Only if the proportion of hexavalent chromium was assumed to be >80% of the total predicted dissolved chromium would the existing guidelines continue to be exceeded. Second, the model assumes chromium acts conservatively in the water column and does not account for any of the potentially toxicity reducing interactions between chromium and other parameters predicted in the Lime Creek water. Such interactions could reduce the concentration of bioavailable hexavalent chromium Dolly Varden in lower Lime Creek would be exposed to.  The CCME WQG for chromium may be overly protective for Dolly Varden in lower Lime Creek. The CCME hexavalent chromium guideline was derived by multiplying the 14-day Lowest Observable Effect Concentration (LOEC) of 0.01 mg/L for Ceriodaphnia dubia, a freshwater crustacean (as determined by Hickey (1999)), by a safety factor of 0.1 (CCME 1999). However, invertebrates, such as Ceriodaphnia dubia, are known to be more sensitive to hexavalent chromium than teleost fish (CCME 1999). For example, the acute toxicity estimates for hexavalent chromium

are <0.010 mg/L for Ceriodaphnia dubia (24 hr EC50) and 0.015 mg/L for Daphnia magna (48 hr EC50) while acute toxicity estimates are 0.1 mg/L for rainbow trout

4 The actual proportion of hexavalent chromium in Lime Creek is unknown and this assumption cannot be validated because more detailed analysis of baseline water chemistry and source loading terms would be necessary to model the predicted concentrations of hexavalent chromium in lower Lime Creek

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(72 hr TLm). Chronic toxicity estimates for hexavalent chromium are 0.01 mg/L (14 day LOEC) and 0.5 mg/L (21 day LC50) for Ceriodaphnia dubia and Daphnia magna, respectively, while chronic toxicity estimates are 0.01 mg/L (LOEC) and 0.1 mg/L (60 day LOEC) for Atlantic salmon (Salmo salar) and rainbow trout, respectively. The CCME WQG, like all CCME guidelines, was designed “to protect all forms of aquatic life and all aspects of the aquatic life cycles, including the most sensitive life stage of the most sensitive species over the long term” throughout Canada. Because the guideline was based on an invertebrate taxa more sensitive to hexavalent chromium than fish species within the same subfamily as Dolly Varden (Salmoninae), the predicted guideline exceedences may not result in acute or chronic health effects to Dolly Varden.  Although no studies were located that specifically assessed hexavalent chromium toxicity to Dolly Varden (Salvelinus malma), toxicological studies of the effects of chromium to brook trout (Salvelinus fontinalis), a species within the same genus as Dolly Varden, suggests that the predicted total chromium concentrations in lower Lime Creek would not result in acute or chronic health effects to Dolly Varden. USEPA (1995) collected acute and chronic toxicity data for brook trout to derive the AWQC for chromium (VI) in the United States. Acute effects to brook trout from hexavalent chromium were not expected to occur below 59 mg/L and chronic effects were not expected to occur below concentrations of 0.264 mg/L. Even if predicted total chromium concentrations were dominated by the chromium (VI) species, the predicted chromium concentrations would be below these thresholds indicative of adverse effects to fish closely related to Dolly Varden.  Based on these lines of evidence, predicted total chromium concentrations in lower Lime Creek are not expected to adversely affect Dolly Varden. However, the proponent acknowledges the uncertainty in the models used to predict total chromium concentrations in lower Lime Creek, the uncertainty regarding the actual proportion that hexavalent chromium would comprise of the total chromium concentration predicted in lower Lime Creek during the Project, and the uncertainty of using surrogate species to determine the acute and chronic toxicity thresholds for other species (i.e., there is a wide difference in tolerance to chromium amongst different freshwater fish species (Irwin 1997). As such, the proponent is committed to working with Environment Canada, the BC Ministry of Environment, and the Nisga’a Lisims Government to develop site-specific guidelines for chromium in Lime Creek and to meeting these guidelines throughout the life of the Project.

6.7.2.10.1.6 Copper 6.7.2.10.1.6.1 Ecological Toxicity Profile Copper occurs abundantly throughout the environment and is an essential component of many biological processes in plants and animals. Toxic effects of copper in aquatic invertebrates vary with phylum: effects include disruption of membrane permeability and cytoplasmic function in snails, and impaired osmotic and ionic regulation, antennal gland degeneration, and respiratory enzyme inhibition in crayfish Orconectes rusticus (Alberta

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Environmental Protection 1996). In fish, toxic effects of copper include interference with osmoregulation (Hodson et al. 1979 , as cited in Eisler 1998 ), oxygen transport, and energy metabolism (ATP synthesis) (Hansen et al. 1992b , as cited in Eisler 1998). Copper disrupts gill function in rainbow trout by interfering with ion regulation (Reid and McDonald 1991, as cited in Eisler 1998), inhibiting sodium influx, and stimulating sodium efflux (Lauren and McDonald 1986, Reid and McDonald 1988, as cited in Alberta Environmental Protection 1996).

In addition to concentration, toxicity of copper depends on numerous physical, chemical, and biological factors. Copper exists in four oxidation states of which the cupric ion (Cu+2) is the most common and toxic form encountered by aquatic life (Eisler 1998). The cupric ion, + the copper hydroxide ion (Cu(OH) ) and copper carbonate (Cu(CO3) make up 98% of dissolved copper in freshwater systems (Nelson et al. 1986 , as cited in Alberta Environmental Protection 1996). The cupric ion is dominant at pH <6, while the aqueous copper carbonate complex is dominant from pH 6.0 to 9.3 (US EPA 1980, as cited in Eisler 1998).

The bioavailability of the cupric ion, and thus its toxicity, decreases significantly through complexation with inorganic and organic compounds (Alberta Environmental Protection 1996). In general, the formation of these compounds is affected by pH, alkalinity, hardness, temperature (Eisler 1998), and by the presence of humic and fulvic acids (Alberta Environmental Protection 1996). Copper readily complexes with fulvic acids and dissolved organic matter (Gardner and Ravenscroft 1991; Lin et al. 1994, as cited in Alberta Environmental Protection 1996). In hard, moderately polluted water, 43 to 88% of the copper is bound up with suspended solids and removed from biologically availability (Shaw and Brown 1974, as cited in Eisler 1998).

In living organisms, copper interacts with many other essential and non-essential trace elements, and the simultaneous effect exerted on toxicity from both elements may be additive (sum of individual toxic effects), synergistic (greater than the sum of individual toxic effects), or antagonistic (less than the sum of individual toxic effects) (Alberta Environmental Protection 1996, and Kirchgessner et al. 1979, as cited in Eisler 1998). Examples include synergistic effects for ova of brown trout (Salmo trutta) from copper-iron interactions, and from copper-aluminum interactions (Sayer et al. 1991, as cited in Eisler 1998), and synergistic effects from copper-zinc interactions for a broad range of aquatic organisms (Eisler 1998). Studies indicate that sensitivity to copper in fish may decrease with older lifestages and with size, depending on the species (Alberta Environmental Protection 1996). Increased toxic effects have also been associated with intermittency (versus continuity) of exposure, increased temperature, decreased pH for fish species sensitive to pH, and increased pH for fish species that are not sensitive to pH (due to diminished competition, at higher pH, of cupric and hydrogen ions at receptor sites) (Alberta Environmental Protection 1996). Decreased toxic effects have been observed with increasing alkalinity, increasing hardness, and increasing dissolved oxygen, again, depending on the fish species (Alberta Environmental Protection 1996).

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6.7.2.10.1.6.2 Water Quality Model Results The water quality model predicted that average annual and peak monthly copper concentrations in lower Lime Creek would not exceed the BC MOE maximum (hardness adjusted) guideline (Singleton, 1987) during any Project phase. However, peak and average monthly copper concentrations were predicted to exceed the hardness adjusted BC MOE 30-day and CCME (formerly CCREM 1987) guidelines during the operations and post- closure phases, respectively. During construction and closure phases, copper concentrations were predicted to be below the BC 30-day average, BC maximum acceptable and the CCME guidelines.

During the operations phase, monthly peak copper concentrations were predicted to range from 0.0006 to 0.0056 mg/L. Therefore, in some months, copper concentration in Lower Lime Creek would exceed the BC MOE 30-day (0.005 mg/L) and CCME (0.003 mg/L) guidelines adjusted to hardness values between 41 and 333 mg/L as CaCO3. For the first five years of post-closure, copper concentrations were predicted to be in the range between 0.0012 and 0.0021 mg/L which exceeds the BC MOE 30-day (0.004 mg/L) and CCME (0.003 mg/L) guidelines based on hardness values between 56-120 mg/L as CaCO3.

6.7.2.10.1.6.3 Residual Effects Assessment The aquatic freshwater Water Quality Guidelines (WQG) for total copper established by the BC MOE (Singleton 1987) are based on hardness-dependent equations and are as follows:

When hardness is less than or equal to 50 mg/L as CaCO3:

Chronic Guideline (µg/L) = 2 µg/L (Equation 1)

When hardness is greater than 50 mg/L as CaCO3:

Chronic Guideline (µg/L) = 0.04 x (hardness) (Equation 2)

Regardless of hardness, the acute guideline is as follows:

Acute Guideline (µg/L) = 0.094 x (hardness) + 2 (Equation 3)

The federal guideline (CCME formerly CCREM) is also hardness-based and is as follows:

WQG (µg/L) = e0.8545 x ln(hardness) -1.465 x 0.2 (Equation 4)

Where WQG is not lower than 2 µg/L and hardness = mg/L as CaCO3.

Both the BC MOE and the CCME copper guidelines are potentially overly conservative for the protection of freshwater aquatic biota and have a high degree of uncertainty due to their derivation. For example, the BC MOE did not base their acute WQG equation (Equation 3) on acute data. Instead, they derived their equation from USEPA’s chronic criteria which were based on chronic effects data. Also, an arbitrary ordinate intercept of 2 µg/L was added to the equation to ensure that the acute criterion was higher than the chronic

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In 2007, the USEPA updated the copper AWQC. The 2007 update includes LC50 and EC50 values reported from 350 acute toxicity tests for 15 species including 22 species of fish. Species included sensitive salmonid fish such as rainbow trout (Oncorhynchus mykiss) and Coho salmon (Oncorhynchus kisutch). These data were used by the USEPA to revise their acute and chronic equations which are:

0.9422* ln (hardness) – 1.700 Acute Guideline (ug/L) = e (Equation 5)

0.8545 * ln (hardness) – 1.702 Chronic Guideline (µg/L) = = e (Equation 6)

The 2007 USEPA chronic AWQC, unlike the existing regulatory approach by the BC MOE (which is extrapolated chronic exposure based on acute data), is based on experimental data showing the relationship between chronic and acute effects. The current USEPA chronic AWQC for copper (2007) was derived from chronic data for 6 invertebrates species and 10 fish species. Fish species included sensitive salmonid fish species such as rainbow trout (Oncorhynchus mykiss). Overall, USEPA’s approach uses a more thorough and up-to- date data set and derives a logarithmic relationship between hardness based on rigorous statistical review of the data and derives the slope using the species sensitivity distribution approach. Based on USEPA’s approach, alternative hardness adjusted copper WQGs in lower Lime Creek would be:

Project Phase Construction Operations Closure Acute (mg/L) 0.014 0.0364 0.0130 Chronic (mg/L) 0.006 0.0110 0.0054

Predicted copper concentrations in lower Lime Creek during operations and closure would be lower than these alternative, site-specific guidelines if adopted.

Like the existing BC MOE and CCME copper guidelines, the intent of these alternative WQGs is to protect a group of diverse genera from the harmful effects on copper. No studies were located that assessed copper toxicity specifically with respect to Dolly Varden (Salvelinus malma). However, toxicity studies in the scientific literature for rainbow trout which is in the same subfamily (Salmoninae) as Dolly Varden, were reviewed by USEPA during their update of acute and chronic copper guidelines.

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As indicated above, copper forms complex species in freshwater environments. To assess the potential effects of such likely speciation in Lower Lime Creek, a biotic ligand model (BLM) was developed for copper. Details of this BLM modeling are provided in Appendix 6.7-C). Essentially, the BLM links bioavailable concentrations of copper to toxicological effects, and accounts for the effects of several contributing factors including hardness, pH, temperature, and the concentration of other dissolved ions. HydroQual was used to develop and parameterise the BLM.

The toxicity data compiled by USEPA and the HydroQual (2007) BLM model indicated that, under site-specific conditions in Lower Lime Creek, acute and chronic effects to freshwater aquatic species for copper are expected to occur at the following concentrations:

Project Phase Construction Operations Closure Acute (mg/L) 0.014 0.0174 0.0141 Chronic (mg/L) 0.0082 0.009 0.0083

The proposed site-specific acute and chronic WQGs determined from the USEPA AWGC approach are less than the lethal and sub-lethal effects concentrations for aquatic species (including the subfamily Salmoninae) used to develop the BLM model. In summary then, the water quality model predicts that copper concentrations in Lower Lime Creek would be below site-specific WQGs derived by the USEPA method and below the BLM predicted acute and chronic copper concentrations for all project phases. Therefore, predicted concentrations of copper in Lower Lime Creek are not expected to adversely affect Dolly Varden.

6.7.2.10.1.7 Mercury 6.7.2.10.1.7.1 Ecological Toxicity Profile Mercury is one of the most toxic metals in nature and has no essential biological function (Eisler 1987). In vertebrates, mercury is mutagen, teratogen, carcinogen (Eisler 1987), and neurotoxicant (CCME 2000). In elevated concentrations, mercury alters genetic and enzymatic systems, damages the immune system, the central nervous system, the reproductive system, and causes birth defects in humans and a wide variety of vertebrate animals (USGS 2000).

In the aquatic environment, mercury occurs as elemental mercury (Hgo), mercurous ion (Hg22+), mercuric ion (Hg2+), and as organomercury compounds such as methylmercury. The mercuric ion is the most toxic inorganic form (Eisler 1987) while methylmercury is the most toxic of all forms of mercury. Methylmercury binds to sulfhydryl groups in proteins, and is therefore retained and bioaccumulated in aquatic biota (Clarkson 1994, as cited in CCME 1), and its concentration increases with increasing levels of the food chain (i.e., biomagnifies) (CCME2).

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The bioaccumulation of mercury in fish, and the toxic effect of mercury in all aquatic biota, is affected by numerous physical, chemical, and biological factors (Environment Canada 2002, as cited in CCME2). In general, lakes with low calcium (<5 mg/L), low alkalinity (acid neutralising capacity of 50 μeq/L or less), and low pH (<6) are associated with elevated mercury concentrations in fish (Grieb et al. 1990 and Spry and Wiener 1991, as cited in CCME2). The toxicity of mercury decreases with increased selenium concentration, salinity, and dissolved oxygen, and with decreased temperature (reviewed by Cuvin-Aralar and Furness 1991; Heit and Fingerman 1977; MacLeod and Pessah 1973; McKenney, Jr. and Costlow, Jr. 1981; Slooff et al. 1991; Snell et al. 1991, as cited in CCME2). However, toxicity is not significantly affected by water hardness as other metals such as aluminum and copper, which decrease in toxicity with increasing hardness (Keller and Zam 1991, as cited in CCME2).

In freshwater systems, mercury can settle and become trapped in sediment, it can be dispersed into the water column, or it can be methylated (USGS). Methylmercurcy is the net product of physical and microbial methylation and demethylation processes (CCME2). It typically comprises less than 10% of the total mercury in freshwater systems (CCME2). However, methlymercury is typically ten times more toxic than inorganic mercury to aquatic plants, fish, and invertebrates (CCME2).

Methylmercury production is increased in situations where: 1) there is a new source of inorganic mercury introduced to the water column; 2) there is a new source of organic nutrients to the water that increases microbial activity; and 3) other physical and chemical properties (e.g., water temperature, dissolved oxygen concentration, pH) are condusive to microbial decomposition of the new organic nutrient source. Flooding for new hydroelectric reservoirs is a prime example of a situation where methylmercury production can be elevated.

Methylmercury can enter the food chain and become biomagnified in upper trophic levels (e.g., in predatory fish), or it can be demethylated and released into the atmosphere through volatilisation (USGS). Microbial demethylation is the primary mechanism for methymercury degradation in freshwater systems (CCME1).

6.7.2.10.1.7.2 Water Quality Model Results Mean mercury concentrations in lower Lime Creek were predicted to be below the BC MOE 30-day average guideline (2006b) of 0.00002 mg/L and the CCME (2007) guidelines (0.000026 mg/L) for the protection of freshwater aquatic life during construction, operation, and closure phases of the Project. However, the 95th percentile and maximum values for mercury, observed as seasonal fluctuations, were predicted to exceed both guidelines during operations and during the first three or four years of the post-closure.

Average and peak mercury concentrations during closure were predicted to be lower than during operations and post-closure phases and below both guideline levels. This was attributed to pit filling and the stored loads from the pit walls and the waste rock.

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The peak mercury concentrations in lower Lime Creek during the initial years of post-closure were predicted to exceed both guideline levels. However, mercury concentrations were predicted to exponentially decrease during post-closure until reaching an equilibrium concentration between 0.00001 and 0.000015 mg/L, concentrations below both the BC 30-day average and CCME guideline levels. The initial spikes and exponential decrease in mercury during post-closure were attributed to the time it takes for the Open Pit to reach a new mercury equilibrium after the TMF surplus water is directed to the pit.

6.7.2.10.1.7.3 Residual Effects Assessment Predicted mercury concentrations in lower Lime Creek were driven by the predicted mercury concentrations in the source term loadings coming from the various waste rock facilities and process tailings. Mercury concentrations in humidity cells used to determine mercury loading concentrations from these source terms were frequently below laboratory detection limits (0.00001 mg/L). As a result, the detection limit concentration of 0.00001 mg/L was used in the water quality model for those time periods and source term loadings when mercury concentrations in the source terms were below laboratory detection limits.

This assumption about the source term mercury concentrations raises the uncertainty surrounding the predicted mercury concentrations in lower Lime Creek during all phases of the Project. Because the detection limit was used for “non-detect” lab results, this assumption would over-estimate and not under-estimate the mercury concentrations in lower Lime Creek. It is possible then, and likely, that mercury concentrations in lower Lime Creek would be lower than the BC 30-day average and CCME mercury guidelines during all phases of the Project, including operations and post-closure phases when mercury concentrations are currently predicted to be higher than these guidelines.

Taking a conservative view and assuming the predicted mercury concentrations during operations and post-closure would be accurate, it is still unlikely that Dolly Varden in lower Lime Creek would be adversely affected by changes in mercury concentrations in Lime Creek water. This is because:

 Acute toxicity of methylmercury in rainbow trout was found to ranges in concentration from 0.024 to 0.125 mg/L (24- to 96-h) Wobeser 1975, as cited in CCME2). This is a minimum of three orders of magnitude higher than the predicted mercury concentrations in lower Lime Creek during operations and post-closure phases;  There is the potential for methylmercury production due to the flooding of the TMF footprint area. Mercury concentrations within the O2 soil type (thick organic deposits) around the Patsy Lake area were below the laboratory maximum detection limit (0.0005 mg/g) in 2010 done for the soil metal concentration analyses. Sampling in the mineral soil layers around Patsy Lake in 2009 indicated mercury concentrations between 0.00002 mg/g and 0.0001 mg/g). These data suggest that the source of inorganic mercury available to be methylated is low.  Juvenile Dolly Varden (the life stage most likely to be affected by any increase in mercury concentrations in lower Lime Creek) are insectivorous (i.e., feed on drifting

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benthic macro-invertebrates). Therefore, although the potential exists for biomagnification of methylmercury in juvenile Dolly Varden through benthic macro- invertebrates, this food-chain is relatively short (two or three trophic levels only) and potential increases in mercury concentrations in juvenile Dolly Varden would be expected to be small as a result (if in fact there was a new source of methylmercury in the system which there is unlikely to be due to mitigation).

Based on these lines of evidence, predicted mercury concentrations in lower Lime Creek are not expected to adversely affect Dolly Varden. However, the proponent acknowledges the uncertainty in the models used to predict mercury concentrations in lower Lime Creek and the potential for mercury toxicity to increase in higher trophic level species such as Dolly Varden. As such, the proponent is committed to working with Environment Canada, the BC Ministry of Environment, and the Nisga’a Lisims Government to develop site-specific guidelines for mercury in Lime Creek and to meeting these guidelines throughout the life of the Project.

Baseline average and maximum mercury concentrations in juvenile Dolly Varden muscle tissues (0.041 mg/Kg and 0.063 mg/Kg, respectively) were greater than the BC MOE screening guideline (0.033 mg/Kg) for the protection of piscivorous wildlife but lower than the Canadian Action Level for protection of human health (0.5 mg/Kg). Therefore, potential increases in mercury concentrations in juvenile Dolly Varden creates a potential linkage to wildlife, ecosystem health, and human health effects assessments.

6.7.2.10.1.8 Molybdenum 6.7.2.10.1.8.1 Ecological Toxicity Profile Molybdenum, an essential trace metal, is widely distributed throughout the environment. Biological functions of molybdenum include nitrogen fixation in plants, oxygen-reduction enzyme systems (Venugopal and Luckey 1978), and growth promotion in periphyton, phytoplankton, and macrophytes (CCME 1996). Molybdenum does not appear to be highly toxic to fish (Davies et al. 2005) and the toxic mode of action in molybdenum is not as well understood as other metals (Ricketts 2009).

The uptake and effect of molybdenum in aquatic biota depends on numerous abiotic and biotic factors. In natural waters, molybdenum is typically found as molybdenum sulphide 2- - (MoS2), molybdate (MoO4 ), and bimolybdate (HMoO4 ) (Jarrell et al. 1980, as cited in CCME3). The fate of molybdenum is primarily influenced by adsorption and co-precipitation with hydrous oxides of iron and aluminum (Allaway 1977, as cited in CCME 1996). At pH >7 2- the molybdate anion (MoO4 ) is predominant, while at pH <7 polymeric forms are predominant (CCME 1996).

Responses to molybdenum appear to be species specific. Some aquatic insects are known to concentrate molybdenum (Davies et al. 2005); however, molybdenum does not appear to bioaccumlate in fish (Davies et al. 2005). Acute toxicity tests performed with fish indicate

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6.7.2.10.1.8.2 Water Quality Model Results Dissolved molybdenum concentrations were predicted to stay below the BC MOE (2006b) guidelines for the protection of freshwater aquatic life during all phases of mining. However, the mean dissolved molybdenum concentrations were predicted to exceed the CCME (2007) guidelines for the protection of freshwater of aquatic life (0.073 mg/L) during all phases of mining.

Natural background concentrations of molybdenum in Lime Creek exceed the CCME guideline for molybdenum. As indicated in the 2010 surface water quality baseline study, mean molybdenum concentrations range from 0.033 mg/L to 0.214 mg/L, with a mean of 0.108 mg/L. This is not unexpected given that there is a molybdenum ore body in the Lime Creek watershed.

Molybdenum concentrations during operations (0.009 mg/L to 0.354 mg/L) were predicted to increase marginally above the background concentration. Molybdenum concentrations were predicted to stay within the range of baseline conditions during the construction (0.018 to 0.176 mg/L), closure (0.005 mg/L to 0.198 mg/L), and post-closure (0.016 mg/L to 0.198 mg/L) phases of mining.

6.7.2.10.1.8.3 Residual Effects Assessment Potential adverse effects to Dolly Varden in Lower Lime Creek from molybdenum are not likely to occur even though molybdenum concentrations were predicted to exceed the CCME guideline for molybdenum. This is because predicted molybdenum concentrations generally fall within the range of natural background concentrations and because the predicted molybdenum concentrations fall well below the BC 30-day (1 mg/L) and maximum acceptable (2 mg/L) guideline levels for the protection of freshwater aquatic biota. The water quality modeling in Lower Lime Creek predicted that peak (0.354 mg/L) and average (approximately 0.2 mg/L) molybdenum concentrations would be only slightly higher than background during the operations phase. The average molybdenum concentrations during construction, closure and post-closure were predicted to be within the range of natural background (i.e., between 0.1 and 0.2 mg/L).

Analysis of the existing guidelines provides further evidence for the likely non-toxic effect of predicted molybdenum concentrations in lower Lime Creek on Dolly Varden:

 The chronic CCME guideline for molybdenum is based a lowest chronic effect level observed in laboratory tests with Daphnia, with a 10-fold safety factor applied. Furthermore, the ameliorating effects of hardness on molybdenum toxicity have not yet been quantified. Therefore, the chronic CCME guideline is likely conservative and likely overestimates any potential adverse effects;

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 Neither the CCME nor BC MOE guidelines have quantified the ameliorating effects of hardness on molybdenum. Therefore, the guidelines may be conservative and may overestimate any potential adverse effects; and  The CCME acute guideline was derived by multiplying the lowest chronic toxicity

value, the 28-d LC50 of 0.73 mg/L for rainbow trout (O. mykiss) (Birge 1978), by a safety factor of 0.1 (CCME 1991). However, this value from Birge 1978 is controversial as different bioassays demonstrate a wide toxicity range (0.73 mg/L to >90 mg/L Mo) (Davies et al. 2005), and is likely over conservative.

These WQGs are designed to protect a group of diverse genera from the harmful effects of molybdenum. No studies were located that assessed molybdenum toxicity specifically with respect to Dolly Varden (Salvelinus malma) however information is available on species of the same genus or in the same subfamily (Salmoninae):

 Molybdenum is generally reported in the literature to be acutely lethal to various fish species at relatively high concentrations (70 mg/L to >2,000 mg/L) (Davies et al., 2005). These lethal concentrations are over two orders of magnitude higher than the predicted molybdenum concentrations in lower Lime Creek.  Duplication of Birge (1978) by Davies (2005) using similar water chemistry and bioassay protocols demonstrated that molybdenum was not acutely toxic to the early life stages of rainbow trout over 32 days up to a maximum molybdenum concentration of 400 mg/L. An additional bioassay exposing early life stages of rainbow trout to a maximum molybdenum concentration of 1,500 mg/L for 32 days

did not cause sufficient mortality to allow an LC50 to be calculated. These effects concentrations are well above predicted concentrations in Lower Lime Creek.

Since the water quality model predicts that molybdenum concentrations in the lower Lime Creek are generally similar with background, and well below consensus effects concentrations of molybdenum for salmonids, predicted concentrations of molybdenum in lower Lime Creek are therefore not expected to adversely affect Dolly Varden in lower Lime Creek.

6.7.2.10.1.9 Selenium 6.7.2.10.1.9.1 Ecological Toxicity Profile Selenium (Se) is an essential trace element that occurs both naturally and anthropogenically from a broad range of industries (Lemly 2004). However, selenium has the narrowest biological tolerance range of all essential trace elements and can become toxic at concentrations from three to five times above concentrations beneficial to aquatic and terrestrial biota (Wake et al. 2004). The toxicity of selenium is expressed through the food chain with dietary exposure, rather than waterborne exposure, as the dominant route of selenium uptake for animals at higher trophic levels including fish (Dallinger et al. 1987, as cited in Hamilton 2004). However, the precise mode of action for selenium toxicity is not clear (Mézes and Balogh 2009).

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Selenium has a very steep dose response curve due to its propensity for rapid bioaccumulation in the food chain (Lemly 2004). Predators at the top of the food chain, such as piscivorous fish, can concentrate selenium from 100 to 30,000 times above ambient levels (Lemly 2004). In sensitive fish species, the dose response can transition from no effect to reproductive failure within a few micrograms per litre (Lemly 2004). Other sub- lethal effects include teratogenesis at the embryo-larval stage. Above species-specific thresholds, acute toxicity resulting in mortality occurs in juvenile and adult fish (Lemly and Smith 1987).

In natural waters, selenium occurs in four oxidation states: selenides (HSe− and H2Se); selenite (SeO32-) and selenate (SeO42-). The selenides are either insoluble or quickly decompose to become insoluble elemental selenium (U.S. EPA 1979b,1980c). Selenite and selenate are soluble with selenite favoured at a pH range between 3.5 and 9.0 (US. EPA 1979b) and selenate favoured in alkaline conditions.

In an aquatic environment, the selenium cycling rate determines the occurrence and duration of toxic events (Lemly and Smith 1987). The cycle turns through immobilisation (removal and sequestration) of dissolved selenium in sediments and mobilisation (release and biological uptake) from sediments. Immobilisation occurs as dissolved selenium (selenate and selenite) undergoes chemical and microbial reduction followed by adsorption and settling with clay and organic particles and co-precipitation with iron (Lemly and Smith 1987). Mobilisation occurs through oxidisation and methylation of selenium by physical and biological processes and, most importantly, through direct uptake from sediments by plants, benthic invertebrates, and bottom-feeding fish and wildlife (Lemly and Smith 1987, Lemly 1999). In this way, inorganic forms of selenium are eventually converted into organic selenium and assimilated into protein (Morgan 2008). Organic selenium is much more toxic than inorganic selenium (Niimi and LaHam 1975, as cited in CCME 2007) and has a far greater bioaccumulation potential (Lemly 2004). While some is returned to the environment through methylation, excretion, and volatilisation (Mézes and Balogh 2009), it is through this process of direct uptake and dietary exposure that selenium can persist at toxic levels even when its concentration in water is low (Lemly and Smith 1987, as cited in Lemly 2004).

Selenium toxicity in aquatic environments depends on the presence of other metals and non-metals which exhibit joint action with selenium. Copper, germanium, antimony, and tungsten are antagonistic to the toxicity of selenium, whereas selenium is antagonistic to the toxicity of silver, cadmium, mercury, and thallium (BC MOE 2006a). Joint action with arsenic can result in an increase or a decrease of selenium toxicity (BC MOE 2006a) whereas the joint action with sulphate depends on the form of selenium present in the water (BC MOE 2006a). Adams (1976), working with the fathead minnow, found that the toxicity of selenium was directly related to water temperature. Lemly (1982), working with juvenile bluegill and largemouth bass, found that neither water temperature nor water hardness had any effect on the uptake of waterborne selenium.

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6.7.2.10.1.9.2 Water Quality Model Results Average selenium concentrations were predicted to be below the CCME (2007) and BC MOE 30-day average (2006b) guidelines (0.001 mg/L and 0.002 mg/L, respectively) for the protection of freshwater aquatic life during all phases of the Project. However, the predicted 95th percentile (0.0014 mg/L) and the maximum (0.0017 mg/L) values for selenium during operations and the maximum (0.0012 mg/L) values during post-closure were predicted to exceed the CCME (2007) guideline of 0.001 mg/L.

During operations, there is an increase in the predicted selenium concentrations in lower Lime Creek until Year 13. The selenium source during operations was predicted to come from the pit walls and waste rock run-off. After Year 13 and through the closure period, the predicted selenium concentrations in lower Lime Creek were predicted to dramatically decrease. This is because water from the TMF, waste rock facilities and from the pit would be captured and retained in the pit as it is filled. During post-closure, there was predicted to be an immediate increase in selenium concentrations in lower Lime Creek above the CCME guideline when the pit begins to over-flow. This would be followed by a steady decrease to a selenium concentration of approximately 0.0005 mg/L by Year 13 and extending for perpetuity post-closure as the pit water becomes more dilute.

6.7.2.10.1.9.3 Residual Effects Assessment Potential lethal or sub-lethal effects to Dolly Varden in Lime Creek may not necessarily occur due to the predicted exceedence of the federal CCME selenium guideline during operations and post-closure phases. This likelihood exists for a number of reasons including:

 Selenium concentrations were never predicted to exceed the BC 30-day average guideline concentration (0.002 mg/L) during any phase of the Project. BC Ministry of Environment has developed a higher selenium guideline concentration (0.002 mg/L) than the CCME (0.001 mg/L) while maintaining the same goal of providing protection to freshwater aquatic biota in BC. Similar to CCME guidelines, the BC MOE guideline was based on published literature and guidelines from other jurisdications. However, the BC MOE guideline was based on general conditions prevalent in British Columbia instead of conditions that prevail across Canada (as the CCME guideline was);  The CCME (1999) selenium guideline may be overly conservative for the protection of Dolly Varden and other aquatic biota in Lime Creek from lethal and sub-lethal effects of selenium. As stated by the CCME (2007), federal guidelines are developed “to protect all forms of aquatic life and all aspects of the aquatic life cycles, including the most sensitive life stage of the most sensitive species over the long term”. With this in mind, the CCME selenium guideline of 0.001 mg/L was adopted from the International Joint Commission (IJC) numerical selenium limit of 0.001 mg/L to protect freshwater aquatic life in the Great Lakes. The IJC’s selenium limit was based applying a 0.2 safety factor to the lowest waterborne selenium concentration (0.005 mg/L) found to cause food-web related acute lethality in

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predatory fish (e.g., lake trout, walleye) in field studies. However, Dolly Varden in lower Lime Creek are not piscivorous like lake trout or walleye in the Great Lakes and are therefore on a lower trophic level less susceptible to potential effects of selenium biomagnifications. The CCME selenium guideline is currently under- review;  The BC MOE 30-day average selenium guideline of 0.002 mg/L (which would not be exceeded at any time during the Project in lower Lime Creek) was based on selenium concentrations (0.005 mg/L) at which acute and chronic effects were noted to occur to the most sensitive fish species tested (i.e., redear sunfish (Lepomis microlophus), blue gill (Lepomis macrochirus), and largemouth bass (Micropus salmoides) (BC MOE 2001). However, these are all warm-water fish species none of which are present at Kitsault. Cold-water fish species such as rainbow trout, a fish species in the same subfamily (Salmoninae) as Dolly Varden, are much more tolerant of selenium than any of these other fish species. For example, BC MOE (2001) reported that effects to rainbow trout (Oncorhynchus mykiss) were not expected until approximately 1.1 mg/L of selenium. Similarly, Hodson et al., (1984)

found that the 96 hour LC50 selenium concentration for rainbow trout was 8 mg/L while Goettl et al. (1976) would no effect on acute mortality of rainbow trout at selenium concentrations of 0.06 mg/L and only subtle hematological responses in rainbow trout exposed to selenium concentrations of 0.028 mg/L over 44 weeks. These concentrations are a minimum of one order of magnitude and up to three orders of magnitude higher than either the BC MOE 30-day average guideline or the CCME guideline suggesting that both guidelines are over-protective for Dolly Varden;  Water quality modelling results are conservative in that they assume there is no complex interaction between selenium and any other abiotic factor (e.g., water hardness, temperature, concentrations of other antagonistic metals such as copper and antimony) that may reduce its toxicity to Dolly Varden in lower Lime Creek. Thus, it is likely that the potential toxicity of selenium in lower Lime Creek would be lower, not higher, during operations and post-closure at the water hardness, water temperatures, and concentrations of other metals predicted to occur in lower Lime Creek at all phases of the Project than would be predicted solely based on the federal guideline exceedances;  Fish in lotic (flowing water) environments, such as lower Lime Creek, have been shown to have a significantly higher tolerance than fish in lentic (still water) environments (Technical Appendix to the BC MOE Water Quality Guidelines for Selenium; BC MOE 2001); and  Selenium concentrations in reproductive tissues of fish (e.g., eggs) may be a more reliable indicator of potential selenium effects to fish than selenium concentrations in water. Chronic effects of selenium on fish are usually manifested at an early life stage, resulting in characteristic larval deformities. Reproductive toxicity studies in fish indicate that the threshold for early life-stage selenium toxicity ranges from below 10 mg/kg dry weight to greater than 30 mg/kg dry weight in eggs, with cold-water species being more tolerant than warm-water species (McDonald, et al. 2010). A

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general guideline for fish egg or ovary tissue of 20 mg/kg dry weight is being considered for broad application (DeForest, et al. 2011). However, Dolly Varden eggs have been shown to be significantly more tolerant of selenium exposure than any other cold-water fish species tested in the scientific literature; a 10% increase in

the frequency of Dolly Varden larval deformity (i.e. an EC10) was calculated to be 54 mg/kg dry weight (McDonald, et al. 2010).

Based on these lines of evidence, predicted selenium concentrations in lower Lime Creek are no expected to adversely affect Dolly Varden. However, the proponent acknowledges the uncertainty in the models used to predict selenium concentrations in lower Lime Creek and its potential toxicity to aquatic life at certain thresholds. As such, the proponent is committed to working with Environment Canada, the BC Ministry of Environment, and the Nisga’a Lisims Government to develop site-specific guidelines for selenium in Lime Creek and to meeting these guidelines throughout the life of the Project.

6.7.2.10.1.10 Zinc 6.7.2.10.1.10.1 Ecological Toxicity Profile Zinc is the most widely used essential trace metal in biology (Vallee and Falchuk 1993). Zinc is a component of the structure and function of a diverse array of enzymes and proteins, including those involved in DNA and RNA synthesis (CCREM 1987, Vallee and Falchuk 1993). At toxic levels of zinc, effects on fish are reported to include increased mucous secretion, anorexia, impaired reproduction, reduced growth, reduced brood size, and reduced size of young at birth (Gül et al. 2009).

The bioavailability (and therefore toxicity) of zinc is dependent on many physical and organic factors (Holcombe and Andrew 1978). Zinc occurs in both dissolved and suspended form in natural waters (Suter II and Tsao 1996). It typically occurs as simple hydrated ions, and in inorganic compounds, stable organic complexes, inorganic clays, and organic colloids (Suter and Tsao 1996). In general, the bioavailability of zinc decreases with increased concentration of organic and inorganic zinc complexes. Toxicity decreases with higher water hardness, higher alkalinity, and lower pH (Holcombe and Andrew 1978). Zinc toxicity is also affected by the presence of other metals, through both additive and synergistic effects (Brown and Dalton 1970; Marking 1977; Sprague 1964; Anderson and Weber 1976, as cited in CCREM 1987).

Sensitivity to zinc toxicity varies with species. Freshwater algae may be more sensitive to zinc than freshwater macrophytes and animals (Suter and Tsao 1996). Salmonids are less sensitive to zinc in harder water. In a study involving water hardness and rainbow trout (O. mykiss), Sinley and Goettl (1974) found that both acute and chronic toxicity decreases as water hardness increases, and that under chronic conditions, eggs may be more sensitive to zinc than adults. Sinley and Goettl (1974) also showed that acclimation was an important factor in chronic toxicity in rainbow trout.

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6.7.2.10.1.10.2 Water Quality Model Results The water quality model predicted that average annual and peak monthly zinc concentrations in lower Lime Creek would never exceed the BC MOE maximum guidance limits (0.033-0.062 mg/L based on hardness values that ranged from 56-128 mg/L as

CaCO3) (2006b) during any of the Project. However, there was predicted to be exceedances of the BC MOE (2006b) 30-day and CCREM (1987) guidelines during the construction, closure, and post-closure phases. No zinc guideline exceedances were predicted during the operations phase.

During the construction phase, the predicted zinc concentrations (0.003 mg/L to 0.021 mg/L) would exceed the BC MOE 30-day limit guideline (0.008 mg/L) based on hardness of

59 mg/L as CaCO3. The predicted average annual and peak monthly concentrations during closure (0.0054 mg/L to 0.0256 mg/L) and the first few of years of the post-closure phase were predicted to exceed the BC MOE 30-day limit guidelines (closure: 0.008 mg/L and post-closure: 0.019 mg/L post-closure, based on hardness values of 56 and 104 mg/L as

CaCO3, respectively).

6.7.2.10.1.10.3 Residual Effects Assessment The aquatic freshwater ambient Water Quality Guideline (WQG) for zinc established by the BC MOE (Nagpal) in 1997 is based on hardness-dependent equations. When hardness exceeds 90 mg/L as CaCO3:

Chronic Guideline (µg/L) = 7.5 +0.75 x (hardness-90) (Equation 1)

Acute Guideline (µg/L) = 33 + 0.75 x (hardness -90) (Equation 2)

When hardness is less than or equal to 90 mg/L as CaCO3, the guideline concentrations are fixed:

Chronic Guideline = 7.5 µg/L (Equation 3)

Acute Guideline = 33 µg/L (Equation 4)

The federal CCME (formerly CCREM) guideline for zinc has been tentatively set at a concentration of 30 µg/L, regardless of hardness, under the basis that “sufficient data are not available to show that chronic toxicity decreases as water hardness increases” (citing USEPA 1980 guidance). However, in 1987, USEPA revised their zinc chronic guidelines to include hardness as a dependent variable (USEPA 1987; 1996).

The BC MOE and the CCME zinc guidelines may be overly conservative and have a high degree of uncertainty. For example, the BC MOE guidelines assume a linear relationship between hardness and toxicity. However, more recent reviews by the USEPA indicate that the relationship is logarithmic/exponential. Also, both studies are now outdated and are based on different species. Lastly, one of the two studies used to derive the slope for the hardness-dependent equation did not actually measure hardness.

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Alternatively, the approach used by the USEPA to derive its Ambient Water Quality Criteria (AWQC) for zinc (CITE) were derived from acute toxicity values for 43 species and chronic toxicity values for 9 species (including trout, salmon, and benthic invertebrates). Overall, USEPA’s approach uses a more thorough and up-to-date data set and derives a logarithmic relationship between hardness based on a more rigorous statistical review of the data and derives the slope using a species sensitivity distribution approach. Based on USEPA’s approach, alternative zinc WQGs in lower Lime Creek would be:

Project Phase Construction Operations Closure Acute (mg/L) 0.124 0.287 0.114 Chronic (mg/L) 0.075 0.145 0.072

Similar to existing provincial and federal guidelines, these alternative WQGs are designed to protect a group of diverse genera from the harmful effects of zinc. No studies were located that assessed zinc toxicity specifically with respect to Dolly Varden (Salvelinus malma). However, toxicity studies in the scientific literature for rainbow trout (O. mykiss) which is in the same subfamily (Salmoninae) as Dolly Varden, were reviewed by USEPA and HydroQual.

These studies were used to develop and parameterise a biotic ligand model (BLM) for zinc in lower Lime Creek. Essentially, the BLM links bioavailable concentrations of zinc to toxicological effects, and accounts for the effects of several contributing factors including hardness, pH, temperature, and the concentration of other dissolved ions. The toxicity data compiled by USEPA and HydroQual (CITE) indicate that that under site-specific conditions in lower Lime Creek, acute and chronic effects to rainbow trout (assumed to be an appropriate surrogate species for Dolly Varden) were expected to occur at the following concentrations:

Project Phase Construction Operations Closure Acute (mg/L) 0.280 0.510 0.270 Chronic (mg/L) 0.130 0.180 0.130

The proposed site-specific acute and chronic WQGs determined from USEPA AWQC approach were less than lethal and sub-lethal effects concentrations for species in the subfamily Salmoninae used to develop the BLM model. The water quality model predicts that zinc concentrations in lower Lime Creek would all be below the site-specific WQGs for all project phases. Predicted concentrations of zinc in lower Lime Creek are therefore not expected to adversely affect populations of species in the Salmoninae sub-family, such as Dolly Varden.

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6.7.2.10.2 Change in Stream Flows in Lime Creek 6.7.2.10.2.1 Assessment Methods Potential effects of predicted monthly flow reductions in lower Lime Creek during the construction and operations of the Project were assessed by comparing predicted average water depths and water velocities in riffles and pool tail-outs during the critical Dolly Varden spawning (September and October) and egg incubation periods (November to March) to similar hydraulic parameters during baseline conditions and to the preferred and optimal ranges of water depths and water velocities for Dolly Varden spawning and egg incubation from the published literature. This assessment required the following steps:

 Collection of hydraulic habitat data (e.g., water depths, substrate types, water velocities) over a range of three different discharges at transects placed in riffles crests and in pool tail-outs in lower Lime Creek;  Development of hydraulic relationships between discharge and water depth and between discharge and water velocity in each of these two mesohabitat types using calibrated hydraulic models developed for each mesohabitat type from the collected transect data; and  Comparison of water depths and water velocities predicted to occur in each mesohabitat type at the monthly discharges predicted to occur from September and to March during each mine phase to the range of water depths and water velocities known to be suitable for Dolly Varden spawning and egg incubation.

Potential effects of predicted flow changes during the closure phase were not assessed because monthly flow reductions were predicted to be smaller than those predicted during the Construction phase (Stage 2 & 3) and the Operations (Year 155) phases. Potential effects of predicted flow changes during the post-closure phase were not assessed because flows were predicted to be higher or only marginally lower during these critical fall and winter months than during the other mine phases.

The spawning period was selected based on observations of spawning adult Dolly Varden in lower Lime Creek at the end of September in 2009 and the month when water temperatures fell below 6°C in Lime Creek in 2010, the water temperature threshold that initiates Dolly Varden spawning runs (McPhail 2007). The egg incubation period was selected based on the number of days to hatching calculated from the relationship between water temperature and days to hatching developed for bull trout by McPhail and Murray (1979). This relationship is described by the equation:

Ln (days to hatching)=5.086-0.131×average water temperature (°C)

5 Kitsault Pit filling scenario A: the scenario when the pit is only being filled by direct precipitation and discharge from the South Water Management Pond and the Low Grade Stockpile sediment control pond. Excess water from the TMF and run-off from the upper Patsy Creek watershed are discharged downstream to Lime Creek during this filling scenario.

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Based on this relationship and the average water temperature in Lime Creek from November to March (1.0°C), Dolly Varden eggs spawned in October would be expected to hatch in 141 days, or sometime in mid-March.

A total of 10 transects were established in reaches 3 and 4 of lower Lime Creek between the 8 meter high waterfalls and the first cascade impediment to fish passage downstream of the bridge crossing near the town of Kitsault in 2010 (Figure 6.7.2-19). Five transects were placed in riffle crests and five transects were placed in pool tail-outs. These two mesohabitat types were selected because they are the mesohabitats likely to be most sensitive to flow reductions in Lime Creek (compared to pools and runs) and are the mesohabitats most likely to be used by Dolly Varden for spawning (McPhail and Taylor 1995). Groundwater upwellings and downwellings (i.e., hyporheic flows) are important to Dolly Varden egg survival and incubation because they serve to keep eggs well oxygenated and free of silt and prevent eggs from being destroyed by keeping the interstitial spaces where the eggs (Griffin 1979; Alaska Department of Fish and Game 1985; McPhail 2007; Stewart et al., 2007). These types of upwellings are most commonly found in riffle crests and pool tail-outs in streams. In Lime Creek, these mesohabitats are also the two habitats that most commonly have gravel / cobble substrates, the preferred substrates for Dolly Varden spawning and redd construction.

Each transect was visited three times in 2010 during the open-water season: early June6 (June 6, 7, or 8th), July 28th, and August 30th. Discharges over these three periods ranged from 0.23 m3/sec on August 30th to 2.83 m3/sec on June 8 (Table 6.7.2-35). Discharges over this range correspond to approximately 8% to 95% of mean annual discharge in lower Lime Creek. This range exceeded the minimum range required for development of hydraulic relationships (5% to 40%) by the Lewis et al. (2004).

Table 6.7.2-35: Daily Discharges and Percent of Mean Annual Discharge in Lower Lime Creek During Data Collection Periods for Development of Hydraulic Relationships at Riffle Crests and Pool Tail-Outs, 2010

Measured Discharge 1 Season Date 3 % of MAD (m /sec) Spring June 6 1.66 56 June 7 2.13 71 June 8 2.83 95 Summer July 28 0.46 15 Late summer August 30 0.23 8 Note: 1 calculated assuming a mean annual discharge (2.99 m3/sec) based on 20 years of daily flows measured in lower Lime Creek at Water Survey of Canada stream gauge #08DB010

6 Three days were required to visit all 10 transects in June because channel and longitudinal profiles were surveyed during this initial visit in addition to the depth, width, and water velocity profiles. Stream discharge during these three days in June increased rapidly due to a large storm event.

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469500 470000 470500 Legend Access Road Contour (5 m) Stream Flow Direction Waterbody Hydrology Station ALICE WSC Station ARM Reach Break

6146000 6146000 Transect KITSAULT TOWNSITE

ALASKA KEY MAP 1 Alice Arm Road NORTHWEST TERRITORIES YUKON

Fort Nelson Juneau BRITISH COLUMBIA ALBERTA 08DB010 09 Fort St. John Stewart LCK-H2 Project Location 2 02 Edmonton Kitimat Prince George 6145500 10 3 01 6145500 08

Calgary

Kamloops Kelowna

03 Vancouver

Victoria UNITED STATES 04 06 L 05 IM Scale:1:6,000 UNITED STATES E C R E 0 50 100 200 300 E K Metres 07 Reference 1. Base Data Geobase 1:20,000 (TRIM) Land and Resource Data Warehouse 1:20,000 (TRIM) 2: Kitsault Mine General Layout Supplied by AMEC and Knight Piesold on March 2011

CLIENT: Avanti Kitsault Mine Ltd.

PROJECT:

6145000 6145000 Kitsault Mine Project

Study Transects Fall Lower Lime Creek

DATE: ANALYST: November 2011 MY 4 Figure JOB No: QA/QC: PDF FILE: VE51988 BH 10-50-110_limecreek_transect.pdf

GIS FILE: 10-50-115.mxd

PROJECTION: DATUM: 469500 470000 470500 UTM Zone 9 NAD83 Y:\GIS\Projects\VE\VE51988_Kitsault\Mapping\10_fisheries-aquatics\Baseline\10-50-110.mxd KITSAULT MINE PROJECT ENVIRONMENTAL ASSESSMENT FRESHWATER AQUATIC RESOURCES

Data collection methods at each transect were based on the BC Instream Flow Methodology described by Lewis et al. (2004). In brief, water depth, water velocity, substrate and cover were measured at a minimum of 20 verticals along at each transect within the wetted width of the creek during each visit. Water depths were measured with a meter stick while water velocities were measured with a calibrated Swoffer® Model 2100 digital flow meter. Wetted width was measured with a 50 metre fibreglass measuring tape. During the first visit to each transect in June, the cross-sectional profile of the riffle or pool tail-out was determined by surveying each transect, from top of bank to top of bank, with a surveyor’s rod and transit. All cross-sectional profiles were tied to benchmarks established at each transect (i.e., spikes hammered into tree roots on the stream bank). Additionally, all transects were tied together longitudinally by surveying the benchmarks and water levels from the upstream-most transect to the downstream-most transect during the first visit. This surveying was not repeated during subsequent visits on the assumption that the cross-sectional and longitudinal profiles would not change as water’s receded over the course of the summer. Appendix 6.7-D summarises the field data collected at each transect during each visit in 2010. Channel cross sections with superimposed water levels during each visit are shown in Appendix 6.7-D.

All measured depths, water velocities, wetted perimeters and cross-sectional profile data collected from each transect were imported into the Flowmaster® computer program. This program was used to simulate hydraulic parameters (e.g., wetted perimeter, water depth, water velocity) for different stream discharges at each transect. Discharges predicted by Flowmaster® were compared to measured discharges at each transect and the stream roughness coefficient (i.e., Manning’s n) was adjusted as necessary to calibrate the model at each cross-section. Details for the Flowmaster® hydraulic modeling are provided in Appendix 6.7-F.

All simulated hydraulic data generated by the calibrated Flowmaster® models for each riffle crest transect and for the pool tail-out transects were then pooled to develop separate hydraulic-habitat relationships between discharge and water depth and water velocity for both mesohabitat types. Water depths and water velocities predicted from these relationships using the predicted September and October discharges during the construction, operatons, and closure phases of the Project were then compared to the upper and lower bounds of the preferred water depths and water velocities for Dolly Varden spawning and egg incubation. Similar comparisons were made for baseline September and October discharges to determine the relative suitability of riffle crests and pool tail-outs under pre-mine conditions.

Upper and lower bounds were based on the project-specific habitat suitability index (HSI) model developed for Dolly Varden (Appendix 6.7-G). This HSI model was developed from a detailed literature review of life history and habitat use requirements of Dolly Varden. Due to the relative paucity of hydraulic habitat information specific to Dolly Varden spawning / egg incubation, juvenile rearing, adult foraging, and overwintering life stages, the HSI was augmented with data from studies on bull trout (Salvelinus confluentus) and Arctic charr (Salvelinus arcticus), two species with similar habitat requirements as Dolly Varden. For the

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KITSAULT MINE PROJECT ENVIRONMENTAL ASSESSMENT FRESHWATER AQUATIC RESOURCES purposes of this analysis, upper and lower bounds of the preferred water depths and water velocities for Dolly Varden spawning and egg incubation were assumed to be 5 to 40 cm and 0.1 to 1.0 m/sec, respectively. Upper and lower bounds of the optimal water depths and water velocities for Dolly Varden spawning and egg incubation were assumed to be tighter: 5 to 30 cm and 0.1 to 0.6 m/sec, respectively.

6.7.2.10.2.2 Assessment Results Hydraulic relationships between discharge and average water depth and water velocity at riffle crests and in pool tail-out mesohabitats in lower Lime Creek are presented in Figures 6.7.2-20 and 6.7.2-21. These two graphs show that, on average, pool tail-outs were shallower and had higher water velocities than riffles in lower Lime Creek. This was due to the much lower roughness of the channel substrates typically found in pool tail-outs compared to riffle crests. Pool tail-outs were comprised largely of smooth cobble and gravel substrates that typically extended <5 cm above the bottom of the channel. In contrast, riffle crests typically had angular cobbles and boulders that typically extended >15 cm above the bottom of the channel. These larger substrates served to increase channel roughness and decrease water velocities and increase water depths compared to pool tail-outs.

1.4

1.2

1

(m)

0.8 Depth

0.6 Water

0.4

0.2

0 012345

Discharge (m3/s)

Average Modeled Pool Tail‐Out Pool Tail‐Out Field Data Pool Tail‐Out Modeled Data Set Average Modeled Riffle Riffle Field Data Riffle Modeled Data Set Optimal Depth ‐ Upper Limit Optimal Depth ‐ Lower Limit Preferred depth ‐Upper Limit

Figure 6.7.2-20 Hydraulic Relationship Between Discharge and Average Water Depth at Riffle Crests and Pool Tail-Outs in Lower Lime Creek

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1.6

1.4

1.2

1 (m/s)

0.8 Velocity

0.6 Water

0.4

0.2

0 012345

Discharge (m3/s)

Average Modeled Pool Tail‐Out Pool Tail‐Out Field Data Pool Tail‐Out Modeled Data Set Average Modeled Riffle Riffle Field Data Riffle Modeled Data Set Optimal Velocity ‐Upper Limit Optimal Velocity ‐Lower Limit Preferred Velocity ‐ Upper Limit

Figure 6.7.2-21 Hydraulic Relationship Between Discharge and Average Water Velocity at Riffle Crests and Pool Tail-Outs in Lower Lime Creek

Table 6.7.2-36 shows the predicted average water depth and average water velocity at pool tail-outs and riffle crests during the Dolly Varden spawning period (September and October) during pre-mine, Construction (Stage 2 & 3), and Operations (Year 15) phases of the Project. These water depths and water velocities were calculated from the discharges predicted from the calibrated Watershed Model (Knight Piésold 2011, Appendix 6.5-C) and the corresponding hydraulic relationships in Figures 6.7.2-20 and 6.7.2-21. Table 6.7.2-37 shows similar predictions during the egg incubation period. For example, with a predicted discharge of 1.81 m3/sec during an average September run-off return period, average water depth and average water velocity in pool tail-outs were predicted to be 0.55 m and 0.73 m/sec, respectively, during the construction phase (Stage 2 & 3) from these relationships.

6.7.2.10.2.2.1 Dolly Varden Spawning Average water depths in pool tail-outs and riffle crests were predicted to remain above the upper limit of the preferred depth range (0.40 m) for Dolly Varden spawning during both the construction and operations phases (Table 6.7.2-36). This is similar to water depths that normally occur in both mesohabitats under pre-mine conditions. Average water depths in pool tail-outs and riffle crests during pre-mine conditions range from 0.52 to 0.65 m and from 0.56 to 0.73 m, respectively. During construction and operations, average water depths in pool tail-outs and riffle crests were predicted to range from 0.43 to 0.61 m and from 0.50 to 0.69 m, respectively. Therefore, despite up to a 29% reduction in discharge, average water

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KITSAULT MINE PROJECT ENVIRONMENTAL ASSESSMENT FRESHWATER AQUATIC RESOURCES depths at pool tail-outs and riffle crests in lower Lime Creek during September and October were predicted to decrease by only 6 to 15% and 5 to 14%, respectively, over the range of average and low flow (i.e., 10th and 25th percentile return period flows) conditions assessed. These reductions in water depth are insufficient to reduce the suitability of pool tail-outs and riffle crests for Dolly Varden spawning.

Predicted flow reductions in lower Lime Creek during the construction and operations phases were predicted to reduce average water velocities in pool tail-outs between 6% and 8% and in riffle crests between 5% and 7% compared to pre-mine conditions at average flows. These reductions increased to between 9% and 12% during 10th percentile flows. Average water velocities in pool tail-outs and riffle crests during average to low flow, pre- mine conditions range from 0.66 to 0.83 m/sec and from 0.49 to 0.59 m/sec, respectively. During construction and operations, average water velocities in pool tail-outs and riffle crests were predicted to range from 0.60 to 0.76 m/sec and from 0.43 to 0.56 m/sec, respectively, at these same average and low flow conditions. As a result, the flow reductions were predicted to decrease average water velocities in pool tail-outs and riffle crests from being consistently within the preferred water velocity range for Dolly Varden spawning to being consistently within the optimal water velocity range for Dolly Varden spawning.

The above analysis indicates that, based on the habitat suitability criteria gathered from the published literature, the predicted reductions in water depth and water velocity in pool tail- outs and riffle crests in lower Lime Creek would not be sufficient to decrease the suitability of these mesohabitat types for Dolly Varden spawning. Dolly Varden would continue to be able to use these habitats for spawning during construction and operation of the Project with no likely reduction in spawning success from pre-mine, baseline conditions.

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Table 6.7.2-36: Comparison of Predicted Water Depths and Water Ve

Lime Creek During the Dolly Varden Spawning Period (SeptemberPool and Tail-Outs October) Under Average and Riffle Low Crests Flow Conditions During Pre-Mine, Construction (Stage 2 & Predicted Average Project Averge Averge Average Water Month Flow Condition Discharge Water Phase 3 Water Depth Water Depth Velocity (m /sec) Velocity (m) (m) (m/sec) (m/sec) Pre-mine September Mean monthly discharge 2.17 locities at 0.60 Pool Tail-outs 0.78and Riffle Crest0.68 Mesohabitats in0.56 Lo 10th percentile monthly discharge 1.26 0.49 0.66 0.56 0.49 25th percentile monthly discharge 1.53 3), and 0.52Operations (Year0.69 15) Phases of0.59 the Project 0.51 October Mean monthly discharge 2.74 0.65 0.83 0.73 0.59 10th percentile monthly discharge 1.45 0.52 0.69 0.59 0.51 25th percentile monthly discharge 1.86 0.57 0.74 0.65 0.54 Construction September Mean monthly discharge 1.81 0.55 0.73 0.63 0.53 (Stage 2 & 3) 10th percentile monthly discharge 0.94 0.44 0.60 0.50 0.44wer 25th percentile monthly discharge 1.33 0.49 0.66 0.56 0.49 October Mean monthly discharge 2.26 0.61 0.78 0.69 0.56 10th percentile monthly discharge 1.15 0.48 0.63 0.53 0.47 25th percentile monthly discharge 1.40 0.50 0.67 0.57 0.50 Operations September Mean monthly discharge 1.83 0.55 0.73 0.63 0.53 a (Year 15) 10th percentile monthly discharge 0.94 0.43 0.60 0.50 0.43 25th percentile monthly discharge 1.33 0.49 0.66 0.56 0.49 October Mean monthly discharge 2.17 0.59 0.76 0.67 0.55 10th percentile monthly discharge 1.03 0.44 0.61 0.51 0.45 25th percentile monthly discharge 1.40 0.50 0.67 0.57 0.50 Note: a Kitsault Pit filling Scenario A XXXXX within the preferred depth range (0.05 to 0.40 m) for Dolly Varden spawning; XXXXX within the optimal depth range (0.05 to 0.30 m) for Dolly Varden spawning; XXXXX within the preferred water velocity range (0.1 to 1.0 m/sec) for Dolly Varden spawning; XXXXX within the optimal water velocity range (0.1 to 0.6 m/sec) for Dolly Varden spawning.

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6.7.2.10.2.2.2 Dolly Varden Egg Incubation Average pre-mine water depths in pool tail-outs and riffle crests are typically within the preferred (0.05 to 0.40 m) or optimal (0.05 to 0.30 m) depth range for Dolly Varden egg incubation in most winter months during average and low flow conditions (Table 6.7.2-37). Only during average November and March flows do water depths in these mesohabitats exceed the preferred egg incubation depth range upper limit. Similarly, average, pre-mine water velocities in pool tail-outs and riffle crests are typically within the optimal range for Dolly Varden egg incubation in most winter months during average and low flow conditions. Only during average November flow conditions (or greater) do water velocities exceed the optimal egg incubation water velocity range upper limit, and only in pool tail-outs (Table 6.7.2-37). However, water velocities in pool tail-outs are still within the preferred range for Dolly Varden egg incubation in this month.

Predicted flow reductions during the construction and operations phases of the Project were predicted to reduce average water depths in pool tail-outs and riffle crests only between 3% and 8% during the winter egg incubation period during average return period flows. These reductions in water depth would increase only to between 8% and 15% during 10th percentile flows. As a result, predicted flow reductions in lower Lime Creek during the construction and operations phases would not decrease water depths in pool tail-outs and riffle crests sufficiently to reduce the suitability of these mesohabitats for Dolly Varden egg incubation during the winter. In fact, based on the habitat suitability criteria (Appendix 6.7-G), the predicted reductions in water depth in these two mesohabitats would increase the frequency of winter months during which water depths would fall within the optimal depth range for Dolly Varden egg incubation compared to pre-mine, baseline conditions. This was most evident during the later winter months of January, February, and March in both mesohabitat types.

Similar to water depths, predicted flow reductions during the construction and operations phases of the Project would not reduce water velocities in pool tail-outs and riffle crests sufficiently low to reduce the suitability of these mesohabitats for Dolly Varden egg incubation during the winter. Predicted flow reductions during construction and operations were predicted to reduce average water velocities in pool tail-outs by only 2% to 7% and in riffle crests by only 3% to 9% under average run-off flows. These reductions were predicted to increase to between 5% and 12% in pool tail-outs and between 6% and 13% in riffle crests during 10th percentile run-off flows. During average and 10% percentile monthly run- off conditions, water velocities in pool tail-outs fall would remain within the optimal water velocity range for Dolly Varden egg incubation in all months with the exception of November when water velocities during average monthly run-off would remain above the optimal water velocity range but within the preferred water velocitiy range (Table 6.7.2-37). Average water velocities in riffle crests would continue to remain within the optimal range for Dolly Varden egg incubation during all winter months at both average and 10% percentile flows.

The above analysis indicates that, based on the habitat suitability criteria gathered from the published literature, the predicted reductions in water depth and water velocity in pool tail- outs and riffle crests in lower Lime Creek would not be sufficient to decrease the suitability

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KITSAULT MINE PROJECT ENVIRONMENTAL ASSESSMENT FRESHWATER AQUATIC RESOURCES of these mesohabitat types for Dolly Varden egg incubation. Dolly Varden egg laid in these mesohabitats during construction and operations of the Project are, therefore, predicted to have the same likelihood of survival to hatching as eggs laid at pre-mine flows.

This assessment, coupled with the prediction that the suitability of Dolly Varden spawning habitat in lower Lime Creek would also not be negatively affected by flow reductions during construction and operations, indicates that the residual effect of flow reductions on Dolly Varden spawning success, egg survival, and annual recruitment would be not significant (Table 6.7.2.6.7.2-40).

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Table 6.7.2-37: Comparison of Predicted Water Depths and Water Ve

Lime Creek During the Dolly Varden Egg Incubation Period (NovemberPool Tail-Outs to March) Under Average and Riffle Low Crests Flow Conditions During Pre-Mine, Construction (Stage 2 & Predicted Average Project Averge Averge Average Water Month Flow Condition Discharge Water Phase 3 Water Depth Water Depth Velocity (m /sec) Velocity (m) (m) (m/sec) (m/sec) Pre-mine November Mean monthly discharge 1.11 locities at 0.46 Pool Tail-Outs0.62 and Riffle Crest0.51 Mesohabitats in0.47 Lo 10th percentile monthly discharge 0.51 0.35 0.49 0.41 0.36 December Mean monthly discharge 0.49 3), and0.34 Operations (Year0.48 15) Phases of0.39 the Project 0.36 10th percentile monthly discharge 0.36 0.31 0.44 0.36 0.33 January Mean monthly discharge 0.36 0.31 0.44 0.36 0.33 10th percentile monthly discharge 0.30 0.29 0.42 0.35 0.32 February Mean monthly discharge 0.40 0.32 0.46 0.38 0.35 10th percentile monthly discharge 0.24 0.26 0.40 0.31 0.31wer March Mean monthly discharge 0.74 0.40 0.54 0.46 0.41 10th percentile monthly discharge 0.23 0.25 0.40 0.30 0.30 Construction November Mean monthly discharge 1.01 0.44 0.61 0.51 0.45 (Stage 2 & 3) 10th percentile monthly discharge 0.34 0.30 0.43 0.35 0.33 December Mean monthly discharge 0.50 0.35 0.49 0.41 0.37 10th percentile monthly discharge 0.26 0.27 0.41 0.32 0.31 Ja nuary Mean monthly discharge 0.39 0.32 0.46 0.37 0.34 10th percentile monthly discharge 0.22 0.25 0.40 0.30 0.30 February Mean monthly discharge 0.32 0.30 0.43 0.35 0.32 10th percentile monthly discharge 0.18 0.24 0.37 0.28 0.27 March Mean monthly discharge 0.62 0.37 0.52 0.44 0.39 10th percentile monthly discharge 0.17 0.23 0.36 0.27 0.26 Operations November Mean monthly discharge 0.97 0.44 0.60 0.51 0.44 a (Year 15) 10th percentile monthly discharge 0.34 0.30 0.43 0.35 0.33

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Pool Tail-Outs Riffle Crests Predicted Average Project Averge Averge Average Water Month Flow Condition Discharge Water Phase 3 Water Depth Water Depth Velocity (m /sec) Velocity (m) (m) (m/sec) (m/sec) December Mean monthly discharge 0.41 0.32 0.46 0.39 0.35 10th percentile monthly discharge 0.26 0.27 0.41 0.32 0.31 January Mean monthly discharge 0.30 0.29 0.42 0.35 0.32 10th percentile monthly discharge 0.22 0.25 0.40 0.30 0.30 February Mean monthly discharge 0.33 0.30 0.43 0.36 0.33 10th percentile monthly discharge 0.18 0.24 0.38 0.28 0.27 March Mean monthly discharge 0.61 0.37 0.51 0.43 0.39 10th percentile monthly discharge 0.17 0.23 0.37 0.27 0.26 Note: a Kitsault Pit filling Scenario A XXXXX within the preferred depth range (0.05 to 0.40 m) for Dolly Varden egg incubation; XXXXX within the optimal depth range (0.05 to 0.30 m) for Dolly Varden egg incubation; XXXXX within the preferred water velocity range (0.1 to 1.0 m/sec) for Dolly Varden egg incubation; XXXXX within the optimal water velocity range (0.1 to 0.6 m/sec) for Dolly Varden egg incubation.

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6.7.2.10.3 Change in Water Temperatures in Lime Creek 6.7.2.10.3.1 Assessment Methods Potential changes in water temperature in lower Lime Creek were not quantitatively modelled. This could have been done with either a conservative mass-balance model similar to that used to model surface water quality or with physical process models (e.g., SNTEMP, CE-THERM-R1) which models water temperatures based on the physical process that influence stream temperatures (e.g., evaporation, solar radiation, shade from riparian vegetation, conductance with stream substrates, etc). However, neither of these models were constructed because of the uncertainty about:

 How much thermal loading would occur in the TMF due to recycling of process water between the TMF and the mill during operations;  Whether the TMF would thermally stratify during summer and or freeze during winter and from what depth surplus water in the TMF would be discharged to the Water Box during operations;  The volume of water that would need to be discharged from the TMF during operations in any given month or year; and  The temperature and volume of non-contact water diverted around the TMF, East WRMF and Kitsault Pit during operations and closure phases.

Instead, potential changes in water temperatures in lower Lime Creek were qualitatively assessed based on the likely differences in thermal contributions to Lime Creek resulting from water being discharged from the TMF during construction, operations, and closure phases and from the Kitsault Pit during the post-closure phase compared to thermal contributions to Lime Creek from Patsy Creek under current pre-mine conditions. This was done by:

 Comparing the likely differences in thermal inertia and mass between Patsy Lake, the current source of most water and heat in Patsy Creek, and the deeper and larger TMF and Kitsault Pit, the two principle sources of water and heat to Patsy Creek during the construction, operations, and closure phases and the post-closure phase, respectively;  Considering the attenuating effect of discharge volumes and thermal loads provided by run-off from the unaffected Lime Creek upstream of the Patsy Creek confluence;  Considering the attenuating effect of discharge volumes and thermal loads provided by unaffected Patsy Creek tributaries downstream of Patsy Lake;  Considering the attenuating effect of discharge volumes and thermal loads provided by unaffected Lime Creek tributaries downstream of the Patsy Creek confluence; and  Considering the local climate and its potential to increase or decrease water temperatures in the TMF and Kitsault Pit compared to Patsy Lake.

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6.7.2.10.3.2 Assessment Results Patsy Lake is the main source of water and heat for Patsy Creek under current conditions. The outlet of Patsy Lake conveys surface water from the top of Patsy Lake downstream to Patsy Creek and the temperature of this water depends on the time of year. In early spring and late fall, water temperatures in the Patsy Lake outlet approach 4°C when Patsy Lake becomes thermally mixed during the spring and fall turn-over periods. Water temperatures gradually increase over the spring and summer as the lake begins to thermally stratify. In winter, the surface of the lake freezes and what little outflow from the lake remains is at or near 0°C.

Differences in water temperatures between Patsy Creek downstream of the existing Kitsault Pit and the epilimnion of Patsy Lake in late August indicates that Patsy Creek receives significant inflow from tributaries downstream of Patsy Lake. Water temperatures in the epiliminion of Patsy Lake were approximately15°C in late July, 2010 (Section 1.4.1.2 in Appendix 6.7-A, Freshwater Aquatic Resources Baseline). However, average daily water temperatures in Patsy Creek downstream of the Kitsault Pit ranged between 8°C and 10°C over this same period and never exceeded 11°C during the summer (Section 1.3.2.2.2; in Appendix 6.7-A, Freshwater Aquatics Resources Baseline). This cooling effect could occur due to the shade provided by the trees that surround the creek or, more likely, from the influence of tributaries entering Patsy Creek downstream of Patsy Lake. There are at least four first order, one second order, and one 4th order tributaries entering Patsy Creek below Patsy Lake with most of these tributaries entering Patsy Creek from the southern part of the watershed. In order to cool outflows from Patsy Lake by the nearly 5°C observed during the summer of 2010, the accumulated discharge from these tributaries must provide either: 1) a relatively large proportion of the total Patsy Creek discharge at the confluence with Lime Creek, especially if water temperatures in these tributaries are only slightly lower than Patsy Lake outflow water temperatures; or 2) much colder water than the Patsy Lake outflow if the accumulated volume from these tributaries is relatively small in comparison to the Patsy Lake outflow volume.

On an annual basis, the upper Lime Creek watershed (i.e., upstream of the Patsy Creek confluence) contributes approximately 55% of the total run-off volume of Lime Creek immediately downstream of the Patsy Creek confluence; the Patsy Creek watershed provides the remaining 44%. This part of the watershed would not be affected by the mine and would, therefore, continue to contribute to the discharge and thermal load of Lime Creek during all phases of the Project.

The influence of run-off from the upper Lime Creek watershed on water temperatures in Lime Creek immediately below the Patsy Creek confluence is evident from the differences in water temperature between Patsy Creek and Lime Creek immediately downstream of the Patsy Creek confluence. Temperatures in Lime Creek downstream of the Patsy Creek confluence were slightly warmer (between 0.5°C and 1.3°C warmer) in Lime Creek in July and August 2010 compared to Patsy Creek but cooler (at least 2°C cooler) in spring and fall. This suggests that the influence of water in the upper Lime Creek watershed on water temperatures in Lime Creek varies depending on monthly discharge. Unlike Patsy Creek,

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KITSAULT MINE PROJECT ENVIRONMENTAL ASSESSMENT FRESHWATER AQUATIC RESOURCES upper Lime Creek does not have a lake to regulate water temperatures and flows. Instead, the upper Lime Creek watershed drains steep, mountainous terrain with little potential for storage. Therefore, run-off and water temperatures in upper Lime Creek during spring are driven by precipitation and snow-melt and during fall by large storm events. In summer, lower flows and warmer water temperatures from upper Lime Creek have less influence on water temperatures in Lime Creek downstream of the Patsy Creek confluence but are still sufficient to attenuate cooler water from Patsy Creek.

During construction and operations, potential increases in summer and winter water temperatures in Patsy Creek due to discharges from the TMF are unlikely to have a significant effect on water temperatures in lower Lime Creek. This is because:

 The relative proportion of monthly discharge from the TMF compared to discharge from upper Lime Creek and, more importantly, to discharge in lower Lime Creek where Dolly Varden reside, would be smaller during the construction and operations phases (due to predicted flow reductions) than during pre-mine conditions. Thus, any increase in water temperatures released to Patsy Creek from the TMF would be more attenuated by the increasing proportion of the unaffected discharge from the upper Lime Creek watershed and from the unaffected Lime Creek tributaries downstream of the Patsy Creek confluence. Under current conditions, Patsy Creek provides approximately 30% of the total average annual run-off to Lower Lime Creek (@LCK-H2). With smaller discharges predicted during construction and operations, the average annual contribution of flows from the TMF to lower Lime Creek are expected to decrase between 24% and 26% during construction, operations, and closure phases;  Cooler water from the Patsy Creek tributaries downstream of Patsy Lake would be diverted around the TMF, the East WRMF, and the Kitsault Pit and would serve to moderate any increase in water temperatures discharged to Patsy Creek from the TMF;  Discharge and thermal loadings from Lime Creek tributaries downstream of the Patsy Creek confluence would continue to attenuate water temperatures in lower Lime Creek. These tributaries contribute approximately 31% of the total annual run- off of lower Lime Creek. This tributaries would be unaffected by the Project; and  Climatic conditions along the north coast of British Columbia are cool and wet with a relatively short summer (July and August). Maximum mean monthly ambient air temperatures in July are approximately 12°C (Knight Piésold 2011, Appendix 6.4-A). Mid-summer air temperatures can exceed 20°C but the number days when air temperatures exceed 15°C is low. The number of days without cloud (i.e., when solar radiation inputs are maximum) is lower. As a result, even with the larger surface area of the TMF compared to Patsy Lake, it is unlikely that water temperatures discharged from the TMF to Patsy Creek would be more than 1°C or 2°C warmer than those discharged from Patsy Lake.

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During post-closure, potential increases in summer and winter water temperatures in Patsy Creek due to over-flow from the Kitsault Pit are unlikely to have a significant effect on water temperatures in lower Lime Creek. This is because:

 The proportional increase in run-off volume provided by the end-pit lake to lower Lime Creek at post-closure is small (<1% increase on an annual basis);  Run-off from upper Lime Creek run-off and Lime Creek tributaries downstream of the Patsy Creek confluence would continue to attenuate any increases in summer temperatures entering Lime Creek from the end-pit lake over-flow; and  Climatic conditions in the Kitsault area are insufficiently warm, dry, or cloudless to cause water temperatures in the end-pit lake to increase much higher than those normally discharged from Patsy Lake under pre-mine conditions.

For the reasons stated above, it is unlikely that water temperatures in lower Lime Creek would increase outside the range of natural variability during any phase of the Project. As a result, no significant residual effect on juvenile Dolly Varden rearing in lower Lime Creek in summer or to Dolly Varden egg’s incubating in lower Lime Creek in winter is expected to occur.

6.7.2.10.4 Change in Benthic Macro-Invertebrate Community in Lime Creek Juvenile Dolly Varden fed primarily on benthic invertebrate drift. Young-of-the-year feed primarily on smaller instar stages while larger 1+ and 2+ fish feed on larger mayflies, caddiesflies, stoneflies, and chironomid larvae and nymphs (McPhail 2007). Dolly Varden also eat any terrestrial invertebrates falling on to the water surface from overhanging vegetation.

Potential changes in benthic invertebrates drift in lower Lime Creek due to the potential combined, indirect effects of changes in water quality, changes in stream flow, and changes in water temperatures are difficult to predict with any certainty. However, it is predicted that no significant adverse effect to Dolly Varden would occur during any phase of the Project due the indirect effect of changes to benthic invertebrate drift because:

 If it is assumed that benthic invertebrate production across the wetted perimeter of Lime Creek is homogenous, the small change in wetted width predicted to occur due flow reductions caused by the Project is unlikely to have a large effect on the number of benthic invertebrates available to drift downstream to Dolly Varden in lower Lime Creek;

 The flow reductions predicted to occur in Lime Creek are unlikely to be large enough to reduce the water velocities or depths preferred by the mayflies, stoneflies, and caddisflies that currently dominate the benthic macro-invertebrate community of Lime Creek;

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 The flow reductions predicted to occur in Lime Creek are unlikely to be large enough to reduce the delivery of benthic invertebrate drift to Dolly Varden in lower Lime Creek;

 The small changes in water temperatures predicted to occur are unlikely alter the benthic invertebrate community of Lime Creek in favour of prey items not preferred by Dolly Varden; and

 Water quality of the discharge effluent from the Project would be monitored such that no water would be released downstream that didn’t meet site-specific water quality objectives designed to ensure the protection of freshwater aquatic biota in Lime Creek, including the benthic macro-invertebrate community.

This potential indirect residual effect is rated as not significant (minor). However, the level of confidence is low because of the uncertainty regarding the potential combined effects of changes in water quality, stream flows, and water temperatures due to the Project on the benthic macro-invertebrate community in Lime Creek.

6.7.2.10.5 Summary of Potential Residual Effects after Mitigation A summary of the potential residual effects of the Project on Dolly Varden in lower Lime Creek is provided in Table 6.7.2-38. All of these potential effects are indirect effects on Dolly Varden through potential direct changes to water quality, stream flows, water temperatures, and benthic macro-invertebrate prey in the Lime Creek watershed.

Table 6.7.2-38: Summary of Residual Effects for Dolly Varden

Project Phase Residual Effect Direction C,O,D/C, PC Change in surface water quality in lower Lime Creek Negative C,O, D/C Change in hydrology in lower Lime Creek Negative C, O, D/C, PC Change in water temperature in lower Lime Creek Negative C, O, D/C Change in benthic macro-invertebrates in Lime Creek Negative Note: C - construction; O - operations; D/C - decommissioning and closure; PC - post-closure

6.7.2.10.6 Significance of Potential Residual Effects Assessments of the potential residual effects of changes in surface water quality, stream flows, water temperatures, and benthic macro-invertebrates in Lime Creek on Dolly Varden during each phase of the Project is provided in Table 6.7.2-39. Each identified residual effect was subjected to rating criteria to determine significance; these criteria are described in Section 5.0, Assessment Methodology. Rationales for the various significance ratings criteria applied to each potential residual effect are provided where needed to explain the overall significance rating not already explained in the residual effect assessments above.

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Table 6.7.2-39: Residual Effects Assessment by Project Development Phase for Dolly Varden

Stage of development/rating Parameter Decommissioning Construction Operations Post-closure and closure Residual Effect Change in surface water quality in lower Lime Creek Effect Attribute Direction Negative negative negative negative Magnitude Low Low Low Low Geographic extent Local Local Local Local Duration Medium-term Long-term Long-term Chronic Frequency Continuous Continuous Continuous Continuous Reversibility No No No No Ecological Context High High High High Probability of occurrence High High High High Certainty Medium Medium Medium Medium Residual Effect Significance Not significance Not significant Not significant Not significant (minor) (minor) (minor) (minor) Level of Confidence Medium Medium Medium Medium Change in hydrology in lower Lime Creek Effect Attribute Direction Negative Negative Negative Negative Magnitude low low low Low Geographic extent local local local Local Duration Medium-term Long-term Long-term Chronic Frequency continuous continuous continuous continuous Reversibility no no no Yes Ecological context Medium Medium Medium Medium Probability of occurrence high high high High Certainty medium medium medium Medium Residual Effect Significance Not significant Not significant Not significant Not significant (minor) (minor) (minor) (minor) Level of Confidence High High High High Change in water temperature in lower Lime Creek Effect attribute Direction Negative negative negative Negative Magnitude low low low Low Geographic extent local Local local Local Duration short-term Long-term Long-term Chronic Frequency continuous continuous continuous Continuous Reversibility no no no No Ecological context low low low Low Probability of occurrence unknown unknown unknown low

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Stage of development/rating Parameter Decommissioning Construction Operations Post-closure and closure Residual Effect Change in surface water quality in lower Lime Creek Effect Attribute Certainty low low low high Residual Effect Significance Not significant Not significant Not significant Not significant (negligible) (negligible) (negligible) (negligible) Level of confidence Medium Low Low High Change in benthic macro-invertebrates in lower Lime Creek Effect attribute Direction Negative Negative Negative Negative Magnitude Low Low Low Low Geographic extent Local Local Local Local Duration Medium-term Long-term Long-term Chronic Frequency Continuous Continuous Continuous Continuous Reversibility No No No No Ecological context Low Low Low Low Probability of occurrence Low Medium Medium Low Certainty Medium Medium Medium Low Residual Effect Significance Not significant Not significant Not significant Not significant (minor) (minor) (minor) (minor) Level of confidence Low Low Low Low

The potential residual effect of changes in surface water quality in lower Lime Creek was assessed to have a not significant (minor) effect on Dolly Varden. This assessment was based on the assumption that alternative site-specific water quality objectives may need to be developed (in consultation with Environment Canada, the BC Ministry of Environment, and the Nisga’a Lisims Government) for the protection of freshwater aquatic biota in Lime Creek and that the proponent would commit to meeting these water quality objectives during all phases of the Project. These WQOs would be met either through adaptive water management and / or treatment of mine effluent prior to release to Lime Creek, if warranted. As a result, the potential residual effect to Dolly Varden in lower Lime Creek was predicted not to have an effect that would be distinguishable at the population level for Dolly Varden. The magnitude of this potential residual effect was predicted to be low (for the reasons above). The ecological context of this potential residual effect was predicted to be high only because of the potential consequences to the Lime Creek Dolly Varden population if WQOs could not be met. The level of confidence in this assessment was medium because the SSWQOs proposed in the assessment are likely to provide protection from the lethal and sub-lethal effects of the chemicals of concern for which guideline exceedences are predicted.

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The potential residual effect of changes in stream flows in lower Lime Creek was assessed to have a not significant (minor) effect on Dolly Varden. This was because the magnitude of the potential flow reductions in lower Lime Creek were expected to have a relatively small effect on the availability and suitability of Dolly Varden spawning habitat during fall and on Dolly Varden egg incubation during winter. The level of confidence in this assessment is high because it was based on detailed hydraulic modeling of the spawning and egg incubation habitat likely used by Dolly Varden in lower Lime Creek.

The potential residual effect of changes in water temperature in lower Lime Creek was assessed to have a not significant (negligible) effect on Dolly Varden. This was because the potential for water temperature changes in lower Lime Creek created by release of water from the TMF and from overflow out of the Kitsault Pit at post-closure would likely be attenuated by run-off from unaffected portions of the Lime Creek watershed and because the potential for temperature extremes during critical periods for Dolly Varden is moderated by the cool, wet climate at Kitsault.

The potential residual effect of change in benthic macro-invertebrates in Lime Creek was assessed to have a not significant (minor) effect on Dolly Varden. This was because the likely combined effect of potential changes in water quality, stream flows, and water temperature on benthic macro-invertebrate drift was considered to be low as a result of either mitigation measures proposed (e.g., SSWQOs and / or water treatment) or because of small predicted changes in habitat availability and suitability. As a result, the magnitude of predicted change in abundance and composition of benthic macro-invertebrate drift available as prey for Dolly Varden in lower Lime Creek was predicted to be low. The level of confidence in this assessment was low because of the difficulty in making an accurate prediction of how the benthic macro-invertebrate community would respond to the potential combined effects of changes in water quality, stream flow, and water temperature in Lime Creek.

Overall, the significance of these potential indirect effects on individual Dolly Varden was predicted to be not significant (minor). This prediction was based on the assumption that the combined effects of changes in water quality, stream flows, water temperature and benthic macro-invertebrate drift would not be distinguishable at the population level for Dolly Varden in lower Lime Creek. The Dolly Varden population in lower Lime Creek would be predicted to be sustained at its current level of abundance, distribution, and health during all phases of the Project.

6.7.2.11 Cumulative Effects Assessment

6.7.2.11.1 Rationalisation for Carrying Forward Project Related Residual Effects Into the Cumulative Effects Assessment In order to produce a cumulative effect, minor or moderately significant residual effects of the proposed Project on Dolly Varden must overlap temporally or spatially with known or likely residual effects from past, present, or foreseeable projects. The minor or moderate

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KITSAULT MINE PROJECT ENVIRONMENTAL ASSESSMENT FRESHWATER AQUATIC RESOURCES residual effects of the proposed Project on Dolly Varden carried forward in the cumulative assessment are listed in Table 6.7.2-40.

Table 6.7.2-40: Project Related Residual Effects - Rationale for Carrying Forward Into the Cumulative Effects Assessment

Carried Project Project Component Residual Effect Rationale Forward Phase in CEA Effluent release from C, O, Change in Surface Changes in surface water Yes the TMF and overflow D/C, water quality in lower quality could affect the growth, from the Kitsault Pit PC Lime Creek health, and survival of Dolly post-closure Varden in lower Lime Creek Construction, C, O, Change in Hydrology Changes in stream flows could Yes operation, and D/C, in lower Lime Creek affect the spawning success decommissioning of PC and egg to hatching survival of the TMF and overflow Dolly Varden in lower Lime from the Kitsault Pit Creek post-closure Construction, C, O, Change in benthic Changes in the benthic Yes operation, and D/C, macro-invertebrate invertebrate community in Lime decommissioning of PC drift in lower Lime Creek could affect the growth the TMF and Kitsault Creek and survival of coho salmon Pit parr in lower Lime Creek Note: C - construction; O - operations; D/C - decommissioning and closure interaction

Potential indirect effects to Dolly Varden in lower Lime Creek due to potential changes in water quality, stream flows, and benthic macro-invertebrate drift are carried forward into the assessment of potential cumulative effects. This is because these potential residual effects have the potential to reduce the growth, survival of individual Dolly Varden and to reduce the annual recruitment of the Dolly Varden population in lower Lime Creek and, therefore, have the potential to cumulatively interact with past, present, or reasonably foreseeable projects or land uses in the Lime Creek watershed or in the greater Alice Arm and Observatory Inlet area.

6.7.2.11.2 Interaction Between Dolly Varden and Other Past, Present or Future Projects / Activities Past mining activities at the Kitsault Mine during the 1960s and early 1970s and again during the early 1980s may cumulative interact with predicted residual effects of the proposed Kitsault Project on Dolly Varden in two ways. First, previous disposal of mine tailings in Lime Creek in the early 1970s may have previously extirpated the Dolly Varden run in Lime Creek (i.e., the current Dolly Varden run in Lime Creek was a result of recolonisation during the 40 years since tailings disposal in the creek stopped) or may have reduced the size, growth, and health of the Dolly Varden population in lower Lime Creek from pre-disposal condition. Second, channelisation of the lower reaches of Lime Creek during the construction of the town of Kitsault during the early 1980s may have reduced the

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KITSAULT MINE PROJECT ENVIRONMENTAL ASSESSMENT FRESHWATER AQUATIC RESOURCES spawning, rearing, or overwintering habitat of the lower reaches of Lime Creek for Dolly Varden. This channelisation eliminated the natural delta at the mouth of the creek that can be clearly see in old aerial photos. The channels in this delta could have provided additional spawning and rearing habitat for Dolly Varden prior to construction of the town and prior to the deposit of mine tailings in the creek in the 1970s. Such a change in the physical habitat of lower Lime Creek may have reduced the size, condition, and health of the current Dolly Varden population compared to pre-mine, pre-town conditions.

Three other past or current Projects or land uses have the potential to cumulatively interact with potential residual effects of the Kitsault Project on Dolly Varden. These are the past mining activities at the head of Observatory Inlet (principally the old Anyox Slag heap), the on-going commercial and recreational fisheries in the Alice Arm / Observatory Inlet area, and the on-going recreational fishing in the Kitsault and Illiance Rivers guided by Nisga’a guides. The Anyox Slag heap is the tailings of a copper mine which were deposited in the nearshore area of Granby Bay between 1914 and 1936. The ongoing erosion of slag deposits are thought to be cause of elevated levels of copper, zinc, cadmium, and iron in the local marine sediments 42 years after mine abandonment (Johannessen et al., 2007). Thus, past or on-going contamination from this mine has the potential to cumulatively increase the acute or chronic toxicity of any of these metals that Dolly Varden in Lime Creek may be exposed to during construction, operation, and closure of the Kitsault Project.

Dolly Varden are not targeted in any commercial fisheries or in any recreational fishery in Alice Arm / Observatory Inlet or their tributary rivers. However, they can be by-catch in commercial and recreational fisheries targeting salmon or steelhead. Therefore, the potential exists for both commercial and recreational fishing to cumulatively reduce the number of Dolly Varden returning to Lime Creek to spawn, thus potentially reducing the sustainability of the Lime Creek population.

All three of these past or on-going projects or land uses have the potential to interact with Dolly Varden potentially affected by residual effects of the Kitsault Project because of the migratory behaviour of adult Dolly Varden once they enter the ocean and because of the potential amphidromous behaviour of juvenile Dolly Varden in Lime Creek.

The potential interactions between past, present, and reasonably foreseeable future projects and potential residual effects from the Kitsault Project on Dolly Varden are identified in Table 6.7.2-41 below.

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Table 6.7.2-41: Assessment of Interaction between Other Projects, Human Activities and Reasonable Foreseeable Projects with Dolly Varden

Reasonably Representative current and Historical land use foreseeable future land use Projects

Potential Effect a’a Nation hunting, hunting, Nation a’a Kitsault Mine and and Mine Kitsault exploration (on- site Town Kitsault going) Alice Arm town site (on- going) mine Previous operations mine Previous exploration and Transportation access Mining exploration guide and Trapping outfitting Nisg trapping, fishing and and fishing trapping, uses other hunting, Aboriginal and fishing trapping, uses other Northwest Transmission Project Line Change in Dolly - - NI - NI NI NI o o NI Varden growth, survival and health due to change in Surface water quality in lower Lime Creek Change in Dolly - - NI NI NI NI NI o o NI Varden growth, survival, and recruitment due to change in stream flows in lower Lime Change in Dolly o o NI NI NI NI NI NI Ni NI Varden growth and survival due to change in benthic macro- invertebrate drift in lower Lime Creek Note: Interaction definitions: o - interaction; - - key interaction; + - benefit; NI - no interaction

An assessment of the potential spatial and temporal overlap between potential residual effects of the Kitsault Project and other past, present, or reasonably foreseeable future Projects on Dolly Varden is provided in Table 6.7.2-42.

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Table 6.7.2-42: Assessment of Spatial and Temporal Overlap Betw

Residual Cumulative Effect (Contribution HumanVarden Activity Environmental Extent Duration Rationale From Project or Overlap) Effect Historical land Kitsault Mine and Change in habitat Local Chronic Mine tailings potentially Potential decrease in the growth, use exploration and water quality in affected size and health of survival, recruitment and health of Lime Creek due to Dolly Varden population in Dolly Varden in lower Lime Creek deposit of mine Lime Creek tailings in the creek een the Project and Other Projects and Human Actions with Dolly Kitsault Townsite Channelisation of Local Chronic Alteration of fish habitat Potential decrease in size and lower reaches of reduced size, growth, and annual recruitment of Dolly Varden Lime Creek recruitment of Lime Creek in lower Lime Creek Dolly Varden population Alice Arm townsite No interaction Past mine Change in water Regional Chronic Mine tailings potentially Potential decrease in the growth, operations quality and sediment affect the health of survival, recruitment and health of quality in Alice Arm / migratory adult Dolly Dolly Varden in lower Lime Creek Observatory Inlet Varden in nearshore areas of Alice Arm / Observtory Inlet and amphidromous juvenile Dolly Varden in Lime Creek Past mine No interaction exploration Representative Transportation No interaction current and and access future land use Mining exploration No interaction Trapping, fishing Reduction of Dolly provincial Chronic Fishing pressure reduces Potential decrease in the number of and guide Varden in north number of Dolly Varden Dolly Varden returning to Lime outfitting coast rivers returning to natal streams Creek to spawn to spawn Nisga’a Nation Reduction Dolly regional intermittent Fishing pressure reduces Potential decrease in the number of hunting, trapping, Varden in the number of Dolly Varden Dolly Varden returning to Lime fishing and other Kitsault and Illiance returning to Lime Creek to Creek to spawn uses rivers spawn

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Residual Cumulative Effect (Contribution Human Activity Environmental Extent Duration Rationale From Project or Overlap) Effect Aboriginal hunting, No interaction trapping, fishing and other uses Reasonably Northwest No interaction foreseeable Transmission Line projects Project

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6.7.2.11.3 Mitigation Measures There are no mitigation measures specifically proposed to eliminate potential cumulative effects of the Kitsault Project on Dolly Varden with residual effects for other past, present, or reasonably foreseeable future projects or land uses. The likely effectiveness of each of the mitigation measures that would be used to reduce Project effects on Dolly Varden have already been assessed above and it is only those Project effects with potential residual effects to Dolly Varden that are being assessed here for their potential cumulative effects (Table 6.7.2-43).

Although not strictly a mitigation measure, an environmental effect monitoring program would be developed in consultation with Environment Canada, the BC MOE, and the NLG prior to construction of the Project. This monitoring program would be designed and implemented with the two-fold purpose of: 1) assessing whether predictions made during the impact assessments are accurate; and 2) determining whether any unanticipated effects are occurring, and if so, to trigger the implementation of additional mitigation, adaptive management, and / or compensation as required.

Table 6.7.2-43: Potential Cumulative Effect by Project Phase on Dolly Varden and Mitigation Measures

Mitigation Project Cumulative Project Mitigation / Enhancement Measure Success Effect Phase Rating Change in surface water C,O, Water management plan, water treatment Medium quality in Lime Creek D/C, PC plant at closure (if required), adherence to site-specific water quality objectives Change in hydrology in C,O, Water management plan Medium Lime Creek D/C, PC Change in benthic macro- C,O, Water management plan, water treatment Medium invertebrates in Lime D/C, PC plant at closure (if required), adherence to Creek site-specific water quality objectives Project Phase: C - construction; D/C - decommissioning and closure; O - operations; PC - post-closure

6.7.2.11.4 Potential Residual Cumulative Effects and Their Significance The potential for residual effects on Dolly Varden from the Kitsault Project to interact cumulatively with potential residual effects of past mining at Kitsault, construction of the Kitsault townsite, past mining in the Alice Arm and Observatory Inlet area, and on-going and future commercial and / or recreational fishing, including the fishing the in Kitsault and Illliance rivers guided by Nisga’a peoples is considered to be unlikely (Table 6.7.2-44). This assessment is based on the following:

 No physical change in habitat or access to habitat upstream of the cascade impediment in lower Lime Creek occurred during previous mining operations at Kitsault or during construction of the town of Kitsault;

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 The likelihood that an adult Dolly Varden from Lime Creek would move upstream into adjacent rivers with past mining or exploration activities (e.g., the Kitsault River, Illiance River) is low. This is because adult Dolly Varden are more likely to remain in the nearshore areas and estuaries of Alice Arm and Observatory inlet rather than moving into other freshwater rivers. Such movements from salt to freshwater come with energetic costs from having to adapt to the different osmoregulatory gradients between the two environments. Thus, adult Dolly Varden from Lime Creek are more likely to remain in salt water or the brackish water of estuaries rather than foray up into freshwater rivers;  The likelihood of juvenile or adult Dolly Varden coming within direct contact of past physical changes in habitat or chemical changes in water quality caused by past mine operations or mine exploration in the Kitsault River and in the Illiance River is restricted by barriers or impediments to fish passage in both rivers. Almost all of the past mine operations in the Kitsault River watershed are located upstream of the waterfall / gradient barrier present in the Kitsault River mainstem approximately 23 km upstream from its mouth. Similarly, the Illy Mine is located on a headwater tributary of the Illiance River upstream of numerous potential barrier and impediments to upstream fish passage;  The likelihood of adult Dolly Varden encountering and remaining in the vicinity of the mine tailings deposited in Granby Bay by the past Anyox Slag Heap long enough to increase copper, zinc, cadmium, or iron concentrations to potentially lethal or sub- lethal concentrations is unlikely. The Anyox Slag Heap is close enough to Lime Creek that adult Dolly Varden from Lime Creek could migrate to Granby Bay. However, the number of Dolly Varden that would do this and the length of time any one fish would stay in Granby Bay is unknown but assumed to be low;  The number of Lime Creek Dolly Varden removed in commercial salmon and halibut fisheries annually is likely low due to the nearshore habitat use of adult Dolly Varden and thus their likely low susceptibility to these fisheries; and  The number of Lime Creek Dolly Varden removed in recreational fisheries in Alice Arm and in the Kitsault and Illiance Rivers is likely low because Dolly Varden are not the target fish species in the non-guided or guided recreational fisheries in the area.

Table 6.7.2-44: Summary of Residual Cumulative Effects for Dolly Varden

Residual Cumulative Effect After Mitigation or Likelihood of Project Phase Direction Enhancement Occurrence C,O, D/C, PC Change in Dolly Varden growth and survival due to Negative Likely surface water quality in Lime Creek due to TMF seepage and past deposition of mine tailings in Lime Creek during previous Kitsault mine operations C,O, D/C,PC Change in Dolly Varden growth and survival due to Negative Unlikely changes in habitat conditions in lower Lime Creek including straightening of Lime Creek during construction of the Kitsault townsite

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Residual Cumulative Effect After Mitigation or Likelihood of Project Phase Direction Enhancement Occurrence C,O, D/C, PC Change in Dolly Varden growth, survival and Negative Unlikely recruitment due to change in water quality in Lime Creek and change in water and sediment quality in the marine environment due to past mine operations C,O,D/C, PC Change in Dolly Varden growth, survival, and Negative Unlikely recruitment due to change in water quality in Lime Creek and exposure to changes in water and sediment quality in adjacent Alice Arm rivers with past mine and exploration activities C,O, D/C, PC Change in Dolly Varden escapement in Lime Creek Negative Unlikely due to reduce habitat suitability in Lime Creek and increasing fishing pressure in commercial and recreational fisheries Note: C - construction; D/C - decommissioning and closure; O - operations; PC - post-closure

The only potential cumulative effect on Dolly Varden with a reasonable likelihood of occurrence is the potential residual effects from the deposition of mine tailings in Lime Creek during previous mining operations at Kitsault (Table 6.7.2-45). This potential cumulative effect is considered to be not significant (minor) because the presence of a Dolly Varden population in Lime Creek suggests that any previous residual effects of past mining activities and mine tailings deposition in Lime Creek have abated since previous mining concluded over 35 years ago. It is not apparent from metals concentrations in the current Dolly Varden population that any lasting effects of past residual effects from tailings deposition remain.

Table 6.7.2-45: Residual Cumulative Effects Assessment on Dolly Varden by Project Development Phase

Current / Future Project Contribution Cumulative Parameter Cumulative Project Phase Environmental Effect(s) Environmental Effect Without Project Change in Dolly Varden growth, survival and health from combined changes C,O,D/C, PC in water quality in Lime Creek due to past deposition of mine tailings and mine effluent from proposed Kitsault Project Effect Attribute Direction Negative Negative Magnitude Low Low Geographic extent local Local Duration chronic Chronic Frequency continuous Continuous Reversibility no No Probability of Unknown Low occurrence Certainty low High Residual Effect Not significant Not significant (minor) Significance (negligible)

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Current / Future Project Contribution Cumulative Parameter Cumulative Project Phase Environmental Effect(s) Environmental Effect Without Project Level of Confidence Low High Note: C - construction; D/C - decommissioning and closure; O - operations; PC - post-closure

6.7.2.12 Limitations

The assessment of potential project-specific and cumulative effects on Dolly Varden was dependent on results of quantitative modelling conducted to determine the potential changes in surface water quality and stream flows and on qualitative assessment of the potential effects of changes in water temperatures and benthic invertebrates in Lime Creek. Models are simplified abstractions of reality. However, they are useful because they provide a means of predicting future conditions that would otherwise not be possible without actually imposing the effect on the environment and monitoring changes in the receptors. As such, the accuracy of any model’s predictions are dependent on the quality of the input data, the accuracy of calibrated model to predict existing conditions, and the number and validity of the assumptions included in the model.

Although all of the models used to predict changes in surface water quality and stream flows were calibrated using real data, each model had limitations on the available input data (e.g., using regional data sets to calibrate site-specific watershed models) and had necessary assumptions (e.g., all the dissolved metals remain in solution and do not form more complex compounds that would make them biologically unavailable) that may have affected the accuracy of the models to predict future conditions. The limitations and assumptions for each of these models are described in greater detail in Section 6.5 (Hydrology) and Section 6.6 (Surface Water Quality).

Most critically to the assessment of potential effects of the Project on Dolly Varden, was the uncertainty regarding the potential effect of the predicted exceedences of existing provincial and federal water quality guidelines for the protection of freshwater aquatic biota for a number of potential chemicals of concern (e.g., selenium) in Lime Creek. Taken at face value, these predicted exceedences could result in significant adverse effects to individual Dolly Varden health, growth, and survival, to the aquatic foodwebs upon which these Dolly Varden depend, and to the sustainability of the Lime Creek Dolly Varden population. However, as the assessment above explains, some of these guidelines may be overly protective for Dolly Varden and site-specific water quality guidelines may be more appropriate. Furthermore, the water quality model used to predicted parameter concentrations in lower Lime Creek included assumptions that may not be valid (e.g., all water quality parameters behaviour conservatively in water) and included inputs from other models (e.g., site water balance, watershed model, source term loading model). Each of these other models also had assumptions which may not be valid (e.g., mercury loading concentrations were assumed to equal the laboratory detection limit) and limitations (e.g., stream flows could be predicted on a monthly time step but not at a daily time step). These

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Finally, professional judgement was necessarily used to assess potential effects to Dolly Varden where quantitative modeling results were unavailable (e.g., potential change in water temperature changes, potential change in benthic macro-invertebrate drift) and where the accuracy of quantitative modeling was restricted by model assumptions and limitations. This was true for the assessment of potential indirect effects of the Project on Dolly Varden but was more so for the assessment of potential cumulative effects. This was because of the relative paucity of information regarding the residual effects from past, present, and reasonably foreseeable Projects in the Alice Arm / Observatory Inlet area that may cumulative effect Dolly Varden in Lime Creek and the uncertainty surrounding the behaviour of individual Dolly Varden spawned in Lime Creek to move into areas where residual effects from past or present Projects may be present. However, whenever and wherever professional judgement was used, evidence from the published literature and from the baseline site conditions was used to assist in assessing these potential residual Project and cumulative effects.

6.7.2.13 Conclusion

Potential effects to Dolly Varden in lower Lime Creek exist in the form of potential changes to their growth, health, survival, and recruitment due to predicted changes in surface water quality, stream flows, water temperatures, and benthic macro-invertebrate drift in Lime Creek. Mitigation measures to reduce or eliminate these potential indirect effects include implementation of the mine water management plan (including extension of the Kitsault Pit re-fill period to between 15 and 17 years by diverting non-contact Patsy Creek run-off to Lime Creek during closure), capture and pumping of TMF seepage during construction and operations, potential water treatment of mine effluent during post-closure, and adherence to any site-specific water quality objectives that may be promulgated during consultations with Environment Canada, the BC Ministry of Environment and the Nisga’a Lisims Government.

While the mitigation measures proposed would not likely eliminate all potential effects to Dolly Varden, the significance of these potential residual effects was assessed to be not significant minor or negligible. These significance ratings were based on the fact that each indirect potential effect would likely have a low magnitude (i.e., <10% change from baseline

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KITSAULT MINE PROJECT ENVIRONMENTAL ASSESSMENT FRESHWATER AQUATIC RESOURCES conditions), and a local geographic extent (i.e., limited to the Lime Creek). However, level of confidence in these assessments ranged from high for potential effects from changes in stream flow (because quantitative modeling was used), to medium for potential effects from changes in water quality (because of the uncertainties described above), to low for potential effects from changes in water temperature and benthic invertebrate drift (because no quantitative modeling was conducted).

Potential cumulative effects to Dolly Varden due to potential interaction between residual effects of the Project and potential residual effects from other past, present, or reasonably foreseeable future project or land uses were considered negligible. This included potential cumulative effects the deposit of mine tailings in Lime Creek and the straightening of the lower reach of Lime Creek during construction of the town of Kitsault. Although no previous data are available for comparison, the current Dolly Varden population in Lime Creek does not appear to be limited in numbers or health by past mining activities. This is because there is no obvious evidence suggesting that habitat in lower Lime Creek has been dramatically modified by past mining activities or that the Dolly Varden population in lower Lime Creek is not at carrying capacity of this available habitat and because there is no obvious evidence that the Dolly Varden population is carrying metal burdens from previous mining activities that would be limiting the growth, survival or reproductive success of individual fish.

Similarly, the potential cumulative effects on Dolly Varden from on-going or future commercial or recreational fishing or from past mining and mine exploration projects in Alice Arm / Observatory Inlet area was expected to be low. This was because Dolly Varden are not the fish species targeted in either fishery along the north coast of BC and because the migratory behaviour of adult and juvenile Dolly Varden likely limits their exposure to those past project with potential residual water quality effects in the nearshore marine environment. Of the numerous past mine operations and mine exploration activities in the Alice Arm / Observatory Inlet area, only the Anyox Slag Heap in Granby Bay would appear to meet these criteria. While it is possible that individual Dolly Varden may travel to Granby Bay, the likelihood of potential cumulative effects on the Dolly Varden population in Lime Creek is low because the number of Dolly Varden from Lime Creek moving to this area is likely to be low and the duration any one fish spent within the zone of influence of the Anoyx Slag Heap is likely to be short.

6.7.3 Coho salmon 6.7.3.1 Introduction

Coho salmon were selected as a VC because of the presence of coho salmon parr in lower reaches of Lime Creek during the 2010 field investigations, the potential interaction of the Project with these fish due to potential changes in Lime Creek water quality and flow, and the importance of coho salmon to the Nisga’a Nation, other Aboriginal groups, federal and provincial regulators and the public at large (see Table 6.5.1-6).

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Although the Kitsault Project has the potential to interact with individual coho salmon parr in lower Lime Creek, there is no potential direct, indirect, or combined Project effects on a coho salmon stock in Lime Creek. This is because it is highly likely that the coho salmon parr found in lower Lime Creek are strays from other rivers or streams in the Alice Arm area that have entered Lime Creek to seek refuge from predators in the ocean.

Evidence for this assertion is based on the fact that there were no coho salmon parr found in Lime Creek upstream of the first cascade impediment to fish passage during 2009 and 2010 field investigations. This 3 metre high cascade is not an impediment to adult Dolly Varden that use Lime Creek for spawning. Because adult coho salmon are larger and stronger swimmers than Dolly Varden, there is no reason to believe that adult coho salmon wouldn’t also be able to pass this cascade if a coho salmon spawning run was present in Lime Creek. However, Dolly Varden were the only fish species found upstream of this cascade in both years of study. For this reason, it was concluded that coho salmon do not spawn in Lime Creek and that the coho salmon parr found in the lower 270 metres of Lime Creek during the summer of 2010 were strays from other rivers. This straying behaviour of coho salmon parr is well documented (numerous authors referenced in Koski 2009) and is believed to be a predatory avoidance behaviour for coho salmon parr that are displaced from their natal streams due to physical displacement as fry during high spring flows, a behavioural response due to density-dependent space limitations, and or habitat limitations (Koski 2009).

Potential direct, indirect, and combined effects of the Kitsautl Project on the health, growth, and survival of individual coho salmon parr are assessed below. Potential direct effects on coho salmon parr are limited to potential mortality from blasting. Potential indirect effects on coho salmon parr include changes in Lime Creek water quality, water temperature, and benthic invertebrate drift and changes in Lime Creek flows. Potential combined effects on coho salmon parr include all potential direct and indirect effects listed above.

Potential cumulative effects of the Project on coho salmon were assessed only for those direct, indirect, or combined Project effects that would likely result in a residual impact. Each of these residual impacts was then assessed for its potential to negatively affect coho salmon affected by residual impacts from other past, present, or reasonably foreseeable Projects in the Alice Arm area.

6.7.3.2 Relevant Legislation and Legal Framework

Two levels of government have jurisdiction over coho salmon potentially affected by the Kitsault Project. The relevant legislation and legal framework for both of these levels of government is described below.

6.7.3.2.1 Federal The following sections of the Fisheries Act apply to the protection of coho salmon and coho habitat:

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 Section 32 of the federal Fisheries Act prohibits the destruction of fish by any means other than fishing except as authorised by Fisheries and Oceans Canada. Thus, for the purposes of the Kitsault Project and its effects on coho salmon, any Project component or activity that would result in the killing of coho salmon is prohibited by law.  Section 35(1) of the federal Fisheries Act prohibits the harmful alteration, disruption, or destruction (HADD) of fish habitat in Canada.  Section 35(2) of the Fisheries Act allows a HADD of fish habitat if it is authorised by Fisheries and Oceans Canada (DFO). Such an authorisation would be issued by DFO only if it is satisfied that there would be “no-net-loss (NNL) of productive capacity of fish habitat”. The proponent would require a Section 35(2) Authorisation from DFO for any unavoidable HADD of fish habitat in Lime Creek where coho salmon are known to reside. Any such HADDs would require a fish habitat compensation plan that meets DFO’s “no-net-loss” guiding principle.  Section 36(3) of the Fisheries Act prohibits “the deposit of a deleterious substance of any type in waters frequented by fish or in any place, under any conditions, where the deleterious substance may enter any such water”. Thus, for the purposes of the Kitsault Project and its effects on coho salmon, Section 36(3) of the Fisheries Act effectively prohibits the deposit of any deleterious substances in Lime Creek in quantities or toxicity sufficient to adversely affect the growth, health, survival, and reproduction of coho salmon.

Coho salmon populations in the Nass Area are not listed on any of the schedules in the federal Species at Risk Act (SARA). Similarly, Nass Area coho salmon are not considered threatened, endangered, or at risk by the Committee on the Status of Endangered Wildlife in Canada (COSEWIC).

Fisheries and Oceans Canada is responsible for managing Pacific salmon stocks in a manner that balances conservation goals with Aboriginal, recreational and commercial fishing opportunities. To do so, DFO has adopted and implemented the following policies and treaties:

 Salmonid Enhancement Program: a program aimed to rebuild vulnerable salmon stocks, to provide harvest opportunities, to work with First Nations and coastal communities in economic development, and to improve fish habitat to sustain salmon populations with: fish hatcheries, habitat restoration projecs, and stewardship and education initiatives;  Wild Salmon Policy: a policy whose objectives are to safeguard the genetic diversity of wild Pacific salmon stocks, to maintain habitat and ecosystem integrity, and manage fisheries for sustainable benefits; and

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 Pacific Salmon Treaty: a framework through which Canada and the United States work together to conserve and manage high migratory Pacific salmom stocks that transverse the political boundaries of the two countries.

In addition, DFO is responsible for the management of salmon fisheries in British Columbia, both in freshwater (i.e., in rivers) and in tidal areas.

6.7.3.2.2 Provincial The province of British Columbia does not have jurisdiction of the management of salmon stocks in BC. Additionally, the province of BC does not have constitutional authority over fish habitat in BC. Instead, the provincial government provides only an advisory role to DFO in regards to when fish or fish habitat can be destroyed or altered and what would be required to ensure that “no-net-loss of the productive capacity of fish habitat” is achieved. This responsibility rests solely with DFO.

6.7.3.2.3 Nisga’a Lisims Government The Nisga’a Final Agreement (NFA) states “the Minister is responsible for the management of fisheries and fish habitat” with the Minister being defined as either the federal or provincial government. However, the NFA goes on to state that “fisheries management may involve the consideration of issues on a regional or watershed basis”. If Canada or British Columbia proposes to establish fisheries management advisory bodies for areas that include any part of the Nass Area, Canada or British Columbia will consult with the Nisga’a Nation in developing those bodies and, if appropriate, will provide for the participation of the Nisga’a Nation in those bodies.” This indicates that while the authority over fish habitat remains with Canada and the province, they do have a duty to consult on fish habitat issues within the Nisga’a traditional territory.

6.7.3.3 Spatial Boundaries

A description of and rationale for the Local Study Area (LSA), Regional Study Area (RSA), and cumulative effects study area (CESA) for coho salmon is provided in the sections below.

6.7.3.3.1 Local Study Area The Local Study Area (LSA) for coho salmon was restricted, like that for Dolly Varden, to the Lime Creek watershed (Figure 6.7.1-1). This LSA was selected because it is the only watershed where potential direct effects to coho salmon from the Kitsault Project could occur.

Potential direct Project effects to coho salmon in the Illiance River and the lower 250 metres of Clary Creek downstream of the impassable waterfalls would not occur, and these areas were excluded from the LSA as a result, because:

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 No blasting would occur in the Clary Creek watershed (therefore no potential for direct mortalities to coho salmon from blasting); and  The project would not provide any new access for anglers to coho salmon in lower Clary Creek or in the Illiance River. Construction and operation of the Kitsault Project would not result in the direct loss of habitat used by coho salmon. This is because all necessary Project components and activities would be located in the non-fish-bearing headwaters of the Lime Creek watershed and in the headwaters of Clary Creek watershed located upstream of impassable waterfalls in both watersheds. Nevertheless, the LSA includes Patsy Creek, Patsy Lake, and upper Lime Creek only to show the location of the project in relation to the location of coho salmon parr in lower Lime Creek.

6.7.3.3.2 Regional Study Area The Regional Study Area (RSA) for coho salmon is the same as that defined for Dolly Varden. This RSA includes the Lime Creek watershed plus the adjacent watersheds known to support coho salmon that may be affected by potential indirect effects of the Project. These potential indirect effects include, but are not limited to, potential changes in water quality due to mine discharges and seepage, potential changes in stream flows due to diversions, loss of upstream catchment area, and potential changes in fish pressure due to the presence of the Kitsault Mine workforce. Coho salmon are known to be present in the Illiance River and in the lower reach of Clary Creek downstream of the impassable waterfalls. Therefore, RSA for coho salmon includes (Figure 6.7.2-1):

 The Lime Creek watershed;  The Clary Creek watershed; and  The Illiance River.

6.7.3.3.3 Cumulative Effects Study Area The CESA for coho salmon includes the watersheds and watercourses within the LSA and RSA plus those watersheds with past, present, or reasonably foreseeable Projects with known or likely residual effects that could cumulatively affect coho salmon populations in the Alice Arm area because of temporal or spatial overlap with the Kitsault Project. Although coho salmon are highly migratory and any coho salmon spawned or reared in streams and rivers in the Alice Arm area (including those rearing in lower Lime Creek) could migrate many hundreds or thousands of kilometres out into the Pacific Ocean, the limits of the CESA for coho salmon were restricted to Alice Arm, Hasting Arm and the Observatory Inlet (Figure 6.7.2-1). This is the same CESA used for the Dolly Varden. This was not intended to diminish the potential cumulative effect of sources of human-induced mortality to salmon in the ocean (e.g., commercial and recreational fishing) but was instead intended to put limits on what could be reasonably assessed in the cumulative effects assessment.

Based on the above information, the CESA for coho salmon includes:

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 Lime Creek Watershed;  Clary Creek Watershed;  Roundy Creek Watershed;  Illiance River Watershed;  Kitsault River Watershed;  Alice Arm;  Hastings Arm; and  Observatory Inlet.

6.7.3.4 Temporal Boundaries

Temporal boundaries for assessment of potential effects of the Kitsault Project on coho salmon were based on the reasonable expectation of the time over which the proposed Project has had and would have effects on coho salmon. Thus, the selection of temporal boundaries for coho salmon was driven by the duration of each of the four primary phases of the proposed Project:

1. Construction Phase: estimated 25 month period that includes site preparation, construction of mine infrastructure access roads and transmission lines, and implementation of the construction phase water management plan; 2. Operations Phase: estimated at approximately two months of commissioning, and 15 to 16 years of mining, including two years of milling of low grade ore and progressive reclamation 3. Decommissioning and Closure Phase: estimated at 15 to 17 years, including removal of non-needed infrastructure, reclamation of facilities and enactment of closure water management plan; 4. Post-Closure Phase: estimated at five years or more, including post-closure monitoring and stabilisation of waste rock and TMF.

6.7.3.5 Information Source and Methods

6.7.3.5.1 Field Studies Baseline information on coho salmon in Lime Creek was collected during 2009 and 2010 field seasons (Appendix 6.7-A). Sampling in 2009 and 2010 had three main objectives: 1) determine the fish-bearing status of Lime Creek, Patsy Creek, and Patsy Lake upstream of the 8 metres (m) waterfalls in Lime Creek; 2) determine the fish community composition, relative abundance, and spatial distribution in Lime Creek downstream of the 8 m waterfall (i.e., lower Lime Creek); and 3) collect fish for tissue metal residue analysis as required for MMER monitoring.

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The primary method of fish capture during the 2009 surveys was backpack electrofishing. Sampling for coho salmon was conducted in July and September and included two sites in lower Lime Creek below the waterfalls. No sites were sampled below the first cascade impediment to fish passage in 2009. Sampling in September also included angling in the pool directly below the waterfalls in Lime Creek.

Sampling in Lime Creek was conducted during four distinct periods in 2010: early July, late July, early September and early October. Sampling methods included backpack electrofishing, angling, and baited minnow traps. Unlike 2009, sampling in 2010 included the entire length of Lime Creek from the impassable waterfalls located approximately 1.6 km upstream to the mouth of Lime Creek at Alice Arm.

In addition to fish sampling, stream habitat in Lime Creek was assessed and mapped using the following standardised methods:

 Resource Inventory Standard Committee (RISC) Reconnaissance (1:20,000) Fish and Fish Habitat Inventory: Reach Information Guide (RISC 2000);  Fish Habitat Assessment Procedures (Johnston and Slaney 1996); and  Sensitive Habitat Inventory and Mapping (Mason and Knight 2001).

Baseline data collected in the field was augmented with:

 Fish distribution reports, and lake, stream, and stocking reports from the provincial Fisheries Inventory Summary System (FISS), Fisheries Inventory Data Query (FIDQ), EcoCat, FishWizard, and HabitatWizard databases;  Species summary and status reports from the BC Conservation Data Center (BC CDC);  Salmon escapement estimates from DFO Pacific Region’s nuSEDs database;  Freshwater and anadromous fish and fish habitat in the North Coast. North Coast LRMP Background report (Gordon and Bahr, 2003);  Final Watershed Report for selected watersheds in DFO Areas 3, 4, 5, 6, & 7 (Rolston and Proctor 1999) from DFO’s WAVES on-line library;  Fisheries and habitat assessments conducted prior to re-starting of the mine in 1981 (i.e., McCart and Withler 1980; Lea and Goddard 1975; O’Connell 1976); and  Fish life history and habitat use syntheses (e.g., Ford et al. 1995; Haas 1998; Roberge et al. 2002; McPhail 2007.

6.7.3.5.2 Regional Baseline Clary Creek (downstream of the waterfalls) and the Illiance River were not sampled as part of baseline fisheries field investigations in 2009 and 2010. Information regarding the distribution and relative abundance of coho salmon in these systems was obtained through

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KITSAULT MINE PROJECT ENVIRONMENTAL ASSESSMENT FRESHWATER AQUATIC RESOURCES a desktop review of the data sources listed above (principally the nuSEDS database and FISS), any available baseline information from past or current environmental impact assessments, past monitoring reports for the previous Kitsault mining operations, and published grey and primary literature available for the watersheds included within the RSA. All available information was reviewed and summarised. When identified documents were not available online, government agencies were contacted directly to request reports.

6.7.3.6 Detailed Baseline for Coho Salmon

6.7.3.6.1 Distribution and Catch No coho salmon were observed or captured in 2009. This was likely due to the relatively low fishing effort (only 926 seconds of backpack electrofishing and 1 rod-hour of angling) conducted in 2009 in the lower Lime Creek.

Eighteen coho salmon parr (<90 mm) were captured in lower Lime Creek in late July of 2010. These fish were all captured in the lower 268 m of Lime Creek downstream of the first cascade impediment to upstream fish passage in the creek. The cascade is made of bedrock but it includes boulders and step pools within its length. The overall height of this cascade is approximately 3 to 4 metres with an overall gradient of approximately 8%. There is an large, deep (>3 m) pool located immediately below it. No coho salmon were captured upstream of this cascade impediment in 2010 despite over 16,000 seconds of electrofishing, 165 trap-hours of minnow trapping, and 4 rod-hours of angling.

Of the fish captured below the cascade, coho salmon parr (16%) were the second most abundant fish species, after coastrange sculpin (68%). These were followed by prickly sculpin and Dolly Varden (8% each).

The absence of coho salmon parr upstream of the cascade indicates that coho salmon do not spawn in Lime Creek. This cascade is passable by adult Dolly Varden in fall and would be equally passable by adult coho salmon if there was a coho salmon spawning run in Lime Creek. There is an abundance of suitable salmon spawning habitat upstream of this cascade. The absence of coho salmon parr above this cascade indicates that coho salmon do not use this habitat for spawning.

The presence of coho salmon parr in the lower 268 metres of Lime Creek downstream of the first cascade impediment are likely strays that were spawned elsewhere and had moved into Lime Creek to seek refuge from predators in Alice Arm. This phenomenon of rearing in non-natal streams has been observed for coho salmon elsewhere in BC (Levings et al. 1995; Levy and Northcote 1982), in other locations from Alaska to northern California (Koski 2009; Wallace and Allen 2009) and for other Pacific salmon species such as Chinook salmon (Murray and Rosenau 1989).

6.7.3.6.2 Length, Weight, and Condition Coho salmon captured in Lime Creek in 2010 had an average length of 52 mm (± 4 mm) and an average weight of 2.8 g (± 0.6 g). Coho salmon ranged in length between 33 and

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88 mm (Figure 6.7.3-1). Although none of these fish were aged, coho salmon <90 mm on the North Coast are typically young-of-the-year (McPhail 2007). Coho salmon parr captured had an average condition factor of 1.65 (± 0.07), ranging between 1.25 and 2.39.

9 n=18 8 7 6 5 4

Frequency 3 2 1 0 <20 21-30 31-40 41-50 51-60 61-70 71-80 81-90 91-100 Length class (mm)

Figure 6.7.3-1 Length-Frequency Distribution of Coho Salmon Captured in Lower Lime Creek in 2010

A weight-length relationship for coho salmon parr in Lime Creek, based on all fish captured in 2010, is described by the formula:

LnWt = 2.61LnLt - 9.51

Where LnWt is the natural logarithm of weight in grams and LnLt is the natural logarithm of fork length in millimetres. The sample size for this equation was 18 fish and the equation had a r2 of 0.97.

6.7.3.6.3 Life History Coho salmon are an anadromous fish species. Adult migrate from the sea to their natal stream to spawn, after which, the adults die Once fry emerge from the gravel, they seek out shallow water, usually moving to the stream margins, sometime forming schools. As they grow larger, individual fish will move on their own and set up territories (Sandercock 1991). At this stage, the fish are termed parr. The most productive parr habitats are found in smaller streams with low-gradient alluvial channels containing abundant pools, cover created by overhanging vegetation, large woody debris and large boulders. Parr displaced due to competition or the lack of suitable rearing habitat may migrate along the shore in low salinity water before entering other streams to rear (Levings et al. 1995; Levy and Northcote 1982). Coho salmon smolts begin to migrate to the ocean one year or more after

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6.7.3.6.4 Diet No coho salmon parr captured in 2010 were sacrificed for stomach content analysis. However, coho salmon parr rearing in freshwater systems are known to feed on aquatic and terrestrial insects, plankton and occasionally on small fish (Healy 1982; Sandercock 1991; McPhail 2007).

6.7.3.6.5 Habitat The description of coho salmon habitat in Lime Creek is restricted to the lower two reaches of Lime Creek (Reach 1 and 2), downstream of the first cascade impediment to upstream fish passage where coho salmon parr were found in 2010.

Habitat in Reach 1 of Lime Creek was entirely riffle habitat with small (65 to 128 mm diameter), angular cobbles and large gravel (16 to 64 mm diameter) substrates. Average gradient in this reach was <1% and the mean bankfull and wetted width were approximately 32 m and 10 m, respectively. Instream cover was limited to occasional boulders mid-stream or along the stream banks. Banks were largely rip-rap boulders placed during creek straightening in the 1970s. Riparian vegetation above these rip-rapped banks was predominantly willows and alder. It is unknown how many channels were present and how wide they were in this lower reach before it was straightened.

Habitat in Reach 2 was more diverse than in Reach 1 and included riffle, cascade, glide, and pool habitat. Average gradient increased from <1% in Reach 1 to approximately 1.4% for the entire reach, but local gradients varied widely in the different habitat types. Most of the habitat in Reach 2 was riffle (39%) or cascade (32%) habitat with large (65 to 256 mm diameter) cobble substrates. There were numerous angular boulders (>256 mm diameter) throughout these habitats which provided coho salmon parr with refuge from high water velocities and were sediment traps for sand in behind them.

Immediately below the cascade is a large (220 m2), deep (>3 m) pool created by the scour from the upstream cascade. This pool lies between a vertical bedrock bank on one side and a sloping bedrock bank on the other. Substrates in the bottom of this pool were comprised of small cobbles and large gravels while the pool tail-out was almost entirely comprised of smooth, small cobbles and gravels.

6.7.3.7 Cultural Ecological or Community Knowledge

6.7.3.7.1 Nisga’a Nation The Kitsault Project is within the Nass Area and the Nass Wildlife Area (NWA) as defined by the Nisga’a Final Agreement (NFA). The Nisga’a Nation has a right to harvest fish within the Nass Area for domestic, ceremonial, and cultural purposes within limits of conservation, health, and safety measures. The Nisga’a Nation has a salmon and steelhead entitlement

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The NLG coordinate jointly with DFO a fish management program to ensure the viability and sustainability of the Nass fishery resources. Salmon species and steelheads are tagged at various Nisga’a fish wheels for purposes of monitoring and management. Coho and Chinook stocks in the Nass Area remain healthy (NLG 2010). Additional information on Nisga’a fish rights and management are provided in Part C (Sections 13) of the Kitsault EA Application.

Schedule D of Chapter 9 in the NFA designates rivers for Nisga’a guide angling activities. Salmon species, as well as halibut and steelhead are the principle target fish species for guides and their clients. Coho salmon in two of the 15 designated rivers proximate to the mine site are important to the Nisga’a Nation because of guiding entitlements in the NFA. These rivers include the Kitsault River and the Illiance River.

6.7.3.7.2 Aboriginal Groups There are five potentially affected Aboriginal groups that have interests in harvesting and managing coho salmon, including Metlakatla First Nation, Kitsumkalum First Nation, Kitselas First Nation, Gitanyow Hereditary Chiefs and Gitxsan Chiefs. Metlakatla First Nation has an asserted territory that overlaps with the Kitsault mine site; whereas the other four Aboriginal groups overlap with the Kitsault transportation route, including Highway 37, Highway 113, and Nass Forest Service Road (FSR). Desk-based research of publicly available sources indicates the following specific Aboriginal interests related to coho salmon:

 Metlakatla First Nation: Salmon played and continues to play an important part of Metlakatla economy, culture, history, and traditional activities. It is an important food source, and historically prevented famine among Metlakatla members, especially during winter months.  Kitselas First Nation has interests in fishing for Coho salmon, which is important for subsistence, economic, and cultural purposes. Salmon have long been, and continue to be, a dietary staple for the Kitselas, who use the Skeena River and its tributaries for fishing.  Kitsumkalum First Nation has interests in fishing for Coho salmon. Kitsumkalum members fish for salmon as an important source of food.  Gitanyow Hereditary Chiefs have expressed interest in managing and preserving Coho salmon stocks, especially in the upper Kitwanga River where Beaver dams block access to Coho. In the Kispiox-Cranberry Landscape Unit Plan, Gitanyow have proposed trapping measures to control beaver populations to reduce the adverse effects of beaver on Coho salmon migrations. Members of wilp Watakhayetsxw also fish for Coho and pink salmon in the canyon of the Cranberry River, which proximate to the Kitsault transportation route. The Gitanyow indicate

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that the Cranberry has important salmon spawning and rearing habitat. Salmon habitat is especially important to Gitanyow, because they rely on salmon and other fish species for sustenance and culture purposes. In 2010, the Gitanyow Fisheries Authority caught 13,622 Coho smolts along the Kitwanga fish fence.  Gitxsan Chiefs have an interest in preserving the Coho salmon run along the Skeena River and its tributaries. Coho salmon were harvested and processed by Gitxsan in proximity to spawning grounds.

6.7.3.8 Past, Present or Future Projects / Activities

Tables 6.7.3-1, 6.7.3-2 and 6.7.3-3 below present a review of the historical land use, present land use and reasonably foreseeable projects, respectively, which have been identified within the coho salmon CESA. This information was used to develop the final Project Inclusion List for the cumulative effects assessment (CEA). These past, present, and reasonably foreseeable land use activities have been identified within the cumulative effects study area for coho salmon have the potential to overlap spatially or temporally with potential residual effects to coho salmon from the Kitsault Project. Potential cumulative effects of these other projects and activities outside of the immediate Lime Creek area are largely facilitated by the migratory behaviour of coho salmon once they reach the ocean.

Table 6.7.3-1: Historical Land Use Activities in Biophysical Cumulative Effects Assessment Study Area

Project / Activity Description

Kitsault Mine and exploration Exploration, which appears to have begun in the area in 1911, identified the presence of an orebody in late 1964. The mine was owned by B.C. Molybdenum, a subsidiary of KEL from 1963 to 1972 and by Climax Molybdenum Company of British Columbia (CMC) and affiliates from 1973 to 1998. Between January 1968 and April 1972, approximately 9.3 million tonnes of ore were produced with about 22.9 million pounds of molybdenum recovered. CMC returned the mine to production in 1981 but production was terminated again because of low metal prices in 1982. Kitsault Townsite The Kitsault Townsite, built in the 1970s and opened in 1981 to support the Kitsault Mine, was occupied for less than two years. The Kitsault Townsite, which is located approximately 5 km from the proposed Project, was purchased by Kitsault Resort Ltd. in 2005 and has been, and continues to be, maintained by caretakers. Alice Arm Townsite Booming mining town in the 1920s and 1930s until the nearby silver mine shut down. In the 1960s, workers commuted by boat from Alice Arm to work the neighbouring mines. Townsite continues to be occupied year-round and includes a sport fishing lodge and homes used by seasonal residents.

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Project / Activity Description

Illy Mine Operated from 1919-1923. High grade silver-lead-zinc mine located along the west bank of the Illiance River, located approximately 16 km northeast of Alice Arm upstream of impassable barrier in Illiance River location approximately 1.6 km upstream of Alice Arm. Macy Mine Macy Mine operated from 1916-1920. Silica mine located less than 10 km south of Alice Arm. Tidewater Mine Operated from 1916-1931. Molybdenum, silver, gold, lead, zinc, copper mine located approximately 3 km east of Alice Arm Esperanza Mine Operated from 1911-1948. High grade silver ore with associated gold, copper and lead located approximately 1 km north of Alice Arm. Wolf Mine Operated sporadically from 1925-1953. High grade gold- silver-copper-lead-zinc located approximately 400 m north-northwest of the centre of Alice Arm. Dolly Varden Mine Located approximately 0.3 km west of the Kitsault River, 22.5 km north of Alice Arm. The mine produced high- grade silver ore periodically between 1919 and 1940. One glory hole, is located 300 m west of the Kitsault River, 22.5 kilometres north of Alice Arm. La Rose Mine Located on the east flank of Tsimstol Mountain west of the Kitsault River, approximately 9.75 km north-northwest of Alice Arm. A few small shipments of high grade ore were made from this deposit between 1918 and 1927. North Star Adit portal is located on the west bank of the Kitsault River, 23 km north of the town of Alice Arm. Between 1919 and 1921 a small tonnage of silver ore was mined from this deposit. Torbrit Located on the east bank of the Kitsault River, approximately 23.5 km north of the town of Alice Arm. Between 1949 and 1959 Torbrit Silver Mines Ltd. produced 1,249,942 tonnes of ore containing silver, lead, zinc and gold. Past mine exploration Tiger - The Tiger vein occurs 0.4 kilometres east of the Kitsault River, 24 km due north of the town of Alice Arm. This prospect has been extensively explored since 1916 for silver. Kitsol - Located on the west bank of the Kitsault River, 24 kilometres north of Alice Arm. The South Musketeer (103P 019), probably an extension of the Kitsol, lies just across the river on the east bank. The Kitsol prospect was extensively explored by Dolly Varden Mines in the early 1970s. Wolf - Lowermost portal, on the east side of the Kitsault River, 25.5 km north of the town of Alice Arm. Extensive diamond drilling and underground development between 1960 and 1980 by various operators has defined moderate

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Project / Activity Description sized reserves of low grade silver-lead-zinc ore. Moose-climax - The Moose-Climax occurrence is situated 0.5 km east of the Kitsault River, 26.5 km north of the town of Alice Arm. This vein has been extensively explored since 1916 for its silver- lead-zinc mineralisation. Victory - Adit portal, 1.25 km east of the Kitsault River, 27.5 km north of the town of Alice Arm. Drilling between 1963 and 1975 has outlined moderate sized reserves of ore for this silver-bearing vein. Robin - Located along Blue Bird Creek in the Upper Kitsault Valley, 28.5 km north of the town of Alice Arm. Zones containing argentiferous galena have been extensively explored by trenching and diamond drilling since 1918. Vangaurd Copper - located 500 m southwest of Homestake Creek in the Upper Kitsault Valley, about 29 km north of Alice Arm. A zone of copper mineralisation has been extensively investigated, since 1916, by trenching and tunnelling. Sault - Located just south of Kitsault Lake, approximately 30.5 km north of Alice Arm. This zinc showing has been extensively investigated since its discovery in 1966. Note: B.C. - British Columbia; CMC - Climax Molybdenum Company of British Columbia; KEL - Kennco Exploration (Western) Ltd.

The only historical land use with potential to cumulatively affect coho salmon is the past mining activities at the Kitsault Mine site. During the first mining operation, between 8 and 11 million tonnes of mine tailings were deposited directly into Lime Creek between 1963 and 1972. During the second mining operation, waste rock dumps were adjacent to Patsy Creek and in the upper headwaters of the Patsy Creek watershed. While the high discharge and energy of Lime Creek has likely removed all of these tailings from Lime Creek and deposited them in Alice Arm, any residual effects of this past deposition and any residual effects of the former waste rock dump is reflected in the baseline characterisation of the Lime Creek coho salmon presented in the Appendix 6.7-A and summarised in Section 6.7.3.6 above.

Construction of the Kitsault Townsite required the armouring and channelising of the lower 260 metres of Lime Creek. This effectively replaced the braided natural channels of the creek delta with a single, straight channel. While the effects of this habitat alteration on coho salmon are unknown, baseline characterisation of the coho rearing habitat summarised in Section 6.7.3.6 above is assumed to reflect any past residual effects of this channelisation on coho salmon.

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The town of Alice Arm and past mining operations and past mining exploration activities in the Alice Arm area are not expected to have a potential cumulative effect on coho salmon. This is because once any coho salmon parr leaves Lime Creek, they would be expected to remain in the ocean, likely leaving the Alice Arm and Observatory Inlet area for Hecate Straight, and would not travel up any other river or stream where these past mining projects were located.

Table 6.7.3-2: Present Land Use Activities in Biophysical Cumulative Effects Assessment Study Area

Project / Activity Description

Transportation and access Within the CESA, Highways 113 and 37 are used by local residents and tourists as well as commercial / industrial traffic associated with activities such as exploration. The Nass Forest Service Road (FSR) and Alice Arm Road currently provides access to the Kitsault exploration camp and reclamation area, and access to the town of Kitsault and Alice Arm. Mining exploration Mining exploration activities are ongoing in the CESA. These include exploration of the Bell Moly and Roundy Creek Molybdenum deposits by the proponent and exploration of the Big Bulk, Clone, and Homestake Ridge deposits. A number of private claims are surrounded by the proponent’s Kitsault mineral tenure area. Trapping and guide outfitting The proposed Project footprint falls within one trap line tenure area that is routinely used in the winter. The eastern section of the access road leading from Highway 37 falls within another trap line tenure area. The Land Use RSA (and Wildlife RSA) falls within the boundaries of one Guide Outfitter. Nisga’a Nation hunting, trapping, Nisga’a Nation has guiding entitlements in the Kitsault and fishing, and other uses Illiance Rivers under the Nisga’a Final Agreement Aboriginal hunting, trapping, fishing and other uses Note: CESA - Cumulative Effects Study Area; FSR - Forest Service Road; RSA - Regional Study Area

Highway 37, the Nass FSR, and the Alice Arm Road currently provide access to streams known to support coho salmon, including Lime Creek where the Kitsault Project is located. However, since Lime Creek does not support an adult coho population and since none of these roads would be upgraded and no new roads would be built for the Kitsault Project that would increase access streams, no potential cumulative interaction between existing transportation and access with the Kitsault Project exists (Table 6.7.3-4).

Exploration in the Bell Moly deposit in the Clary Creek watershed and exploration of the Roundy Creek deposit in the Roundy Creek watershed also do not have the potential create cumulative effects on coho salmon. The rationale for this decision is the same as that for

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There is a potential cumulative effect between any residual effects of the Kitsault Project on coho salmon and trapping or guide outfitting, non-guided recreational fishing, and traditional and subsistence fishing by the Nisga’a Nation. This is because the coho salmon parr in lower Lime Creek are likely to be progeny of one of the coho salmon runs in the Alice Arm area (e.g., Kitsault River or Illiance River) where recreational fishermen, fishermen guided by Nisga’a guides, and Nisga’a peoples themselves are likely to harvest adult coho salmon returning to these rivers to spawn (Table 6.7.3-4).

Table 6.7.3-3: Reasonably Foreseeable Projects in Biophysical Cumulative Effects Assessment Study Area

Project/Activity Construction Operation Area and Rationale Northwest Spring 2011 - Unknown – with routine The Northwest transmission line is a Transmission Line 2013 maintenance it would 287 KV 335 km transmission line Project operate into the between the Skeena substation (near foreseeable future Terrace) and Bob Quinn Lake.

There are no potential interaction to coho salmon from residual effects from the Northwest Transmission Line Project and residual effects from the Kitsault Project. This is because the Northwest Transmission Line Project does not cross any watersheds draining into Alice Arm.

Table 6.7.3-4 summarises potential interactions between coho salmon and historic, present, and reasonably foreseeable land use activities.

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Table 6.7.3-4 Assessment of Linkages Between Other Projects,

Reasonably Representative Current and Future Land Salmon Historical Land Use Foreseeable Use Projects

Freshwater Aquatic Resources VC Human Activities and Reasonable Foreseeable Projects with Coho a’a Nation a’a Nation Kitsault Mine and exploration Townsite Kitsault (on-going) Alice Arm (on- townsite going) Previous mine operations Previous mine exploration Transportation and access Mining exploration Trapping and guide outfitting Nisg hunting, trapping, hunting, trapping, other fishing and uses Aboriginal hunting, fishing, uses and other Northwest Transmission Line Project Coho salmon - - NI NI NI NI NI o o o NI Note: Interaction definitions: o - interaction; - - key interaction; + - benefit; NI - no interaction

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6.7.3.9 Potential Effects of the Proposed Project and Proposed Mitigation

This section presents the likelihood that different Project components and activities would have a direct, indirect, or combined effect on coho salmon during the construction, operations, closure / decommissioning and post-closure phases of the Kitsault Project. It does so by:

 Identifying each potential direct, indirect, and combined effect that may occur to coho salmon during each phase of the Project;  Identifying any direct, indirect, or combined effects on coho salmon that may indirectly effect other Valued Components (e.g., human health), including other Freshwater Aquatic Resource VCs;  Identifying any potential direct, indirect, or combined effects on coho salmon that are eliminated through mitigation measures included in the Project water management and environmental management plans; these potential effects are not carried forward in the assessment; and  Identifying and rating the likelihood of mitigation measures to reduce or eliminate potential direct, indirect, or combined effects on coho salmon; only potential effects where mitigation measures are not determined to complete break the linkage between the Project component or activity and coho salmon were carried forward into the assessment of residual effects.

Those direct, indirect, and combined effects carried forward in the residual effects assessment were presented and rated for their significance to the health, growth, survival, and / or recruitment of coho salmon in Section 6.7.3-106.

6.7.3.9.1 Identification and Analysis of Potential Project Effects 6.7.3.9.1.1 Potential Direct Effects on Coho Salmon For the purposes of this assessment, direct effects to coho salmon were considered to occur from those Project components or activities that would result in the direct mortality of individual coho salmon or the direct loss of their habitat in lower Lime Creek. Based on this definition, there is only one potential direct effect of the Kitsault Project on coho salmon. This is the potential mortality of coho salmon parr do to blasting in the Kitsault Pit (Table 6.7.3-5). No direct effect to coho salmon due to increased fishing pressure created by the presence of the Kitsault mine work-force would occur because no adult coho salmon are present in Lime Creek.

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Table 6.7.3-5: Potential Direct Project Effects on Coho Salmon

Project Likelihood of Project Phase Potential Direct Project Effect Component Occurrence Blasting Construction, operations Potential increase in fish mortality Unlikely due to sound overpressures and increased particle velocities

The use of explosives has the potential to impact fish. The detonation of explosives produces post-detonation compressive shock waves characterised by a rapid rise to a high peak pressure followed by a rapid decay to below ambient hydrostatic pressure (Wright and Hopky 1998). Overpressures greater than 100 kPa can result in rupture of internal organs of fish, particularly the swim-bladder, and the rupture of fish eggs (Wright 1982).

The likelihood of potential direct effects of blasting on coho salmon during construction and operations in the Kitsault Pit is negligible and is not carried forward in this assessment (Table 6.7.3-5). This is because the distance between the Kitsault Pit where the blasting would occur and the habitat used by coho salmon in the lower Lime Creek is at least two orders of magnitude greater than the setback distance guideline for the protection of fish from overpressure changes due to detonation of a 100 Kg charge in solid rock (50.3 metres) as outlined in the “Guidelines for the Use of Explosives in or near Canadian Fisheries Waters” (Wright and Hopky 1998).

The Kitsault Pit is located in the lower Patsy Creek watershed. In this location, the Kitsault Pit is approximately six kilometres upstream from the impassable waterfall in Lime Creek and another 1.5 kilometres from the cascade below which coho salmon parr were found (for a total of at least 7.5 kilometres from habitat inhabited by coho salmon parr).

6.7.3.9.1.2 Potential Indirect Effects on Coho Salmon For the purposes of this assessment, indirect effects to coho salmon were considered to occur from those Project components or activities that had the potential to indirectly affect the health, growth or survival of coho salmon through direct Project effects to other VCs. The primary VCs through which indirect effects to coho salmon could occur are changes in surface water quality and hydrology (i.e., stream flows).

Indirect effects to coho salmon due to changes in surface water quality included effects from mine effluent discharge and seepage, changes in groundwater quality or quantity, and changes in air quality (e.g., dust deposition and contaminants from burning of fossil fuels). Indirect effects to coho salmon due to changes in hydrology included effects from changes in upstream catchment areas, diversion of streams, capture of run-off for use during operations or closure of the mine, and annual release of excess accumulated run-off.

Other potential indirect effects to coho salmon are also possible from direct Project effects on air quality, riparian vegetation, and wildlife (both those upon which coho salmon are known to feed and those whom are known to feed on coho salmon). All potential indirect

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Table 6.7.3-6 Potential Indirect Project Effects on Coho Salmon

Project Likelihood of Project Component Potential Indirect Effect Phase Occurrence Land clearing, top-soil stripping, C Potential increase in Likely and grading of land for mine suspended solids in Lime infrastructure installations, ore Creek decreases growth and stockpiles, and waste rock survival of coho salmon management facilities (WRMFs) Soil and till salvage, handling and C, O Potential increase in Likely storage, including locations, suspended solids in Lime volumes and impacted areas Creek decreases growth and survival of coho salmon Emissions and dust generation C,O, Potential increase in Unlikely (fugitive emissions, equipment D/C, PC suspended solids in Lime operation and movement) Creek decrease growth and survival of coho salmon Mine infrastructure installations C Potential increase in Unlikely including processing plant, camp, suspended solids in Lime equipment washing facility, and Creek decrease growth and primary crusher, conveyor survival of coho salmon systems, and pipelines Pre-stripping of Kitsault Pit C Potential increase in Likely suspended solids and blasting residues in Lime Creek; potential decrease growth and survival of coho salmon Development of south C, O Potential increase in Likely embankment of Tailings suspended solids and potential Management Facility (TMF) decrease in stream flow in development Lime Creek; potential decrease in growth and survival of coho salmon Development of south water C Potential increase in Likely management pond suspended solids and potential decrease in discharge in Lime Creek; potential decrease in growth and survival of coho salmon Coffer dams, sumps, pump C, O, Potential increase in Likely systems, and diversion ditches D/C suspended solids in Lime Creek; potential decrease in growth and survival of coho salmon

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Project Likelihood of Project Component Potential Indirect Effect Phase Occurrence Water management including C, O, Potential change in water Likely dewatering, diversions, and D/C temperature and discharge in downstream discharges Lime Creek; potential decrease in growth and survival of coho salmon Waste-water and sewage C, O, Potential change in water Likely management D/C quality of Lime Creek; potential decrease in growth and survival of coho salmon East WRMF development and O, D/C Potential change in water Likely reclamation quality, water temperature, and discharge of Lime Creek; potential decrease in growth and survival of coho salmon TMF development and O, D/C, Potential change in water Likely reclamation PC quality, water temperature, and discharge of Lime Creek; potential decrease in growth and survival of coho salmon TMF seepage management and O, D/C, Potential change in water Likely reclamation PC quality of Lime Creek; potential decrease in growth and survival of coho salmon Ore stockpiles development and O, D/C Potential change in water Likely reclamation quality of Lime Creek; potential decrease in growth, and survival of coho salmon Surface water management and O, D/C, Potential change in water Likely diversion systems PC quality and discharge of Lime Creek; potential decrease in growth and survival of coho salmon Groundwater management O, D/C, Potential change in water Likely PC quality, water temperature, and discharge of Lime Creek; potential decrease in growth and survival of coho salmon Pit dewatering O Potential change in water Likely quality of Lime Creek; potential decrease in growth and survival of coho salmon Storm-water run-off measures O Potential change in suspended Likely sediments and discharge of Lime Creek; potential decrease in growth and survival of coho salmon

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Project Likelihood of Project Component Potential Indirect Effect Phase Occurrence TMF surplus and contact water O, D/C, Potential change in water Likely discharge (including blasting PC quality and water temperature residues) of Lime Creek; potential decrease in growth and survival of coho salmon Metal Leaching and Acid Rock D/C, PC Potential change in water Likely Drainage (ML/ARD) management quality of Lime Creek; potential decrease in growth and survival of coho salmon Decommissioning and removal of D/C Potential increase in Likely all processing facilities, suspended solids in Lime infrastructure, and ancillary Creek; potential decrease in facilities growth and survival of coho salmon Kitsault Pit reclamation including D/C, PC Potential change in water Likely Kitsault Pit re-filling and over-flow quality, water temperature and discharge of Lime Creek; potential decrease in growth and survival of coho salmon Surface water and groundwater D/C, PC Potential change in water Likely management quality, water temperature, and discharge of Lime Creek; potential decrease in growth and survival of coho salmon Note: C - construction; D/C - decommissioning and closure; ML/ARD - metal leaching and acid rock drainage; O - operations; TMF - Tailing Management Facility; PC - post-closure; WRMF - Waste Rock Management Facility

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Without mitigation, the only mine components or activities during construction, operation, closure / decommissioning phases unlikely to result in indirect, adverse effects on coho salmon in Lime Creek were: 1) emission and dust generation (during all phases of the Project); and 2) installation of mine infrastructure during the construction phase. These two mine activities are not carried forward in this assessment. The rationale for not carrying the potential effects of these two activities forward into the coho salmon assessment is provided below.

6.7.3.9.1.2.1 Emissions and Dust Generation Emissions from burning of fossil fuels in trucks, shovels, and generators and dust generated from blasting, drilling, loading trucks, and driving machinery on mine roads would not affect coho salmon for two reasons. First, emissions such as SOx and NOx, which have the potential to create acidic conditions in freshwater, would not accumulate in Lime Creek. Lime Creek is a fast flowing stream and it would not have a headwater lake after construction (i.e., Patsy Lake would be covered by the TMF). Instead, any of these emissions falling onto the Lime Creek watershed would be quickly carried downstream to Alice Arm before having the opportunity to accumulate. Second, the sources of dust and emissions would all be located in the Patsy Creek watershed far above lower Lime Creek where coho salmon are found. It is highly unlikely that any of these emissions or dust would be deposited this far downstream, especially in the wet climate on the north coast of BC.

Mitigation measures such as the use of low sulphur diesel fuel, regular maintenance of machinery, using a dust collection system during bulk materials loading and unloading, regular dust suppression on mine roads, and maintaining the operational supernatant pond in the TMF to ensure that tailings beaches are saturated (see 6.2, Air Quality) would all further reduce the likelihood of these effects on coho salmon.

6.7.3.9.1.2.2 Installation of Mine Infrastructure Installation of the mine infrastructure was considered unlikely to adversely affect coho salmon in Lime Creek because it was assumed that this activity would involve physical disruption of land in the upper Lime Creek watershed. Instead, this activity was assumed to involve only the placement or removal of buildings, pipelines, and conveyors on the land. Clearing, excavating, or grading of the land prior to installation or removal of these infrastructure components was assumed to be the activity with the potential to impact coho salmon through changes in surface water quality due to potential increased suspended sediment loading. This activity was carried forward in the assessment but installation of mine infrastructure was not.

6.7.3.9.1.2.3 All Other Project Components and Activities That Could Indirectly Affect Coho Salmon Through Changes to Surface Water Quality and Stream Flows in Lime Creek Besides emissions and dust generation, and installation and decommissioning of mine infrastructure, all other mine components and activities during construction, operations, closure / decommissioning phases of the Project were carried forward in this assessment.

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This was because, unmitigated, all of these other mine components and activities had the potential to indirectly affect coho salmon through:

 Direct changes to surface water quality in Lime Creek;  Direct changes to stream flow in Lime Creek;  Direct changes to water temperatures in Lime Creek; or  Direct changes to both surface water quality, water temperatures, and stream flow in Lime Creek.

Although these components and activities were carried forward into the effects assessment, this does not imply that these mine components or activities would necessarily cause an adverse effect to coho salmon. It only implies that, without mitigation, these mine component and activities have the potential to adversely affect coho salmon. The likely effectiveness of the various mitigation measures available to minimise or eliminate these potential effects on coho salmon were assessed in Section 6.7.3.9. The significance of any residual effects to coho salmon was assessed in Section 6.7.3.10.1.

6.7.3.9.1.3 Potential Combined Effects Potential combined effects to coho salmon were considered to be those indirect effects that would occur simultaneously or through time in the same waterbody or stream to potentially change the growth, survival, and / or health of coho salmon in Lime Creek. Table 6.7.3-7 summarises the potential combined effects on coho salmon due to potential indirect Project effects to surface water quality, stream flow, and water temperatures in Lime Creek, and the potential change in the benthic macro-invertebrate community which may result. The abundance of coho salmon parr in Lime Creek may be reduced through all of these potential effects.

Any change in the benthic macro-invertebrate community in Lime Creek has the potential to directly affect coho salmon because they are their primary food source. Such a change in prey would create the potential for a combined effect on coho salmon health, growth and survival with concurrent effects on coho salmon due to changes in water quality, stream flow and water temperature. Any change in the benthic macro-invertebrate community would be expected to occur soon after (i.e., within weeks and months) these physical and chemical changes in the Lime Creek occurred. Benthic macro-invertebrates are better indicators of stressors in the aquatic environment than fish and, therefore, any effects on benthic macro- invertebrate due to changes in water quality, stream flows, and water temperatures would likely occur well within the stream residency period of coho salmon parr in Lime Creek (i.e., 1 to 2 years).

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Table 6.7.3-7: Potential Combined Project Effects by Project Phase on Coho Salmon

Potential Indirect Project Likelihood of Potential Combined Project Effect Project Effect Phase Occurrence Change in surface Change in coho salmon health, growth and C, O, Likely water quality in Lime survival in Lime Creek due to combined D/C, PC Creek effect with potential changes in stream flow, water temperatures, and resulting change in their benthic macro-invertebrate prey Change in stream flow Change in coho salmon health, growth and C, O, Likely in Lime Creek survival in Lime Creek due to combined D/C, PC effect with potential changes in surface water quality, water temperatures, and resulting change in their benthic macro-invertebrate prey Change in water Change in coho salmon health, growth and C, O, Likely temperature in Lime survival in Lime Creek due to combined D/C, PC Creek effect with potential changes in stream flow, and resulting change in their benthic macro- invertebrate prey Change in benthic Change in coho salmon health, growth and C, O, Likely macro-invertebrate survival in Lime Creek due to combined D/C, PC community in Lime effect with potential changes in surface water Creek quality, stream flow, and water temperatures Project Phase: C - construction; D/C - decommissioning and closure; O - operations; PC - post-closure

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6.7.3.9.1.4 Potential Indirect Effects on Other Valued Components Potential direct, indirect, or combined effects on coho salmon have the potential to indirectly affect other Valued Components (Table 6.7.3-8). These include potential indirect effects on piscivorous wildlife (e.g., herons, crows, mink) that feed on coho salmon parr, and on other Freshwater Aquatic Resource VCs (e.g., Dolly Varden and benthic macro-invertebrates) that co-exist with coho salmon in Lime Creek. The potential effects identified in Table 6.7.3-8 represent those that could occur without considering the likely effectiveness of mitigation measures to reduce or eliminate them.

There is no potential interaction between potential changes in coho salmon health, growth or survival with any other biophysical VC other than those identified and rationalised in Table 6.7.3-8. All other biophysical VCs (e.g., air quality, hydrogeology, soil and vegetation) have the potential to interact indirectly with coho salmon through changes in surface water quality and hydrology but the reverse linkage from coho salmon to these other VCs is not valid (e.g., changes in coho salmon health, growth, and survival cannot affect air quality).

There is no potential interaction between potential changes in coho salmon health, growth or survival and any socio-economic VCs. This is because, while coho salmon are an economically valuable sport or commercial fish species in the Alice Arm area, the number of coho salmon parr likely to be rearing in lower Lime Creek are too small to have an effect on the recreational, commercial or subsistence fisheries in the Alice Arm / Observatory Inlet area for coho salmon. Lime Creek is not the natal stream for the coho salmon parr present in the stream and, as a result, any potential indirect Project effect on these coho salmon parr are unlikely to have an effect on any of these fisheries. For the same reason, no potential effect exists between Project effects on coho salmon and marine biota (e.g., seals, orcas). A summary of the potential interactions between potential direct, indirect, and combined effects of the Project on coho salmon and other biophysical and socio-economic VCs is provided in Table 6.7.3-9 below.

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Table 6.7.3-8: Potential Indirect Proj

Direct Project, Indirect, or Carried Potential Indirect Project Combined Effect (adverse or Project Phase Forward Rationale Effect positive) (yes / no) Potential change in health, Construction,ect Effects onChange Other Valued in tissue Components metal Yes Elevated tissue metal concentrations in coho growth and survival of coho operations, concentrations and size and salmon may increase despite commitment to salmon due to changes in water decommissioning, abundance of coho salmon meet site-specific water quality objectives quality, water temperature, and post-closure in Lime Creek may affect throughout the mine life. Such increases stream flow in Lime Creek piscivorous fish and wildlife may result in acute and / or chronic toxicity to piscivorous wildlife, especial for those metals known to bioaccumulate in higher trophic levels (e.g., mercury). Reduced size and abundance of coho salmon in Lime Creek may indirectly reduce the health, growth, survival and abundance of piscivorous fish and wildlife that rely on coho salmon parr for all or part of their dietary needs. Change in size and Yes Change in the health, size and abundance of abundance of coho salmon coho salmon has the potential to influence in Lime Creek may affect the size and abundance of Dolly Varden other Freshwater Aquatic which compete with coho salmon for food Resource VCs in Lime and space. Such a change may also Creek (e.g., Dolly Varden influence the density, distribution, and and benthic macro- community composition of benthic macro- invertebrates) invertebrates upon which coho salmon and Dolly Varden and feed. Note: VC - Value Component

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Table 6.7.3-9: Summary of Potential Interaction Between

Direct, Indirect, or Combined Project Effect on Coho Salmon Use Use Social Health Health Habitat Change Change Heritage Heritage Land Use Land Use Resource Resource Economic Economic Terrestrial Terrestrial a’a Nation Land a’a Nation Marine Biota Marine Biota Environment

Project Effects on Coho Salmon and Other Hydrogeology Valued Components Freshwater and Freshwater Sediment Quality Wildlife and Their Wildlife and Aboriginal Groups Aboriginal Groups Surface Hydrology Hydrology Surface Freshwater Aquatic Aquatic Freshwater Noise and Vibration Vibration Noise and Nisg Groundwater Quality Quality Groundwater Marine Water Quality Quality Marine Water Environmental Health Environmental Health Air quality and Climate Climate Air quality and Potential change in health, growth, survival, recruitment, and abundance of coho NI NI NI NI NI NI o NI NI NI o o NI NI NI NI NI NI salmon in Lime Creek Note: Interaction definitions: o - interaction; - - key interaction; + - benefit; NI - no interaction n/a - not applicable; VC - Valued Component

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6.7.3.9.1.5 Potential Project Effects Carried Forward for Assessment A summary of the potential indirect Project effects on coho salmon that were carried forward into the assessment is presented in Table 6.7.3-10. These include:

 All Project components and activities that, combined, have the potential to indirectly affect coho salmon by altering surface water quality in Lime Creek;  All Project components and activities that, combined, have the potential to indirectly affect coho salmon by altering stream flows in Lime Creek;  All Project components and activities that, combined, have the potential to indirectly affect coho salmon by altering water temperatures in Lime Creek; and  All Project components and activities that, combined, have the potential to indirectly affect coho salmon by altering the benthic macro-invertebrate community in Lime Creek.

Effects on coho salmon due to potential changes in surface water quality were assessed based on results from a surface water quality model that predicted metal, ion, cation, and nutrient concentrations in Lime Creek downstream of the waterfalls. Similarly, effects on coho salmon due to potential changes in stream flows were assessed based on results of a watershed model that predicted annual, monthly, peak instantaneous, and 7-day low flows at the same location. Both models incorporated all of the various mine activities and components that could potentially affect surface water quality and stream flow in Lime Creek during each phase of the Project (i.e., all activities, components, and mitigation measures included in the Project water management plan). Thus, the assessment of potential changes in surface water quality and stream flow on coho salmon were based on the likelihood that predicted changes in water quality parameters and predicted changes in stream flow in lower Lime Creek would adversely affect coho salmon at specific points in time during the development of the Kitsault Project and not on the likelihood that any individual mine component or activity would adversely affect coho salmon in Lime Creek.

Because neither model explicitly linked any single mine component or activity to a predicted change in water quality or stream flow during any phase of the Project (e.g., increase in watershed area and re-filling of the Kitsault Pit during closure), neither could the explicit indirect effects of any single mine component or activity be linked to coho salmon. This reality did not limit the credibility or accuracy of the assessment on coho salmon but it did limit the ability of the assessment to explicitly identify which mine component or activity was most likely to the cause the predicted change in water quality or stream flow, and hence effect on coho salmon.

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Table 6.7.3-10: Summary of Potential Project Effects to be Carried Forward Into the Assessment for Coho Salmon

Adverse Effects / Positive Effects Project Phase Direction Potential change in surface water quality in Lime Creek C, O, D/C, PC Negative Potential change in hydrology in Lime Creek C, O, D/C, PC Negative Potential change in water temperature in Lime Creek C, O, D/C, PC Negative Potential change in benthic macro-invertebrate community in Lime Creek C, O, D/C, PC Negative Note: C - construction; D/C - decommissioning and closure; O - operations; PC - post-closure

6.7.3.9.2 Mitigation Measures Mitigation measures to reduce or eliminate each of the potential indirect and combined effects of the Project on coho salmon in Lime Creek are the same as those described to mitigate potential indirect and combined effects on Dolly Varden in Lime Creek. For brevity, the specific mitigation measures included in the water management plan and the environmental management plan that would be implemented to reduce the potential indirect effects of specific Project components and activities on coho salmon during each phase of the Project are not repeated in this section of the EA. The reader is referred to the appropriate mitigation sections of the Dolly Varden effects assessment (Section 6.7.2.9.2) in the sections below.

6.7.3.9.2.1 Changes in Surface Water Quality in Lime Creek Potential changes in surface water quality in Lime Creek may occur during all phases of the Kitsault Project (Table 6.7-3-6). The primary mitigations measures to eliminate or minimise these potential changes in Lime Creek surface water quality include: 1) implementation of the mine’s Water Management Plan; and 2) the construction and operation of a water treatment facility during the post-closure phase, if required. The water management plan is presented in detail in Appendix 6.4-B Details of the proposed water treatment facility are described in the Section 6.6.2.6.2.2 of the Surface Water Quality assessment.

Specific mitigation measures included in the water management plan that would be implemented to reduce the potential indirect effects to coho salmon due to potential changes in surface water quality in Lime Creek during each phase of the Project are described in the discussion and tables presented in Section 6.7.2.9.2.2 of the Dolly Varden effects assessment.

6.7.3.9.2.1.1 Surface Water Quality Model Results The likely effectiveness of the water management plan, the environmental management plan and the water treatment plant at post-closure (if required) to eliminate or reduce potential changes to surface water quality, and hence to reduce potential effects to coho salmon parr in Lime Creek, was determined by comparing surface water quality concentrations in lower Lime Creek predicted from a mass balance mixing model to provincial and federal water quality guidelines for the protection of aquatic life. Details of the

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KITSAULT MINE PROJECT ENVIRONMENTAL ASSESSMENT FRESHWATER AQUATIC RESOURCES mass balance mixing model are provided in Appendix 6.6-B of the Surface Water Quality assessment. In brief, this model incorporated, at all phases of the Project:

 Baseline surface water quality and groundwater quality source terms;  All predicted contaminant loading concentrations from all potential sources (e.g., Waste Rock Facilities, ore stockpiles, TMF, exposed Kitsault Pit surface) (SRK 2011);  All elements of the site water balance (Knight Piésold Appendix 6.4-A);  All potential changes to natural catchment areas and stream discharges; and  All water management plan mitigation measures list above.

While the model output included water quality predictions at four locations in the Lime Creek watershed, only water quality predictions in lower Lime Creek were relevant to the assessment of potential effects on coho salmon parr as these fish are only present in the lower 260 metres of the creek.

Guidelines and standards for comparison with the model output at the lower Lime Creek output node were as follows:

 BC MOE water quality guidelines (approved) for the protection of Fresh Water Aquatic Life (BC MOE 2006a, 2006b): o The Maximum Acceptable limits (Max); and o The 30 Day Average limits (30 Day Average);  BC MOE ambient aquatic life guideline for iron (BC MOE 2008);  BC MOE Water Quality Guidelines for Nitrogen (Nitrate, Nitrite, Ammonia)(BC MOE 2009); and  CCME (2007) guideline for the protection of aquatic life (freshwater).

Table 6.7.3-11 summarises these provincial and federal guidelines. Where specific guidelines are dependent on other water quality parameters (e.g., hardness, pH, temperature), guideline values for lower Lime Creek were calculated using equations provided in the relevant guideline and baseline water quality parameters documented during baseline water quality sampling in Lime Creek conducted in 2009 and 2010.

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Table 6.7.3-11: Summary of Provincial and Federal Water Quality Guidelines for the Protection of Freshwater Aquatic Life in Lower Lime Creek

BC Water Quality Guideline Canadian Parameter Environmental Quality 30 day average (mg/L) Maximum (mg/L) Guideline (mg/L) Chloride 150 600 Fluoride 0.3a Sulphate 100 Nitrate (as N) 31.3 13.0 Ammonia (total) 1.8 to 2.05b,c 6.98 to 23.1 b,c Aluminum 0.05b 0.1b 0.1b,g Antimony 0.02 0.005 Arsenic 0.005 0.005 Barium 5.0 Beryllium 0.0053 Boron 1.2 Cadmium 0.000023d 0.000023d Chromium III 0.0089 0.0089 Chromium VI 0.001 0.001 Cobalt 0.004 0.11 Copper 0.002/0.005/0.002/0.004e,f 0.008/0.014/0.073/0.12e,f 0.002/0.003/0.002/0.003e,f Iron (total) 1.0 Iron (dissolved) 0.35 0.3 Lead 0.005/0.008/0.005/0.007e,f 0.042/0.112/0.039/0.087e,f 0.002/0.004/0.002/0.003e,f Mercury 0.00002 0.000026 Molybdenum 1.0 2.0 0.073 Nickel 0.065d 0.065d Selenium 0.002 0.001 Silver 0.00005d 0.001d 0.0001 Thallium 0.0003 0.0008 Uranium 0.3 0.015 Vanadium 0.006 Zinc 0.008/0.036/0.008/0.019e,f 0.033/0.062/0.033/0.044e,f 0.03 Note: a assumed hardness of > 50 mg/L CaCO3; b assumed pH = 7; c assumed mid-winter and mid-summer temperatures of 1°C and 12°C, respectively; d assumed hardness of 65 mg/L CaCO3; e assumed mean hardness during construction, operations, closure, and post-closure of 59, 128, 56, and 105 mg/L CaCO3, respectively; f guideline reported in construction, operations, closure, and post-closure phases, respectively based on average hardness values for each phase; g total aluminum concentration; mg - milligram; L - litre

Based on the BC MoE 30-day average and maximum guidelines (2006, 2008 and 2009) and the CCME (2007) guidelines listed above, the following water quality parameters were predicted to exceed one, two, or all three of the guideline concentrations during the

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KITSAULT MINE PROJECT ENVIRONMENTAL ASSESSMENT FRESHWATER AQUATIC RESOURCES construction, operations, closure, and / or post-closure phases of the Project in lower Lime Creek:

 Fluoride;  Sulphate;  Aluminum;  Cadmium;  Chromium VI;  Copper;  Mercury;  Molybdenum;  Selenium; and  Zinc.

Table 6.7.3-12 summarises which parameter exceeds which provincial and / or federal water quality guideline for the protection of freshwater aquatic biota for each phase of the Project.

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Table 6.7.3-12: Summary of Predicted Exceedences of Provincial and Federal Water Quality Guidelines for the Protection of Fresh

Construction Operations Closure Post-Closure Canadian Canadian BC Canadian BC WQG BC WQG 30 BC WQG Environmental BC WQG 30 BC WQG Environmental WQG Canadian BC WQG Environmental Parameter BC WQG 30 day day average Maximum Quality day average Maximum Quality 30 day Environmental Quality Maximum Quality Maximum (mg/L) average (mg/L) (mg/L) Guideline (mg/L) (mg/L) Guideline average Guideline (mg/L) (mg/L) Guideline (mg/L) (mg/L) (mg/L) (mg/L) (mg/L) Fluoride     Sulphate   Aluminun         Cadmium         Chromium VI         Copper       Lead Mercury     Molybdenum   water Aquatic Life in Lower Lime Creek  Selenium   Zinc    Note: BC WQG - British Columbia Water Quality Guideline; mg - milligram; L - litre

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Each of these guideline exceedences in lower Lime Creek were created because there would be an unavoidable release of mine effluent and / or mine contact water during all phases of the Project. Project design had attempted to minimise the Project footprint and locate all project infrastructure in the Patsy Creek above fish-bearing waters in Lime Creek. In addition, the water management plan had attempted to capture and separate all contact water from non-contact water. However, annual precipitation at the Project site exceeds 2000 mm per year and run-off volumes of this magnitude would cause the mine site water balance to operate with a water surplus in all years except during the closure phase when the Kitsault Pit is re-filling. During mine operations for example, this water surplus was predicted to be on the order of 10 Mm3 of water per year; this excess water necessitates a release of water from the site to Lime Creek.

Predicted surface water quality exceedences of provincial and federal guidelines during all phases of the Project indicates that mitigation measures included in the water management plan are insufficient to eliminate all potential effects to coho salmon parr due to changes in water quality in Lime Creek. For this reason, the potential effects of the predicted changes in surface water quality on coho salmon parr were carried forward to the residual effects assessment section below.

6.7.3.9.2.2 Change in Stream Flows in Lime Creek Potential changes in stream flows in Lime Creek may occur during all phases of the Kitsault Project (Table 6.7-3-6). These potential changes would occur primarily due to: 1) changes to the upstream catchment areas; 2) capture of upstream catchment run-off in the TMF for start-up processing requirements and management of mine tailings; 3) diversion of streams; and 4) filling of the Kitsault Pit at closure.

The primary mitigation measures to eliminate or minimise these potential changes in stream flows in Lime Creek were: 1) implementation of the mine’s Water Management Plan (Appendix 6.4-B); and 2) filling the Kitsault Pit over an extended period instead of filling the pit as quickly as possible (Knight Piésold 2011 Appendix 6.5-C).

Specific mitigation measures included in the water management plan that would be implemented to reduce the potential indirect effects to coho salmon due to potential changes in stream flows in lower Lime Creek during each phase of the Project are described in the discussion and tables presented in Section 6.7.2.9.2.3 of the Dolly Varden effects assessment.

6.7.3.9.2.2.1 Modelling Methods The likely effectiveness of the mitigation measures listed above to eliminate or reduce potential changes to stream flows, and hence to reduce potential effects to coho salmon parr in Lime Creek, was determined by: 1) comparing predicted monthly average, monthly minimum, monthly maximum, annual, peak instantaneous, and 7-day low flow discharges in lower Lime Creek during each phase of the Project to similar flow statistics during pre-mine, baseline conditions; and 2) comparing predicted monthly discharges during each phase of

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KITSAULT MINE PROJECT ENVIRONMENTAL ASSESSMENT FRESHWATER AQUATIC RESOURCES the Project to the instream flow guideline threshold as calculated using the BC Instream Flow Guidelines (BCIFG) for Fish (Hatfield et al., 2003).

Baseline discharges in lower Lime Creek were predicted from a watershed model developed to estimate the long-term (70 year period of record) surface water and groundwater flow patterns in the Lime Creek watershed calibrated with stream gauge data obtained from Lime Creek during the 2009 and 2010 field seasons. This calibrated model was then used to predict discharges in lower Lime Creek (at watershed model node LCK-H2; Figure 6.7.2-15) for each stage of the Project by superimposing key mine components on the modelled catchment area. Percent change in monthly, annual, peak instantaneous, and 7-day low flow discharges in lower Lime Creek were then calculated for each mine phase. These phases included:

 Construction (Phase 1): run-off from the upper Patsy Creek catchment is pumped to Lime Creek from behind temporary coffer dams to dewater the south embankment footprint;  Construction (Phase 2 and 3): run-off from the upper Patsy Creek catchment is stored behind the south embankment of the TMF;  Operations (Year 13): non-contact water from the upper Patsy Creek catchment is diverted around the TMF, East WRMF, and open pit via the South Diversion and Patsy Diversion channels and contact water from the LGS and surplus water from the TMF is discharged to Lime Creek via the Water Box;  Operations (Year 15): Patsy Creek diversion is maintained to divert non-contact water around TMF, East WRMF and open pit to Lime Creek; Kitsault Pit is filled with direct precipitation and seepage and run-off from the South WMP and LGS sediment control pond; TMF surplus water is discharged to Lime Creek via the Water Box;  Closure: all contact water and groundwater seepage is diverted to the Kitsault Pit and all non-contact water from the upper Patsy Creek watershed is diverted around the TMF, East WRMF, and open pit to Lime Creek (i.e. pit re-fill scenario A which fills the pit in 15 to 17 years (Knight Piésold, Appendix 6.5-C);

 Post-closure: all upstream contact and non-contact water reports to the Kitsault Pit and is ultimately discharged to Lime Creek via the pit spillway channel.

The BC Instream Flow Guideline Threshold for lower Lime Creek was calculated using the methods described in Hatfield et al. (2003) and a 20 year daily flow record for Lime Creek (1976 to 1996) obtained from a previously operated Water Survey of Canada (WSC) stream gauge in lower Lime Creek (WSC gauge #08DB010). The instream flow threshold for fish- bearing streams under the BCIFG is a seasonally-adjusted threshold for alterations to natural stream flows designed to protect fish and fish habitat. Flow thresholds using the BCIFG are calculated as percentiles of the natural mean daily flows for each calendar month. These percentiles vary throughout the year to ensure a higher protection during low flow months than high flow months (Hatfield et al. 2003). Predicted monthly discharges that

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KITSAULT MINE PROJECT ENVIRONMENTAL ASSESSMENT FRESHWATER AQUATIC RESOURCES exceeded the calculated monthly minimum instream flow threshold were assumed to be protective of coho salmon parr in lower Lime Creek. Conversely, predicted monthly discharges that fell below the calculated monthly minimum instream flow threshold were assumed to be potentially harmful to coho salmon parr and, therefore, were carried forward to the residual effects assessment below (Section 6.7.3-10).

6.7.3.9.2.2.2 Watershed Modelling Results Table 6.7.2-31 in the Dolly Varden effects assessment provides a comparison of the baseline monthly average, minimum, and maximum, and annual discharge in lower Lime Creek to the discharges predicted to occur during each of the six mine phases indicated above. These data were derived from Knight Piésold (2011; Kitsault Mine Project-Surface Water Hydrology Flow Changes report).

On an annual basis, potential changes in discharge in lower Lime Creek were predicted to be greatest during Year 15 of operations and during the closure phase. During both of these phases, average annual discharge in lower Lime Creek is predicted to be reduced by 20% and 17%, respectively. These reductions increase to 28% annually during a 1:70 year dry condition.

Average annual and monthly flow changes during Phase 1 of construction were assumed zero because all run-off captured behind the temporary coffer dams would be pumped downstream around the south embankment footprint construction area. Average annual flow changes during Phase 2 and 3 of construction were predicted to be 20% lower than baseline in an average year, 29% lower during a 1:70 year dry return period, and 9% lower during a 1:70 year wet return period.

Average annual flows in lower Lime Creek during the post-closure phase were predicted to increase during an average year (2% increase) and during a 1:70 year wet return period (3% increase) but predicted to decrease during a 1:70 year dry return period (8% reduction). The increase in annual discharge predicted in lower Lime Creek during the post-closure phase was due to the increased run-off from the encroachment of the TMF into the headwaters of the adjacent Clary Creek watershed; run-off from the headwaters of Lake 901 would report to Lime Creek post-closure.

Monthly flow changes during July and August, the critical summer rearing months for coho salmon parr, were also predicted to occur (Figure 6.7.3-3). On average, monthly flows in July and August were predicted to range between 8% lower during closure to 17% lower during construction (Phase 2 and 3). Monthly flow reductions during the winter low flow period (November to March) were predicted to be greatest during operations (Year 15: 13% to 18% reduction) and closure (18% to 23% reduction) phases when the Kitsault Pit is re- filling.

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5.0 4.5 4.0 3.5 /s) 3 3.0 2.5

Flow (m 2.0 1.5 1.0 0.5 0.0 Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec

Pre-mine C-P2&3 YrMonth 13 Yr 15 A C PC

Figure 6.7.3-2: Comparison of Predicted Average Monthly Discharges in Lower Lime Creek during Construction, Operations (Years 13 and 15), Closure, and Post- Closure Phases to Average Pre-Mine Conditions

A comparison of the predicted average monthly flows in lower Lime Creek during each phase7 of the Project to the calculated monthly instream flow guideline threshold8 is provided in Figure 6.7.3-4 below. As can be seen from this graph, predicted monthly discharges in lower Lime Creek during all phases of the Project were predicted to be below the calculated BC IFG threshold for lower Lime Creek in all months except during the spring freshet months of May and June. The largest deviations in discharge from the calculated BC IFG threshold occur in the low flow months of August, December, January, February and March. During these months, the predicted average monthly discharges in lower Lime Creek were predicted to be approximately 0.5 m3/sec lower than the corresponding BC IFG threshold discharge.

The fact that the predicted mean monthly discharge during each phase of the Project are predicted to be below the calculated BC IFG threshold in these months, particularly during

7 Average monthly discharges for each Project phase were calculated using the percentage change in monthly flows from baseline predicted by the watershed model. Pre-mine baseline monthly average discharges were calculated from the 20 year daily flow record (1976 to 1996) obtained from the Water Survey of Canada stream gauge (08DB010) in lower Lime Creek. This was done so that predicted monthly flows could be fairly compared to the BC Instream Flow Guideline threshold; the watershed model only predicts monthly flows but the BC IFG threshold must be calculated from daily flows.

8 Threshold guideline was calculated from the 20 year daily flow record (1976 to 1996) obtained from the WSC stream gauge (08DB010) in lower Lime Creek using the methods described in Hatfield et al. (2003)

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KITSAULT MINE PROJECT ENVIRONMENTAL ASSESSMENT FRESHWATER AQUATIC RESOURCES the summer and winter low flow months when coho salmon parr are rearing and overwintering in lower Lime Creek, indicates that the mitigation measures included in the Project’s water management plan are insufficient to eliminate the potential indirect effect of predicted changes in stream flows in lower Lime Creek on coho salmon parr. As a result, this potential effect is carried forward to the assessment of residual effects (see Section 6.7.3.10).

5

4.5

4

3.5 /s) 3 3 (m

2.5

2 Discharge 1.5

1

0.5

0

Pre‐mine BC Instream Flow Minimum Threshold Construction Stage 2 & 3 Operations‐Year 13 Operations‐Year 15 Closure Post‐closure

Figure 6.7.3-3 Comparison of Predicted Average Monthly Discharges in Lower Lime Creek during Construction, Operations (Years 13 and 15), Closure, and Post- Closure Phases to Pre-Mine Average Monthly Discharge and the Calculated BC Instream Flow Guideline Threshold

6.7.3.9.2.3 Change in Water Temperatures in Lime Creek 6.7.3.9.2.3.1 Potential Change in Water Temperatures in Lime Creek Potential changes in water temperatures in Lime Creek may occur during all phases of the Kitsault Project (Table 6.7.3-6). These changes would occur primarily from: 1) ponding and release of water from the developing TMF during Construction Phases 2 and 3; 2) ponding

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KITSAULT MINE PROJECT ENVIRONMENTAL ASSESSMENT FRESHWATER AQUATIC RESOURCES and release of water from the TMF during mine operations and closure; and 3) ponding and release of Kitsault Pit over-flows during post-closure.

The TMF and Kitsault Pit are located in the Patsy Creek watershed. Subsequently, water temperatures in Patsy Creek could change when the discharge in Patsy Creek is altered from being largely determined by outflows from Patsy Lake during pre-mine conditions to being largely determined by outflows from the TMF during construction, operations and closure phases and from the Kitsault Pit during the post-closure phase. Thus, these activities could ultimately result in changes in water temperatures in lower Lime Creek, particularly if:

 Water discharged from the TMF and Kitsault Pit to Patsy Creek are substantially colder or warmer than water temperatures discharged from Patsy Lake;  Water temperatures in Patsy Creek are increased or decreased such that the addition of flow from the unaffected Patsy Creek tributaries downstream of the TMF and East WRMF, from Lime Creek watershed upstream of the Patsy Creek confluence and from the additional flow contributed by downstream tributaries is insufficient to attenuate changes in Patsy Creek water temperatures.

During construction and operations, release of surplus water from the TMF has the potential to increase summer water temperatures in lower Lime Creek. This is because: 1) the surface area of the TMF supernatant pond would be larger (1.7 milliion m2) than Patsy Lake (185,803 m2) thus increasing the amount of water exposed to the sun during summer; 2) the recycled process water may contribute heat to the TMF supernatant pond; and 3) water from the TMF would be pumped from near the surface of the TMF to the Water Box (this surface water would be warmer than water at the bottom of the supernatant pond in summer).

During the post-closure phase, water released from the Pit to Patsy Creek (via the spillway) may be warmer in summer with delays in the spring warm-up and fall cool-down periods compared to current temperatures in Patsy Creek due to the greater surface area (660,591 m2) and depth (approximately 300 m) of the end-pit lake compared to that of Patsy Lake (185,803 m2 and 29 m maximum depth). This is approximately 3.5 times the size and 10 times the depth of Patsy Lake. However, no change in winter water temperatures are expected because, similar to Patsy Lake, the surface of the end-pit lake is expected to freeze and water temperatures drawn off the top of the lake are expected to be near zero.

Based on the above situations, the potential exists for water temperatures in Patsy Creek and Lime Creek to be altered during all seasons and during all phases of the Project compared to water temperatures currently experienced by Dolly Varden in lower Lime Creek. Some of these potential changes in water termpeature created by the Project would at least partially be attenuated by the continued influence of thermal loading provided by run-off from the unaffected upper Lime Creek watershed, run-off from the diverted upper Patsy Creek watershed, and run-off from the unaffected Lime Creek tributaries downstream of the Patsy Creek confluence.

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6.7.3.9.2.3.2 Potential Effect of Water Temperature Changes on Coho Salmon Parr Changes in water temperature have the potential to directly affect rates of feeding, metabolism, conversion efficiency, and growth of fish (Brett, 1971; Wurtsbaugh and Davis 1977; Elliott 1982; Diana 1995). Water temperature can also result in direct mortality of fish if temperatures exceed the incipient lethal water temperature of the fish species in question. Water temperature also indirectly affects fish by altering the solubility of dissolved gases (Johnson and Jones 2000), the prevalence of water-borne diseases (Becker and Fugihara 1978) and the interactions of fish with other stream organisms (i.e., prey, predators or competitors).

Fish are obligate poikilotherms (i.e., cold-blooded animals that take on the temperature of their surroundings) and alter their behaviour in relation to temperature in order to maximise their growth, minimise their risk of predation, and avoid, if possible, temperatures at or near their physiological tolerances. Such behaviour can occur daily (Brett 1971), seasonally (Coutant 1987), or ontogenetically (Magnuson et al. 1979, McCauley and Huggins 1979) but depends on the availability of appropriate thermal habitat, habitat that can be potentially more limited for species with relatively narrow physiological temperature requirements such as coho salmon (Brett 1952).

Coho salmon are a cold-water species. Juveniles show a preference for water temperature ranging from 12° to 14°C (Brett 1952; Reiser and Bjornn 1979) in summer, which is close to optimum for maximum growth efficiency (Sandercock 1991). Juvenile coho exhibit positive growth rates in water temperatures as high as 17°C as long as food is not limiting (Brungs and Jones 1977; Hughes and Davies 1986). The lower and upper lethal temperature limit for juvenile coho ranges between 0.2° and 1.7°C and 22.9°and 25°C, respectively (Brett 1952; Becker and Genoway 1979). Brett (1952) has shown that juvenile coho can tolerate up to 4 days of exposure to temperature close to 0°C, but a sharp drop in temperature (from 5°C to 0°C) resulted in mortality.

Based on this information, any releases of water from the TMF during construction or operations or from the Kitsault Pit during closure or post-closure that would cause water temperatures in lower Lime Creek to increase above 17°C or above 23°C in summer could be expected to reduce growth rates or increase mortality of coho salmon parr rearing in the creek. Conversely, any releases of water from the TMF or Kitsault Pit that would cause water temperatures to fall below 1°C or to fall quickly from 5°C to below 1°C over a few days could be expected to result in increased mortality of coho salmon parr.

6.7.3.9.2.3.3 Mitigation Measures No mitigation measures are proposed to specifically eliminate or reduce the potential changes in water temperatures in Lime Creek. However, any potential changes in water temperatures in Patsy Creek on lower Lime Creek water temperatures would be partially attenuated by run-off from the unaffected upper Lime Creek watershed and from unaffected Lime Creek tributaries downstream of the Patsy Creek confluence during all phases of the Project and by the diversion of non-contact run-off from upper Patsy Creek watershed

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As it is uncertain whether the TMF and / or the Kitsault Pit would alter water temperatures entering Lime Creek and whether natural inflows from the unaffected upstream watershed areas would completely eliminate any potential changes in water temperatures in Patsy Creek and ultimately in lower Lime Creek where coho salmon parr reside, this potential effect on coho salmon is carried forward to the assessment of potential residual effects.

6.7.3.9.2.4 Change in benthic macro-invertebrate community in Lime Creek There are no-specific mitigation measures proposed to eliminate or reduce potential effects to benthic macro-invertebrates in Lime Creek due to potential changes in water quality, surface water flow and temperature created by the Project. Only those mitigation measures included in the water management plan already discussed in Section 6.7.2.9 of the Dolly Varden effect assessment would be implemented. It is assumed that some or all of these mitigation measures would reduce some of the potential indirect Project effects on benthic macro-invertebrate communities in Lime Creek and, therefore, would reduce some of the potential indirect effects to coho salmon parr residing in lower Lime Creek. Because these mitigation measures are not expected to completely eliminate potential changes benthic macro-invertebrate density and community structure in the Lime Creek, potential effects of changes in benthic macro-invertebrates community on coho salmon is carried forward to the assessment of potential residual effects.

6.7.3.10 Potential Residual Effects and Their Significance I am Only those potential effects that would not be eliminated by mitigation measures included in here the water management plan or committed to in Section 6.7.3.9.2.3.3 above were carried forward to this assessment of potential residual effects on coho salmon parr. An assessment of the potential residual effects to coho salmon parr of each of these indirect effects is presented in the sections below. The significance of each of these potential effects is assessed in Section 6.7.3.10.2.

6.7.3.10.1 Potential Residual Effects After Mitigation 6.7.3.10.1.1 Change in Surface Water Quality in Lime Creek Potential changes in surface water quality in Lime Creek were compared to provincial and / or federal water quality guidelines for the protection of freshwater aquatic biota. Exceedences were identified for fluoride, sulphate, aluminum, cadmium, chromium, copper, mercury, molybdenum, selenium, and zinc during one or more Project phases.

The proponent acknowledges that lethal or chronic health effects to coho salmon and other freshwater aquatic biota in Lime Creek due to water quality changes caused by the proposed Project would be unacceptable. As such, the proponent is committed to working with Environment Canada, the BC Ministry of Environment, and the Nisga’a Lisims Government to determine if and what water quality objectives (WQOs) would be appropriate

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KITSAULT MINE PROJECT ENVIRONMENTAL ASSESSMENT FRESHWATER AQUATIC RESOURCES for each chemical of concern with predicted exceedences of existing water quality guidelines for the protection of freshwater aquatic biota. The proponent is also committed to monitoring water quality in their mine effluent (as required under the Metal Mine Effluent Regulation [MMER] of the federal Fisheries Act) and in Lime Creek (as part of any future Environmental Effects Monitoring [EEM] program) and to providing water treatment of their mine effluent if required.

Section 6.7.2.10.1.1 assesses the potential residual effect of each of these parameter exceedences on the health, growth, survival, and recruitment of Dolly Varden in lower Lime Creek. Although the potential toxicological effects of these potential chemicals of concern on Dolly Varden and coho salmon parr may be slightly different, both species are members of the Salmonidae family and, therefore, are assumed to have similar responses to the predicted concentrations of these chemicals of concern in lower Lime Creek. As result, the assessment and potential residual Project effects of water quality changes on Dolly Varden health, growth and survival in Lime Creek identified in section 6.7.2.10.1.1 are assumed to apply equally to coho salmon parr. To summarise that assessment here:

 Water quality modelling assumed that all chemicals entering the receiving environment remain in dissolved form and do not form complex compounds with other water quality parameters present in the water column (this is conservative assumption and likely over-estimates the concentrations of metals that are known to have complex speciation in freshwater environments (e.g., aluminum);  Some of the predicted exceedences were due to making assumptions about the actual concentration loads entering the Lime Creek because detection limits for the parameter were too high to determine the actual concentration (e.g., mercury);  Some of the guidelines were incorrectly derived (e.g., fluoride) and when corrected, the predicted concentrations no longer resulted in exceedences; and  No residual effects to fish or other aquatic biota in Lime Creek would occur because site-specific water quality objectives would be developed in consultation with Environment Canada, the BC Ministry of Environment, and the Nisga’a Lisims Government and the proponent would ensure that no water that exceeded these site- specific guidelines would be discharged to Lime Creek at any time during the Project. This may include the development of a water treatment plant if site-specific water quality objectives were found to be unattainable without one.

Based on this assessment, no significant residual effect to coho salmon parr in lower Lime Creek is expected to occur due to predicted water quality changes in Lime Creek.

6.7.3.10.1.2 Change in Stream Flows in Lime Creek 6.7.3.10.1.2.1 Assessment Methods Relationships between discharge and predicted average wetted width, water depths and water velocities in lower Lime Creek in the lowest reaches of Lime Creek where coho salmon reside could not be developed as was done for Dolly Varden. This was because

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KITSAULT MINE PROJECT ENVIRONMENTAL ASSESSMENT FRESHWATER AQUATIC RESOURCES hydraulic habitat transects in these lowest reaches of Lime Creek were not established during the 2010 field season; a greater emphasis was placed on the analysis of potential flow reductions on Dolly Varden than on coho salmon due to the fact that an anadromous run of Dolly Varden exists in lower Lime Creek while an anadromous run of coho salmon does not exist in lower Lime Creek. As a result, a quantitative assessment of the potential effect of the predicted discharge changes in lower Lime Creek similar to that conducted for Dolly Varden spawning habitat (see Section 6.7.2.10.2) could not be conducted. Instead, a qualitative assessment of the potential effect of predicted stream flow changes was conducted by comparing the known hydraulic habitat preference of coho salmon parr available in the published literature to the availability and distribution of this type of hydraulic habitat that currently exists in the lowest reaches of Lime Creek and to the likely change in the availability and suitability of this habitat due to the predicted flow reductions caused during all phases of the Project.

6.7.3.10.1.2.2 Assessment results Within streams in summer, coho salmon parr select deep (>0.3 m <1.0 m), slow pools (McMahon 1983; Taylor 1991; Rosenfeld et al. 2000) with cover from large woody debris, undercut banks, and riparian vegetation (Glova 1986; Taylor 1988; McMahon and Hartman 1989). However, given the opportunity, coho salmon parr will actively select off-channel habitats with water velocities <0.3 m/sec (Murphy et al. 1989) and abundant instream and overhanging cover.

Coho salmon parr typically spend one to two years rearing in streams before moving downstream to the ocean as smolts. During the winter, coho salmon parr prefer off-channel pools with water velocities <0.3 m/sec (Tschaplinski and Hartman 1983) but will use deep, slow-flowing pools in the mainstem channels if there is also instream (e.g., boulders and logs) or overhanging riparian vegetation (Swales et al. 1985).

Beecher et al. (2002) found the strongest correlation between juvenile coho salmon parr distribution and habitats with the combination of preferred water depths and water velocities compared to habitats with only one of these two attributes. Beecher et al. (2002) found that the preferred depth and water velocity range of coho salmon parr in summer was 0.76 m and 1.0 m and 0.03 and 0.06 m/sec, respectively. Slow water velocity is high correlated to juvenile coho salmon distribution (Murphy et al. 1989), holding capacity (Ruggles 1966) and habitat use (Bisson et al 1988; Peters 1986).

Habitat in the lowest reaches of Lime Creek is characterised by riffle and cascades with large (65 to 256 mm diameter), angular cobble substrates. There is also numerous large (>500 mm) boulders throughout these reaches but in mid-channel and along the stream margins. While the banks of the channel have been heavily rip-rapped due to the straightening of the channel during the construction of the town of Kitsault in the early 1980s, cover is provided along the stream margins by overhanging branches of the willows and alders that line the both sides of the channel. As would be expected based on the habitat preference data presented above, most of the coho salmon parr captured in lower

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Lime Creek in the summer of 2010 were associated with slow-flowing water along the stream margins or behind the large boulders strewn through the lower reaches.

Although flow reductions are predicted to occur in lower Lime Creek during the summer during all phases of the Project, no change in the amount or suitability of summer rearing habitat for coho salmon parr in lower Lime Creek is expected to occur. This is because, even during construction when July and August discharges would be reduced the most (up to 17% lower on average), the reduction of slow flowing habitat available to coho salmon parr rearing the lower Lime Creek is expected to be negligible. This type of habitat would continue to exist in lower Lime Creek along the stream margin and behind the boulders present in the channel downstream of the cascade even with the predicted flow reductions.

Overwintering habitat for coho salmon parr in the lowest reaches of Lime Creek is restricted to the single large pool located directly below the 3 m high bedrock cascade located 270 metres upstream from Alice Arm. The density of other fish species (e.g., Dolly Varden, prickly sculpin, and coast range sculpin) in this deep pool in winter is likely to be high given that it is the only pool available to fish for overwintering between the cascade and Alice Arm. Whether coho salmon parr use this pool in winter or move downstream to Alice Arm is unknown; the pool does not have any cover for coho salmon parr over than cover from depth. However, even if they use this pool in winter, it is highly unlikely that the predicted flow reductions caused by the Project would lower its suitability as overwintering habitat. This pool is large and well over 3 metres deep and, therefore is likely to be relatively insensitive to the flow reductions predicted to occur in winter during any phase of the Project.

Considering that coho salmon parr present in lower Lime Creek are only strays from other streams and the fact that the predicted flow reductions in lower Lime Creek are unlikely to adversely affect existing coho salmon parr summer or winter habitat in the lowest reaches of the stream, no residual effect to coho salmon parr is expected to occur. The residual effect is rated as not significant (negligible).

6.7.3.10.1.3 Change in Water temperatures in Lime Creek Water temperatures in lower Lime Creek are currently near optimal for coho salmon parr growth and survival in summer (Figure 6.7.3-5). Average monthly water temperatures during July and August are 11°C and 12.5°C, respectively, which is within their optimal temperature range of 12°C to 14°C (Brett 1952; Reiser and Bjornn 1979). Therefore, at least a 2°C increase in July or August water temperatures would be needed to exceed the preferred temperature range upper limit of coho salmon parr while at least a 6°C temperature increase is needed to exceeded to being to impair coho salmon parr growth and survival (Brungs and Jones 1997; Hughes and Davies 1986). At least an 11°C temperature increase would be needed to create lethal temperatures (>23°C; Brett 1952; Becker and Genoway 1979) for coho salmon parr in lower Lime Creek.

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20.0 Mean 18.0 Min

16.0 Max 14.0

12.0

10.0

8.0

6.0 Temperature (Temperature C) 4.0

2.0

0.0

-2.0

Date

Figure 6.7.3-4 Mean, Minimum, and Maximum Daily Water Temperatures in Lower Lime Creek in 2010/2011

The likelihood of water releases from the TMF during construction and operations and from the Kitsault Pit during closure and post-closure phases raising summer water temperature more than one or two degrees is unlikely. This is because, even though both reservoirs would have a larger surface area and a greater thermal mass than Patsy Lake, the prevailing climatic conditions in the Kitsault Area in summer are cool (average summer air temperature of 12°C) and cloudy with frequent rain events. This cool, wet climate combined with the attenuating effects of the combined contributions of unaffected run-off and thermal loadings from upper Lime Creek upstream of the Patsy Creek confluence, the diverted run- off from upper Patsy Creek watershed (during construction and operations only) and from Lime Creek tributaries downstream of the Patsy Creek confluence, are likely to moderate any potential increases in water temperature released from either the TMF or Kitsault Pit during any phase of the Project.

Average monthly water temperatures in lower Lime Creek during the winter (0.3°C to 2°C) are already very near the lower lethal temperature range for coho salmon parr (Figure 6.7.3-5). While it is difficult to predict winter water temperatures in the TMF due to the uncertainties regarding the thermal inputs to the TMF from the processing plant, whether

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KITSAULT MINE PROJECT ENVIRONMENTAL ASSESSMENT FRESHWATER AQUATIC RESOURCES the supernatant pond would stratify, and how much water would need to be released during winter, the release of water from the TMF during construction and operations is more likely to increase winter water temperatures in lower Lime Creek than decrease them. Any such change is likely to be small (approximately 1°C or 2°C) however due to attenuation from the upstream watershed. As a result, any increase in water temperature of this small magnitude may be potentially beneficial to coho salmon parr overwintering in lower Lime Creek not detrimental.

Even with the uncertainties indentified above, no potential residual effect of changes in water temperatures on coho salmon parr is expected during any phase of the Project. Any water temperature changes that would occur would likely be insufficient to alter the growth or survival of coho salmon parr in summer or to alter the survival of coho salmon parr in winter. This potential effect is rated as not significant (negligible).

6.7.3.10.1.4 Change in Benthic Macro-Invertebrate Community in Lime Creek Coho salmon parr fed on benthic invertebrate drift during the summer. Young-of-the-year will feed primarily on smaller instar stages, particularly chironomids) while yearlings will feed on larger larvae and nymphs (Mundie 1969; McPhail 2007). These can be larvae of aquatic insects drifting downstream or terrestrial invertebrates falling on to the water surface from overhanging vegetation.

Potential changes in benthic invertebrates drift in lower Lime Creek due to the potential combined, indirect effects of changes in water quality, changes in stream flow, and changes in water temperatures are difficult to predict with any certainty. However, it is predicted that no significant adverse effect to coho salmon parr would occur during any phase of the Project due the indirect effect of changes to benthic invertebrate drift because:

 If it is assumed that benthic invertebrate production across the wetted perimeter of Lime Creek is homogenous, the small change in wetted width predicted to occur due flow reductions caused by the Project is unlikely to have a large effect on the number of benthic invertebrates available to drift downstream to coho salmon parr on any given day;  The flow reductions predicted to occur in Lime Creek are unlikely to be large enough to reduce the water velocities or depths preferred by the mayflies, stoneflies, and caddisflies that currently dominate the benthic macro-invertebrate community of Lime Creek;  The flow reductions predicted to occur in Lime Creek are unlikely to be large enough to reduce the delivery of benthic invertebrate drift to coho salmon in lower Lime Creek;  The small changes in water temperatures predicted to occur are unlikely alter the benthic invertebrate community of Lime Creek in favour of prey items not preferred by coho salmon parr; and

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 Water quality of the discharge effluent from the Project would be monitored such that no water would be released downstream that didn’t meet site-specific water quality objectives designed to ensure the protection of freshwater aquatic biota in Lime Creek, including the benthic macro-invertebrate community.

This potential indirect residual effect is rated as not significant (minor). However, the level of confidence is low because of the uncertainty regarding the potential combined effects of changes in water quality, stream flows, and water temperatures due to the Project on the benthic macro-invertebrate community in Lime Creek

6.7.3.10.1.5 Summary of Potential Residual Effects after Mitigation A summary of potential residual Project effects on coho salmon parr in lower Lime Creek is provided in Table 6.7.3-13. All of these potential effects are indirect effects through potential direct changes to water quality, stream flows, water temperatures, and benthic macro- invertebrate prey in the Lime Creek watershed. There are no potential direct effects of the Project on coho salmon parr.

Table 6.7.3-13: Summary of Residual Effects for Coho Salmon

Project Phase Residual Effect Direction C,O,D/C, PC Change in surface water quality in lower Lime Creek Negative C,O, D/C Change in hydrology in lower Lime Creek Negative C, O, D/C, PC Change in water temperature in lower Lime Creek Negative/Positive C, O, D/C Change in benthic macro-invertebrates in Lime Creek Negative Note: C - construction; O - operations; D/C - decommissioning and closure; PC - post-closure

6.7.3.10.2 Significance of Potential Residual Effects Assessments of the potential residual effects of changes in surface water quality, stream flows, water temperatures, and benthic macro-invertebrates in Lime Creek on coho salmon parr during each phase of the Project is provided in Table 6.7.3-14. Each identified residual effect was subjected to rating criteria to determine significance; these criteria are described in Section 5.0, Assessment Methodology. Rationales for the various significance ratings criteria applied to each potential residual effect are provided where needed to explain the overall significance rating not already explained in the residual effect assessments above.

For all of the potential residual effects to coho salmon parr, the ecological context was considered low because none of the coho salmon parr present in lower Lime Creek are progeny of a coho salmon run in Lime Creek; all coho salmon parr present are strays from other rivers in the Alice Arm area and, therefore, the potential for any residual effect created by the Project to have a measureable adverse effect on the coho salmon stock(s) from which these fish came is negligible.

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Table 6.7.3-14: Residual Effects Assessment by Project Development Phase for Coho Salmon

Stage of Development / Rating Parameter Decommissioning Construction Operations Post-closure and closure Residual Effect Change in surface water quality in lower Lime Creek Effect Attribute Direction Negative negative negative negative Magnitude Medium Medium Medium Medium Geographic extent Local Local Local Local Duration Medium-term Long-term Long-term Chronic Frequency Continuous Continuous Continuous Continuous Reversibility No No No No Ecological Context Low Low Low Low Probability of occurrence High High High High Certainty Medium Medium Medium Medium Residual Effect Significance Not significance Not significant Not significant Not significant (low) (low) (low) (low) Level of Confidence Medium Medium Medium Medium Change in hydrology in lower Lime Creek Effect Attribute Direction Negative Negative Negative Negative Magnitude low low low Low Geographic extent local local local Local Duration Medium-term Long-term Long-term Chronic Frequency continuous continuous continuous continuous Reversibility no no no Yes Ecological context low low low Low Probability of occurrence high high high High Certainty medium medium medium Medium Residual Effect Significance Not significant Not significant Not significant Not significant (negligible) (negligible) (negligible) (negligible) Level of Confidence High High High High Change in water temperature in lower Lime Creek Effect attribute Direction Negative negative negative Negative Magnitude low low low Low Geographic extent local Local local Local Duration short-term Long-term Long-term Chronic Frequency continuous continuous continuous Continuous Reversibility no no no No Ecological context low low low Low

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Stage of Development / Rating Parameter Decommissioning Construction Operations Post-closure and closure Residual Effect Change in surface water quality in lower Lime Creek Effect Attribute Probability of occurrence unknown unknown unknown low Certainty low low low high Residual Effect Significance Not significant Not significant Not significant Not significant (negligible) (negligible) (negligible) (negligible) Level of confidence Medium Low Low High Change in benthic macro-invertebrates in lower Lime Creek Effect attribute Direction Negative Negative Negative Negative Magnitude Low Low Low Low Geographic extent Local Local Local Local Duration Medium-term Long-term Long-term Long-term Frequency Continuous Continuous Continuous Continuous Reversibility No No No No Ecological context Low Low Low Low Probability of occurrence Low Medium Medium Low Certainty Medium Medium Medium Low Residual Effect Significance Not significant Not significant Not significant Not significant (minor) (minor) (minor) (minor) Level of confidence Low Low Low Low

Overall, the significance of these potential indirect effects on individual coho salmon parr is not significant (minor). This is because some change in the growth and survival of individual coho salmon parr rearing and overwintering in lower Lime Creek may be slightly compromised, particularly by the combined effects of these four potential indirect effects. However, the overall significance of these potential indirect effects on the coho salmon stocks from which the coho salmon parr in lower Lime Creek were spawned is negligible. Lower Lime Creek is not ideal rearing and overwintering habitat for coho salmon because of the paucity of slow, deep pools with cover. Also, lower Lime Creek is not critical habitat for long-term sustainability of these stocks and the number of coho salmon parr rearing and overwintering in lower Lime Creek is likely to be negligible in comparison to the number of coho salmon parr rearing and overwintering in their natal stream(s).

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6.7.3.11 Cumulative Effects Assessment

6.7.3.11.1 Rationalisation for Carrying Forward Project Related Residual Effects Into the Cumulative Effects Assessment In order to produce a cumulative effect, minor or moderately significant residual effects of the proposed Project on coho salmon parr must overlap temporally or spatially with known or likely residual effects from past, present, or foreseeable projects. The minor or moderate residual effects of the proposed Project on coho salmon parr carried forward in the cumulative assessment are listed in Table 6.7.3-15.

Table 6.7.3-15: Project Related Residual Effects - Rationale for Carrying Forward Into the Cumulative Effects Assessment

Carried Project Project Component Residual Effect Rationale Forward Phase in CEA Effluent release from the C, O, Change in Surface Changes in surface water quality Yes TMF and overflow from D/C, water quality in lower could affect the growth, health, and the Kitsault Pit post- PC Lime Creek survival of coho salmon parr in closure lower Lime Creek Construction, operation, C, O, Change in benthic Changes in the benthic invertebrate Yes and decommissioning of D/C, macro-invertebrate community in Lime Creek could the TMF and Kitsault Pit PC drift in lower Lime affect the growth and survival of Creek coho salmon parr in lower Lime Creek Note: C - construction; O - operations; D/C - decommissioning and closure interaction

Both potential indirect effects to coho salmon parr in lower Lime Creek with minor or moderate significance are carried forward into the assessment of potential cumulative effects. This is because both potential residual Project effects have the potential to reduce the growth and survival of individual coho salmon parr in lower Lime Creek which, therefore, have the potential to cumulatively interact with past mining activities at the Kitsault mine which may have already reduced the suitability of coho salmon parr habitat in lower Lime Creek and with commercial or recreational fishing which may have in the past, and may continue to lower the number of coho salmon available to return to their natal streams to spawn.

6.7.3.11.2 Interaction Between Coho Salmon and Other Past, Present or Future Projects / Activities Past mining activities at the Kitsault Mine during the 1960s and early 1970s and again during the early 1980s may cumulative interact with predicted residual effects of the proposed Kitsault Project in two ways. First, previous disposal of mine tailings in Lime Creek in the early 1970s may have extipirated any coho salmon run that may have previously existed in the creek. Second, the channelisation of the lower reaches of Lime Creek during the early 1980s may have reduced habitat quality of the lower reaches of Lime

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Creek which may have precluded the re-establishment of a coho salmon run in the creek after the disposal of mine tailings in the creek ceased.

Lea and Goddard (1975) reported anecdotal evidence from an unidentified local Alice Arm resident that “there was no salmon run in Lime Creek between 1934 and 1974.” However, McCart and Withler (1980) refute the contention that a salmon run never existed in Lime Creek because, in their view, the reasons Lea and Goddard (1975) suggest for the absence of salmon in Lime Creek in the mid-1970s (i.e., insufficient food supply for parr and over- exploitation of salmon by the former mining settlement of Silver City (dating back to the 1900s) are unsubstantiated by empirical evidence, don’t account for apparent suitability of spawning habitat in the stream, and don’t account for the likelihood that the Alice Arm resident may not have noticed salmon in the creek because they salmon do not necessarily require major holding areas in the creek prior to spawning when they would then be observable.

McCart and Withler (1980) instead conclude that “there can be no question that there had been salmon populations in Lime Creek and the dumping of over 12 million tons of mine waste into its waters over a period of years would have drastically affected spawning success and egg to fry survival and been a significant factor in preventing recolonisation.” However, they too do not provide any empirical evidence for any such assertion.

Although it is not conclusive either, the fact that an anadromous Dolly Varden population exists in Lime Creek suggest that a coho salmon run never previously existed in Lime Creek prior to past mining activities. Presumably, Dolly Varden in Lime Creek would have been equally affected by the deposit of mine tailings in Lime Creek as salmon. If so, the fact that a Dolly Varden has returned to the creek suggest that it should be equally probable that a coho salmon run would also have returned to the creek if habitat was indeed suitable for them. This is because both adult Dolly Varden and adult coho salmon are known to stray from their natal streams to spawn. Therefore, given the duration of time since this past mining effect took place, it seems reasonable to conclude that a coho salmon run would also exist in Lime Creek if it was indeed suitable for coho salmon spawning and rearing. The absence of coho salmon parr upstream of the cascade impediment suggest this is not true and that a coho salmon run in Lime Creek never existed.

Channelisation of the lower reaches of Lime Creek during construction of the town of Kitsault in the 1980s eliminated the natural delta at the mouth of the creek that can be clearly see in old aerial photos. The channels in this delta could have provided spawning and rearing habitat for coho salmon prior to construction of the town and prior to the deposit of mine tailings in the creek in the 1970s.

On-going commercial and recreational fisheries in the Alice Arm, Observatory Inlet and Pacific Ocean plus recreational fishing guided by Nisga’a peoples in the Kitsault and Illiance Rivers have the potential to cumulartive interact with potential residual effects of the Kitsault Project on coho salmon. This potential interaction exists because both commercial and recreational fishing and residual effect of the Kitsault Project have the potential to redue the

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KITSAULT MINE PROJECT ENVIRONMENTAL ASSESSMENT FRESHWATER AQUATIC RESOURCES number of coho salmon returning to the natal streams to spawn, thus potentially reduce the size and sustainability of the stock(s).

The potential interactions between past, present, and reasonably foreseeable future projects and potential residual effects from the Kitsault Project are identified in Table6.7.3-16 below.

Table 6.7.3-16: Assessment of Interaction Between Other Projects, Human Activities and Reasonable Foreseeable Projects with Coho Salmon Reasonably Representative Current and Historical Land Use Foreseeable Future Land Use Projects

a’a Nation hunting, hunting, Nation a’a Kitsault Mine and and Mine Kitsault exploration (on- Townsite Kitsault going) Alice Arm townsite (on- going) min Previous operations mine Previous exploratioin and Transportation access Mining exploration guide and Trapping outfitting Nisg trapping, fishing and and fishing trapping, uses other hunting, Aboriginal and fishing trapping, uses other Northwest Line Transmission Project Change in coho - - NI NI NI NI NI o o NI salmon due to change in Surface water quality in lower Lime Creek Change in coho - - NI NI NI NI NI o o NI salmon due to change in benthic macro-invertebrate drift in lower Lime Creek Note: Interaction definitions: o - interaction; - - key interaction; + - benefit; NI - no interaction

An assessment of the potential spatial and temporal overlap between potential residual effects of the Kitsault Project on coho salmon and other past, present, or reasonably foreseeable future Projects on coho salmon is provided in Table 6.7.3-17.

Table 6.7.3-17: Assessment of Spatial and Temporal Overlap Between the Project and Other Projects and Human Actions with Coho Salmon

Cumulative Residual Effect Human Activity Environmental Extent Duration Rationale (Contribution Effect from Project or Overlap) Historical land Kitsault Mine Change in Local Chronic Mine tailings Potential use and habitat and potentially change in exploration water quality in extirpated coho salmon Lime Creek previous growth and due to deposit coho salmon survival of mine tailings run reduces the

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Cumulative Residual Effect Human Activity Environmental Extent Duration Rationale (Contribution Effect from Project or Overlap) in the creek probability of re- establishing a coho salmon run in Lime Creek Kitsault Channelisation Local Chronic Alteration of Potential Townsite of lower fish hindered change in reaches of recolonisatoin coho salmon Lime Creek of Lime growth and Creek by survival coho salmon reduces the probability of re- establishing a coho salmon run in Lime Creek Alice Arm No interaction townsite Past mine No interation operations Past mine No interaction exploration Representative Transportation No interaction current and and access future land use Mining No interaction exploration Trapping and Reduction of provincial Chronic Fishing Potential guide coho salmon pressure change in outfitting stocks in north reduces coho salmon coast rivers number of parr growth coho salmon and survival returning to reduces natal streams number of to spawn adult coho salmon returning to natal streams to spawn Nisga’a Reduction of regional intermittent Fishing Potential Nation coho salmon pressure change in hunting, stocks in the reduces coho salmon trapping, Kitsault and number of parr growth fishing and Illiance rivers coho salmon and survival other uses returning to reduces natal streams number of to spawn adult coho salmon returning to natal streams

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Cumulative Residual Effect Human Activity Environmental Extent Duration Rationale (Contribution Effect from Project or Overlap) to spawn Aboriginal No interaction hunting, trapping, fishing and other uses Reasonably Northwest No interaction foreseeable Transmission projects Line Project

6.7.3.11.3 Mitigation Measures There are no mitigation measures specifically proposed to eliminate potential cumulative effects of the Kitsault Project on coho salmon with residual effects for other past, present, or reasonably foreseeable future projects or land uses. The likely effectiveness of each of the mitigation measures that would be used to reduce Project effects on coho salmon parr have already been assessed above and it is only those Project effects with potential residual effects to coho salmon parr that are being assessed here for their potential interaction with other past, present, or future effects to coho salmon parr in Lime Creek and in Alice Arm / Observatory Inlet (Table 6.7.3-18).

Although not strictly a mitigation measure, an environmental effect monitoring program would be developed in consultation with Environment Canada, the BC MOE, and the NLG prior to construction of the Project. This monitoring program would be designed and implemented with two-fold purpose of: 1) assessing whether predictions made during the impact assessments are accurate; and 2) determining whether any unanticipated effects are occurring, and if so, to trigger the implementation of additional mitigation, adaptive management, and / or compensation as required.

Table 6.7.3-18: Potential Cumulative Effect by Project Phase on Coho Salmon and Mitigation Measures

Mitigation Project Project Mitigation / Enhancement Measure Success Cumulative Effect Phase Rating Change in surface C,O, D/C, PC Water management plan, water treatment Medium water quality in plant at closure (if required), adherence to Lime Creek site-specific water quality objectives Change in benthic C,O, D/C, PC Water management plan, water treatment Medium macro-invertebrates plant at closure (if required), adherence to in Lime Creek site-specific water quality objectives Note: C - construction; D/C - decommissioning and closure; O - operations; PC - post-closure

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6.7.3.11.4 Potential Residual Cumulative Effects and Their Significance The potential for residual effects on coho salmon parr from the Kitsault Project to interact cumulatively with potential residual effects of past mining at Kitsault, construction of the Kitsault townsite and on-going and future commercial and / or recreational fishing, including the fishing in Kitsault and Illliance rivers guided by Nisga’a peoples is negligible Table 6.7.3-19). This assessment is based on the facts that:

 The likelihood that an androumous coho salmon run ever existed in Lime Creek is low. This is because, even though suitable habitat exists in the creek for spawning and rearing of coho salmon, a coho salmon run does not currently exist in Lime Creek. This is true despite that fact that a Dolly Varden run in Lime Creek does exist and the probability of recolonisation of Lime Creek by coho salmon is likely equal to the probability of recolonisation of Lime Creek by Dolly Varden given that individual adults of both species are known to stray from their natal streams;  The number of coho salmon rearing in Lime Creek is likely to represent a negligible proportion of the coho salmon run from which came; and  Coho salmon stocks in the Nass Area remain healthy (NLG 2010) indicating that current fishing levels are sustainable.

Table 6.7.3-19: Summary of Residual Cumulative Effects for Coho Salmon

Project Residual Cumulative Effect After Mitigation or Likelihood of Direction Phase Enhancement Occurrence C,O, D/C, PC Change in coho salmon growth and survival due to surface Negative Unlikely water quality in Lime Creek due to TMF seepage and past deposition of mine tailings in Lime Creek during previous mine operations C,O, D/C,PC Change in coho salmon growth and survival due to changes Negative Unlikely in habitat conditions in lower Lime Creek including straightening of Lime Creek during construction of the Kitsault townsite C,O, D/C, PC Change in coho salmon escapement due to reduce rearing Negative Unlikely habitat suitability in Lime Creek and increasing fishing pressure in commercial and recreational fisheries Note: C - construction; D/C - decommissioning and closure; O - operations; PC - post-closure

Because potential cumulative effects on coho salmon from the Kitsault Project and past, present, and reasonably foreseeable projects and land uses are unlikely to occur, no significance ratings were assigned.

6.7.3.12 Limitations

The assessment of potential project-specific and cumulative effects on coho salmon was dependent on results of quantitative modelling conducted to determine the potential

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KITSAULT MINE PROJECT ENVIRONMENTAL ASSESSMENT FRESHWATER AQUATIC RESOURCES changes in surface water quality and stream flows and on qualitative assessment of the potential effects of changes in water temperatures and benthic invertebrates in Lime Creek. Models are simplified abstractions of reality. They are useful because they provide a means of predicting future conditions that would otherwise not be possible without actually imposing the effect on the environment and monitoring changes in the receptors. As such, the accuracy of any model’s predictions are dependent on the quality of the input data, the accuracy of calibrated model to predict existing conditions, and the number and validity of the assumptions included in the model.

Although all of the models used to predict changes in surface water quality and stream flows were calibrated using real data, each model had limitations on the available input data (e.g., using regional data sets to calibrate site-specific watershed models) and had necessary assumptions (e.g., all the dissolved metals remain in solution and do not form more complex compounds that would make them biologically unavailable) that may have affected the accuracy of the models to predict future conditions. The limitations and assumptions for each of these models are described in greater detail in Section 6.5 (Hydrology) and Section 6.6 (Surface Water Quality).

Most critically to the assessment of potential effects of the Project on coho salmon, was the uncertainty regarding the effect of the predicted exceedences of existing provincial and federal water quality guidelines for the protection of freshwater aquatic biota for a number of potential chemicals of concern (e.g., selenium, arsenic) in Lime Creek. Taken at face value, these predicted exceedences would result in significant adverse effects to individual coho salmon health, growth, and survival, and to the aquatic foodwebs upon which they depend. However, as the assessment above explains, some of these guidelines may be overly protective and site-specific water quality guidelines may be more appropriate. Methods to arrive at some these alternative site-specific water quality guidelines have been provided in this assessment. The BC MOE and the CCME acknowledge that site-specific water quality guidelines for certain chemicals of concern may be more appropriate than existing provincial and federal guidelines depending on site-specific conditions. Both agencies provide guidance on how these guidelines could be derived (McDonald et al. 1997; CCME 2007).

Therefore, because the assessment of potential residual effects on coho salmon due to predicted water quality changes in Lime Creek during the Project depends on the accuracy of the water quality modeling and on the assertion that existing provincial and federal water quality objectives for the protection of freshwater aquatic biota are overly protective for many chemicals of concerns with predicted exceedences, the accuracy and acceptability of the assessment of this residual Project effect on rainbow trout is open to debate. That said, the proponent is committed to working with Environment Canada, the BC Ministry of Environment, and the NLG to derive more appropriate site-specific water quality objectives where warranted and to develop any additional mitigation measures necessary to avoid potential changes in surface water quality in Lime Creek downstream of the TMF.

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6.7.3.13 Conclusion

Potential effects to coho salmon parr in lower Lime Creek exist in the form of potential changes to their growth, health, and survival due to predicted changes in surface water quality, stream flows, water temperatures, and benthic macro-invertebrate drift in Lime Creek. Mitigation measures to reduce or eliminate these potential indirect effects on coho salmon include implementation of the mine water management plan, potential water treatment during post-closure, and adherence to any site-specific water quality objectives that may be promulgated by the proponent during consultations with Environment Canada, the BC Ministry of Environment and the Nisga’a Lisims Government.

While the mitigation measures proposed would not likely eliminate all potential effects to coho salmon parr, the significance of any residual effects was assessed to be not significant minor or negligible. These significance ratings were based on the facts that each indirect potential effect would likely have a low magnitude, local effect and because the potential residual effect only had the potential to effect individual coho salmon and not to affect an andromous run of coho salmon using Lime Creek for spawning. Thus, the ecological context for all potential residual effects of the Project on coho salmon parr was considered low.

Potential cumulative effects to coho salmon due to potential residual effects of the Project and potential residual effects of other past, present, or reasonably foreseeable future project or land uses were considered negligible. This included potential cumulative effects the deposit of mine tailings in Lime Creek and the straightening of the lower reach of Lime Creek during construction of the town of Kitsault because it is unlikely that a coho salmon run ever existed in Lime Creek. Similarly, no potential cumulative effect on coho salmon would occur from potential residual effects of the Kitsault Project and from on-going or future commercial or recreational fishing because the coho salmon parr found in lower Lime Creek represent only a negligible portion of the coho salmon stock(s) from which they were spawned and because current coho salmon stocks in the north coast of BC appear to be healthy, suggesting that they are not being overharvested.

6.7.4 Rainbow Trout 6.7.4.1 Introduction

The selection of rainbow trout as a VC was based on the presence of naturalised (i.e., previously stocked), resident populations of rainbow trout in the Clary Creek watershed, the potential interaction of the Project with these populations due to encroachment of the Kitsault Project into the headwaters of the Clary Creek watershed upstream of Clary Lake, and the importance of rainbow trout to Aboriginal groups, federal and provincial regulators, the public, and the proponent (see Table 6.7.1-1). Importantly, this VC does not extend to steelhead, the anadromous form of rainbow trout. This is because, as this assessment will show, the potential effects of the Project are restricted to Clary Creek upstream of the impassable waterfalls located approximately 250 metres upstream from the confluence of

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Clary Creek and the Illiance River. No potential effects on steelhead in the lower reach of Clary Creek downstream of these waterfalls or in the Illiance River are expected to occur.

Potential direct, indirect, and combined effects on rainbow trout may occur during all phases of the Project. Potential direct effects of the Project on rainbow trout include mortality of fish and eggs impinged or entrained in pumps placed in Clary Lake for potable water supply, fishing mortality from the mine construction and operations work force, alterations to fish passage at road crossings, and direct loss of fish habitat. Potential indirect effects on rainbow trout include changes in water quality due to tailings seepage, changes in water levels due to water withdrawals and changes in upstream catchment areas, changes in stream flows due to water diversions, and changes in benthic macro-invertebrate populations. Potential combined effects include the additive effects of potential changes in water quality, lake levels, stream flows, and critical habitat.

Potential cumulative effects of the Project on rainbow trout were assessed only for those direct, indirect, or combined effects that would likely result in a residual impact. Each of these residual impacts was then assessed for its potential to negatively affect rainbow trout by residual impacts from other past, present, or reasonably foreseeable Projects in the Clary Creek watershed. These projects are limited to past and current exploration of the Bell Moly deposit in the upper Clary Creek watershed.

6.7.4.2 Relevant Legislation and Legal Framework

Three levels of government have potential jurisdiction over rainbow trout potentially affected by the Kitsault Project. The relevant legislation and legal frameworks for each of these levels of government is described below.

6.7.4.2.1 Federal Section 20 of the federal Fisheries Act prohibits the obstruction of fish passage in any stream where it is determined that fish passage around the obstruction is in the public interest. Where an obstruction is unavoidable, a durable and efficient fish-way or canal around the obstruction shall be provided.

Section 32 of the federal Fisheries Act prohibits the destruction of fish by any means other than fishing except as authorised by Fisheries and Oceans Canada. Fish, as defined in the Fisheries Act, includes: 1) parts of fish; 2) shellfish, crustaceans, marine animals, and any parts of shellfish, crustaceans, or marine animals; and 3) the eggs, sperm, spawn, larvae, spat, and juvenile stages of fish, shellfish, crustaceans, and marine animals. Thus, for the purposes of the Kitsault Project and its effects on Rainbow trout, any Project component or activity that would result in the killing of Rainbow trout eggs, juveniles, or adult fish is prohibited by law.

Section 35(1) of the federal Fisheries Act prohibits the harmful alteration, disruption, or destruction (HADD) of fish habitat in Canada. Such a HADD is defined as “any change in fish habitat that reduces its capacity to support one or more life processes of fish” (DFO

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1998). Fish habitat, as defined in the Fisheries Act, is “spawning grounds and nursery, rearing, food supply, and migration areas on which fish depend directly or indirectly in order to carry out their life processes”. By this definition, fish habitat includes areas that currently produce fish, area that could potentially produce fish, or areas that provide the nutrients, water, or food supply to fish-producing habitat downstream.

Section 35(2) of the Fisheries Act allows a HADD of fish habitat if it is authorised by Fisheries and Oceans Canada (DFO). Such an authorisation would be issued by DFO only if it is satisfied that its guiding principle for the management of fish habitat in Canada would be met, that is there would be “no-net-loss (NNL) of productive capacity of fish habitat”.

The NNL guiding principle strives to avoid a net loss of productive capacity of fish habitat as a result of development projects by requiring the proponent to avoid any loss or harmful alteration by re-designing or relocating the project or mitigating the impacts where relocation or redesign is not possible. If none of these options are possible, compensation for the unavoidable habitat losses or harmful alterations is required.

The proponent would require a Section 35(2) Authorisation from DFO for any unavoidable HADD of fish habitat in the Clary Creek watershed where Rainbow trout are known to reside. Any such HADDs would require a fish habitat compensation plan that meets DFO’s “no-net-loss” guiding principle.

Section 36(3) of the Fisheries Act prohibits “the deposit of a deleterious substance of any type in waters frequented by fish or in any place, under any conditions, where the deleterious substance may enter any such water”. A deleterious substance is defined in the Fisheries Act as “any substance that, if added to any water, would degrade or alter, or form part of a process of degradation or alteration, of the quality of that water so that it is rendered, or is likely to be rendered, deleterious to fish or fish habitat or to the use by man of fish that frequent that water”. Thus, for the purposes of the Kitsault Project and its effects on rainbow trout, Section 36(3) of the Fisheries Act effectively prohibits the deposit of any deleterious substances in the Clary Creek watershed in quantities or toxicity sufficient to adversely affect the growth, health, survival, and reproduction of rainbow trout.

Rainbow trout are not listed on any of the schedules in the federal Species at Risk Act (SARA). They are not considered threatened, endangered, or at risk in Canada by the Committee on the Status of Endangered Wildlife in Canada (COSEWIC).

6.7.4.2.2 Provincial The province of British Columbia is responsible for the management of freshwater fish and fish habitat in BC. While this responsibility largely surrounds the management of fisheries for their sustained recreational use, the province has enacted legislation and various regulations that serve to protect and manage fish habitat. These legal devices include:

 Wildlife Act: fish are defined as “wildlife” for the provisions of the Act that provide for the designation of wildlife management areas and their protection. The Act also

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provides for the acquisition of land or improvements for the management and protection of fish;  Fish Protection Act: provides authority to consider impacts to fish and fish habitat before approving new or renewing existing water licenses and before issuing approvals for working in or near a stream; ensures sufficient water for fish when making decisions about licenses or approvals under the Water Act; allows the listing of streams with recognised fish values as being sensitive to water withdrawals; protects riparian areas through provisions of the Riparian Areas Regulation;  Riparian Areas Regulation: requires Qualified Environmental Professionals to assess riparian habitat, develop mitigation measures, and avoid impacts from development to fish and fish habitat;  Water Act: allows for effects to fish and fish habitat through the diversion or storage of water and to water in and about a stream; the Water Act has been amended for consistency with the Fish Protection Act; and  Forest and Range Protection Act: provides guidance on discretionary and mandatory Riparian Management Areas around fish bearing streams, lakes, and wetlands; provides guidance on size of harvestable forest areas and the rate at which wood can be removed from a watershed; and provides regulations on road building.

Despite these legal devices, the provincial government of BC does not have constitutional authority over fish habitat in BC. Instead, the provincial government provides only an advisory role to DFO in regards to when fish or fish habitat can be destroyed or altered and what would be required to ensure that “no-net-loss of the productive capacity of fish habitat” is achieved. This responsibility rests solely with DFO.

6.7.4.2.3 Nisga’a Lisims Government The Nisga’a Final Agreement (NFA) states “the Minister is responsible for the management of fisheries and fish habitat” with the Minister being defined as either the federal or provincial government. However, the NFA goes on to state that “fisheries management may involve the consideration of issues on a regional or watershed basis”. If Canada or British Columbia proposes to establish fisheries management advisory bodies for areas that include any part of the Nass Area, Canada or British Columbia will consult with the Nisga’a Nation in developing those bodies and, if appropriate, will provide for the participation of the Nisga’a Nation in those bodies.” This indicates that while the authority over fish habitat remains with Canada and the province, they do have a duty to consult on fish habitat issues within the Nisga’a traditional territory.

6.7.4.3 Spatial Boundaries

A description of and rationale for the Local Study Area (LSA), Regional Study Area (RSA), and cumulative effects study area (CESA) for rainbow trout is provided in the sections below.

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6.7.4.3.1 Local Study Area The Local Study Area (LSA) for rainbow trout was restricted to the Clary Creek watershed upstream of the Clary Lake outlet to Lake 901 and Lake 493 (Figure 6.7.4-1). This LSA was selected because it is the only portion of the Clary Creek watershed where potential direct effects (i.e., direct mortality of individuals or direct habitat loss) to rainbow trout from the Kitsault Project could occur. The LSA for rainbow trout includes the following lakes and streams where potential direct effects of the Project on rainbow trout could occur:

 Clary Lake: Lake with naturalised rainbow trout population that would be the source of potable water for Project. Lake directly downstream of Lake 901;  Lake 901: Lake with naturalised rainbow trout population directly downstream of northeast embankment of TMF;  Lake 901 outlet: unnamed stream that drains Lake 901 to Clary Creek upstream of Clary Lake;  Lake 493: potential direct effect on fish habitat and rainbow trout due to partial diversion of Lake 493 outflows flows to Lake 901 to mitigate potential flow reductions, water quality changes, and lake level fluctuations; and  Clary Creek from Clary Lake to Lake 493: potential direct effects on habitat and rainbow trout in creek downstream of Lake 493 due to partial diversion of Lake 493 outflows to Lake 901.

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472000 474000 476000 478000 480000 482000 484000 486000 Legend Access Road 6150000 6150000 Transmission Line Stream THEOPHILUS CREEK Waterbody ILLIANCE RIVER Mine Footprint FOXY CREEK Rainbow Trout Local Study Area Rainbow Trout Regional Study Area MORLEY CREEK Rainbow Trout Cumulative Effect Study Area 6148000 6148000 NCE RIVER ILLA

CLARY CREEK

KITSAULT

6146000 D) 6146000 TOWNSITE ROA ARM ICE ALASKA AL R ( FS LT CLARY KEY MAP AU S LAKE IT NORTHWEST TERRITORIES K YUKON

L IM Fort Nelson E Juneau C RE BRITISH COLUMBIA ALBERTA EK KILLAM LAKE Fort St. John LAKE LAKE Stewart #901 #493 Project Location

6144000 6144000 Edmonton Kitimat Prince George

Calgary

Kamloops PATSY LAKE Kelowna

Vancouver

Victoria UNITED STATES

Scale:1:50,000 UNITED STATES 1 0.5 0 1 6142000 6142000 K E E Kilometres R C Y S T A P LIME CREEK Reference 1. Base Data Geobase 1:20,000 (TRIM) Land and Resource Data Warehouse 1:20,000 (TRIM) KSI GWINHAT'AL 2: Kitsault Mine General Layout Supplied by AMEC and Knight Piesold December 2010

CLIENT: Avanti Kitsault Mine Ltd.

PROJECT: 6140000 6140000 Kitsault Mine Project Rainbow Trout Local, Regional and Cumulative Effect Study Areas

DATE: ANALYST: November 2011 MY Figure

JOB No: QA/QC: PDF FILE: VE51988 BH 10-50-104_rainbow_study_area.pdf

GIS FILE: 6138000 6138000 10-50-104.mxd

PROJECTION: DATUM: 472000 474000 476000 478000 480000 482000 484000 486000 UTM Zone 9 NAD83 Y:\GIS\Projects\VE\VE51988_Kitsault\Mapping\10_fisheries-aquatics\Baseline\10-50-0104.mxd