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Osler, Hoskin & Harcourt LLP Suite 2500, TransCanada Tower 450 – 1st Street S.W. Calgary, Alberta, Canada T2P 5H1 403.260.7000 MAIN 403.260.7024 FACSIMILE Calgary Martin Ignasiak November 26, 2020 <contact information removed> Toronto Our Matter Number: 1167150 Montréal SENT BY ELECTRONIC MAIL Ottawa Grassy Mountain Coal Project Joint Review Panel Impact Assessment Agency Vancouver 160 Elgin Street, 22nd Floor New York Place Bell Canada Ottawa, ON K1A 0H3 Attention: Alex Bolton, Chair, Joint Review Panel Dear Mr. Bolton: Re: Benga Mining Limited (“Benga”) Grassy Mountain Coal Project (“Project”) CEAA Reference No. 80101 Response to Undertakings #24 and #25 We write to provide Benga’s response to undertakings #24 and #25, given in the public hearing for the above noted Project. Undertaking #24 Undertaking #24: Confirm whether any confidentiality restrictions apply to the report regarding the expansion of the Yellowhead Tower Mine, referenced by Mr. John Kansas in cross-examination on November 25, 2020, and if there are no restrictions, provide a copy of the report. Benga’s Response: Attached at Appendix “A” is a copy of the report referenced by Mr. Kansas, titled “Mercoal West - Yellowhead Tower Mine Extension Project: Ungulate, Small Mammal, Avifauna, Amphibian Assessment”. Status: Complete Undertaking #25 Undertaking #25: Provide literature regarding the success of bat boxes utilized for maternity roosting. Benga’s Response: Attached at Appendix “B” is the following paper: Niels Rueegger, “Bat boxes — a review of their use and application, past, present and future” (2016), 18(1) Acta Chiropterologica 279. Further reference to the use of bat boxes for the Little Brown LEGAL_CAL:15115031.2 Myotis, specifically, is made in the Recovery Strategy for the Little Brown Myotis (Myotis lucifugus), the Northern Myotis (Myotis septentrionalis), and the Tri-colored Bat (Perimyotis subflavus) in Canada (2018), located on the record at CIAR 904 (PDF 30 and 46). Status: Complete Conclusion We assume the above responses satisfy the undertakings given. Yours truly, <Original signed by> Martin Ignasiak cc. Gary Houston Mike Bartlett LEGAL_CAL:15115031.2 Appendix “A” LEGAL_CAL:15115031.2 Mercoal West - Yellowhead Tower Mine Extension Project: Ungulate, Small Mammal, Avifauna, Amphibian Assessment February 2008 Prepared by Bighorn Wildlife Technologies Ltd. 176 Moberly Dr. Hinton AB T7V 1Z1 Prepared for Coal Valley Resources Inc. Bag Service 5000 Edson, AB T7E 1W1 Bighorn Wildlife Technologies Ltd. February 2008 i Bighorn Wildlife Technologies Ltd. February 2008 ii EXECUTIVE SUMMARY This report presents the results of an environmental and cumulative impact assessment of a proposed mine extension by Coal Valley Resources Inc. on ungulates, small mammals, avifauna and amphibians. The Mercoal West and Yellowhead Tower Mine Extension Project (MW-YT Mine Extension Project) is located near Robb, Alberta and involves two Principle Development Areas (PDAs) and an adjoining walk road. A Regional Study Area (RSA) has also been identified which includes seven Bear Management Units (BMUs) defined by the Foothills Model Forest Grizzly Bear project. The MW-YT mine permit boundary encloses a 3,546 ha local study area (LSA). Mercoal West (MW) is almost twice as large (3,546 ha) as Yellowhead Tower and the walk road (1,872 ha). Various wildlife inventories were carried out on the MW and YT LSA between 2004 and 2007. Previous inventories undertaken on the reclaimed part of Coal Valley Mine (Bighorn 1995 and 1999) were updated by means of aerial ungulate survey, breeding bird survey, amphibian monitoring and a monthly ground survey conducted April 2006 to March 2007. MW is dominated by Lodgepole Pine-Black Spruce / Labrador Tea (38%) and various fen (19%) habitats. YT is dominated by Lodgepole Pine / Tall Bilberry (30%), and Lodgepole Pine-Black Spruce / Labrador Tea (18%) habitats. Mixed wood habitats comprise about 10% of the YT but were barely represented in MW (1%). Cutblocks in various types of pine habitat represented about 16% of MW but were not present in YT. Hard surface right-of-ways comprised 4.0% and 1.7% of YT and MW respectively. Mixed wood habitats are a feature of the Lovett Ridge on which parts of the operating the Coal Valley Mine and proposed YT are located. The Lovett Ridge supports populations of moose, elk and deer at higher densities than the surrounding coniferous forest (Alberta Forestry, Lands and Wildlife 1990). Elk were the most abundant ungulate (133) observed during a January 2007 aerial survey of the MW-YT and the Coal Valley Mine area, followed by white-tailed deer (110), moose (64), and mule deer (9). Survey results indicate that elk numbers have not increased since 1996/97, moose numbers have declined, mule deer numbers are lower and white-tailed deer numbers have substantially increased. Elk distribution in 2007 was largely restricted to the Coal Valley Mine. They were not found scattered through the mixed wood habitats of the Lovett Ridge as in 1996/97. Moose bull:100 cow and calf:100 cow ratios were extremely low (9 bull:100 cow and 7 calf:100 cow). Low calf moose numbers are generally attributed to wolf predation, lack of forage, increased access leading to increased hunting and die-off related to ticks. Alberta Fish and Wildlife Division reported a significant decline in the moose population in WMU340 between 1996 and 2004 resulting in a 50% decrease in the eight years. Increased road access that enhances regulated and unregulated hunting opportunities, an overestimate of the moose population for several years resulting in too high bull harvest goals, and a more accurate survey in 2004 over 1996 were cited as reasons for the decline (Ficht and Smith 2004). Decreased numbers of mule deer observed during the annual ground survey of the Coal Valley Mine in 2007 as compared to 1997 suggests a drop in mule deer numbers since 1997. White-tailed deer numbers have increased on the Lovett Ridge, and in west-central Alberta. Pellet-group surveys indicated that two habitats (Lodgepole Pine-Black Spruce / Labrador Tea and Lodgepole Pine / Tall Bilberry) comprising 50% of the disturbed area of the MW-YT LSA were used at levels less than availability by moose, elk and deer. Ungulates showed preference Bighorn Wildlife Technologies Ltd. February 2008 iii for a variety of forest community types that comprised 29% of the area to be disturbed in the LSA. These were: Mixed Wood / Hairy Wild Rye (elk, moose, deer), Mixed Wood / Tall Bilberry (elk and deer), Trembling Aspen / Hairy Wild Rye (moose and deer), Lodgepole Pine / Hairy Wild Rye (elk and moose), Black & White Spruce / Labrador Tea (moose), Black & White Spruce-Lodgepole Pine / Bracted Honeysuckle (deer), White Spruce / Tall Bilberry (deer) and Treed Rich Fen (moose). Total species identified in the RSA, MW LSA, YT LSA, and the reclaimed Coal Valley Mine (CV Mine) are: • RSA = 244 species (5 ungulates, 29 small mammals, 205 birds, 4 amphibians) • CV Mine = 162 species (5 ungulates, 12 small mammals, 142 birds, 3 amphibians) • YT LSA = 87 species (3 ungulates, 10 small mammals, 72 birds, 2 amphibians) • MW LSA = 71 species (4 ungulates, 9 small mammals, 56 birds, 2 amphibians) Elk, moose, mule deer, white-tailed deer, small mammals, breeding birds, raptors, and amphibians were identified as Valued Environmental Components. Initial displacement of the existing wildlife community on the MW-YT LSA by active mining will be followed quickly by colonization of species appropriate to the stage of succession reached by the regenerated plant community. Wildlife species composition will be similar, but changed, in response to the addition of lakes, ponds and other habitat features into the final landscape. Species composition of the wildlife communities will change over time in response to vegetation development and maturation. Because the MW-YT development is relatively narrow and small in area, species representative of the initially undisturbed habitats are expected to continue to be represented in the final landscape. Designing complexity into the landscape (lakes, ponds, wetlands, variety in vegetation communities and topography) will support wildlife diversity. With mitigation, including reclamation and monitoring, there were no significant impacts for the MW-YT Mine Extension Project on ungulates, small mammals, breeding birds, raptors, and amphibians. The residual impact ratings assume: human recreation and access is managed to provide security for wildlife especially in the vicinity of the Lovett Ridge, diverse habitat types are established, structural complexity is established in reclaimed forest types, deciduous shrubs are incorporated into the reclaimed landscape, and industrial development in the region promotes best management practices that ensure long term viable wildlife populations. Cumulative effects assessment (CEA) was carried out for elk, moose, and terrestrial avifauna in the RSA (Figure 1.1). The RSA encompasses approximately 2,658.5 km. The CEA is based on a land class map (LC20 RSA) developed by Geographic Dynamics Corporation (2007). Development features in the RSA were identified (e.g., pipelines, wellsites, roads) and the 20 land classes were modified to predict changing conditions caused by mining, forest harvesting, mountain pine beetle, and climate change, for 10, 25 and 50 years (Section 5.1.4.3, GDC 2007). The MW-YT Mine Extension Project will increase regional elk habitat suitability for winter forage by year 10 at which time elk are expected to colonize this new habitat resulting in a potential increase in the regional elk population. More use of the YT LSA by elk is expected than of the MW LSA because of habitat limitations. Once reclamation is complete, this effect should last 25-50 years at which time, large areas of reclamation on the current and future Coal Valley Mine operations and on the MW-YT LSA become closed forest regeneration. At Year 50, elk habitat suitability will be reduced by 10% without MW-YT and 11% with MW-YT. Implementing appropriate mitigation for elk (Section 12.2) including establishing a variety of vegetation Bighorn Wildlife Technologies Ltd.

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