4.0 CONSULTATION SUMMARY 4.1 Introduction IAMGOLD Recognizes
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4.0 CONSULTATION SUMMARY 4.1 Introduction IAMGOLD recognizes that an important part of the Project permitting and planning process is proactive consultation with potentially affected and interested stakeholders, Aboriginal communities and government agencies. Consultation to date has involved informing and engaging these respective parties about the development of the Project, including the environmental assessment (EA) process, responding to their interests and concerns, and continuing to build and maintain positive relationships. This has been and is currently being achieved by creating avenues for dialogue and information exchange (verbal and written), and by fostering an ongoing relationship between IAMGOLD and these stakeholder and Aboriginal groups. As outlined in Chapter 2, IAMGOLD is required to meet the requirements of both Federal and Provincial EA processes which includes the consultation of local stakeholders, government agencies and potentially affected Aboriginal communities. This chapter will capture how IAMGOLD has met these requirements, or where applicable, gone beyond these requirements to ensure adequate and meaningful consultation. The Canadian Environmental Assessment Agency (the Agency) developed Environmental Impact Statement (EIS) Guidelines for the Côté Gold Project for the preparation of an EIS under the Canadian Environmental Assessment Act, 2012. These Guidelines were approved by the Agency on July 9, 2013 and outline public participation and Aboriginal consultation requirements and expectations. IAMGOLD is required to ensure that Aboriginal people and groups who may be affected by the Project have access to information required to understand the proposed Project and identify potential impacts on their rights and interests. The Crown will assess the adequacy of consultation with Aboriginal Groups, as set out in the Updated Guidelines for Federal Officials to Fulfill the Duty to Consult (AANDC, 2011) and using the information gathered throughout the EA process, will identify potential Project-related impacts on Aboriginal or Treaty rights and related interests (potential or established). Additionally, Project consultation and engagement activities have been undertaken and described herein under the direction of the Province of Ontario’s relevant Codes of Practice, namely Consultation in Ontario’s Environmental Assessment Process (January 2014) and Preparing and Reviewing Environmental Assessments in Ontario (January 2014). IAMGOLD and the Federal and Provincial government agencies recognize opportunities for synergy in planning and implementing stakeholder engagement and consultation for their respective EA processes, and have attempted to align consultation activities and documentation to the extent practical. Similarly, the intention with this chapter is to demonstrate how IAMGOLD has met internal objectives for consultation, and the Federal and Provincial requirements for consultation in a coordinated document. The description of consultation activities outlined in this chapter were initially scoped in IAMGOLD’s Stakeholder Consultation Plan and Aboriginal Consultation Plan (AMEC, 2013a and 2013b). These plans have been detailed, and included as Côté Gold Project Amended EIS / Final Environmental Assessment Report January 2015 Project #TC121522 Page 4-1 part of IAMGOLD’s submission of the approved Project Description (PD) and the Proposed Terms of Reference (ToR). Copies of these plans are located in Appendix D-1. The consultation plans were developed based on guidance provided in the relevant Provincial Codes of Practice and Federal EIS Guidelines noted previously. These plans also follow IAMGOLD’s standards and best practices for community relations and consider Aboriginal feedback on appropriate levels of engagement for Aboriginal groups. IAMGOLD has been, and will continue to seek input on these plans to modify them to the individual consultation preferences of each community. While IAMGOLD has made all efforts, to the extent practicable, to coordinate the Federal and Provincial processes, the key milestones in these processes are divergent in some respects. However, for readability of this document, IAMGOLD has divided key consultation activities into two main time periods which coincide with EA milestones in the Provincial process: pre-ToR Approval (June 2012 – January 14, 2014), and during EA preparation (January 15, 2014 – September 30, 2014). Appendix D contains detailed records of consultation, comments and concerns raised throughout the EA process, as well as copies of Notices and other key Project-related correspondence. 4.2 Overview of Key Consultation Milestones Graphic 4-1 depicts the major milestones of the Federal and Provincial EA processes. The intention of this graphic is to help readers understand what consultation activities have occurred during various phases of the EA process. 4.2.1 Consultation as an Iterative and Ongoing Process The time periods outlined above, and Graphic 4-1 reflect the milestones the Project has met, based largely on timeframes laid out by the Federal and Provincial EA processes. IAMGOLD, however, recognizes that different stakeholders and Aboriginal communities may choose to participate in consultation on the Project outside of these given timeframes. IAMGOLD is open to consultation with stakeholders and Aboriginal communities at any time, and have met with different groups at various points throughout the EA process, to ensure that the interests and needs of these communities are being taken into consideration and responded to. Therefore, while Graphic 4-1 is meant to provide readers with an understanding of what consultation activities occurred during particular stages of the EA process, it should be understood that some consultation activities with communities do not necessarily reflect the general consultation goals of that time period, but rather the consultation interests of the community at that particular time. Further details of all consultation activities can be found in Appendix D. Côté Gold Project Amended EIS / Final Environmental Assessment Report January 2015 Project #TC121522 Page 4-2 Graphic 4-1: Overview of Key Consultation Milestones Provincial EA Process Federal EA Process May 2013: Notice of Commencement of March 2013: Submission of Project Terms of Reference Description May 2013: Notice of Environmental July 2013: Notice of Submission of Terms Assessment Determination - CEAA issues of Reference Draft EIS Guidelines to IAMGOLD January 14, 2013: Project Terms of July 9, 2013: Final EIS Guidelines issued Reference Approval by CEAA to IAMGOLD February 2014: Notice of May 2014: Submission of Environmental Commencement of Environmental Impact Statement and Successful Assessment Conformity Review June 2014: Submission of, and June 2014: Consultation on EIS/Draft EA consultation on Draft Environmental with local Aboriginal communities, Assessment Report stakeholders and government agencies 4.2.2 Goals of Consultation The objective of consultation for the Project is to meet both Federal and Provincial requirements for consultation, and to provide stakeholders, Aboriginal communities and government agencies with information about, and gather their feedback on a number of issues. As a result, IAMGOLD established the following goals for consultation: • introduce IAMGOLD to area stakeholders, Aboriginal groups and government agencies; • understand Aboriginal interests and treaty rights in the area that have the potential to be affected by the Project; • establish positive working relationships with stakeholders, Aboriginal groups and government agencies; • share information and gather feedback on the draft and final PD; • share information and gather feedback on the draft and proposed ToR (including various alternatives); • share information about the Federal and Provincial EA processes; • share information and gather feedback on the EIS / Draft EA Report; • provide status updates on exploration and mining-related activities; Côté Gold Project Amended EIS / Final Environmental Assessment Report January 2015 Project #TC121522 Page 4-3 • ensure stakeholders have an appropriate opportunity to understand the proposed Project and identify potential environmental effects by reviewing and gathering feedback on: − results of baseline studies and/or other studies; − alternatives and evaluation methods; − final selection of criteria indicators; − results of the selection of the preferred alternatives; − potential environmental effects and mitigation measures; − proposed monitoring and management plans; and − decommissioning / closure plan. • demonstrate and discuss how comments heard previously were addressed through Project designs or management practices to reduce or avoid the effects; • provide an explanation of why the proposed Project cannot be modified to reduce or avoid the effects; • discuss appropriate ways that residual effects could be managed; • document and respond to any issues or concerns raised by stakeholders; and • meet all regulatory requirements for stakeholder consultation, to the extent possible. 4.3 Identification of Stakeholders and Aboriginal Groups Stakeholders, Aboriginal groups (First Nation and Métis) and government agencies who were expected to have an interest in the Project were identified during early consultation efforts. Interested and potentially affected stakeholders, Aboriginal groups and government agencies were identified using the following criteria: • proximity to the Project and potential for being