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Written Comments on Baffinland's Proposed Phase 2 Expansion

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Written Comments on Baffinland's Proposed Phase 2 Expansion Written Comments on Baffinland’s Proposed Phase 2 Expansion Hamlet of Clyde River and Nangmautaq Hunters and Trappers Association January 11, 2021 The Hamlet of Clyde River and Nangmautaq Hunters and Trappers Association (HTA) do not support the Phase 2 expansion in its current form. We believe that controversial development proposals like Phase 2 should not be permitted without clear and unequivocal support from both the Hamlets and HTAs in the most affected communities. In this case, Pond Inlet has the most to lose if this project moves forward. It is our understanding that neither the Mittimatalik HTO or the Hamlet of Pond Inlet support the Phase 2 proposal in its current form. The Hamlet of Clyde River and the Nangmautaq HTA have several outstanding concerns with the proposed expansion and its possible effects on our environment, community well-being, and Indigenous rights. We are concerned that the project will negativly affect our hunting lifestyle. Comments from hunters in Pond Inlet suggest that the Mary River project has already had significant effects on Inuit hunting. We are also not convinced that we will substantially benefit from the project. We are extremely disappointed with Baffinland’s record on Inuit employment and are not convinced that Phase 2 will increase Inuit employment numbers. Adaptive management The Hamlet of Clyde River and Nangmautaq HTA are concerned with the adaptive management approach at the Mary River mine. Instead of ‘set-in-stone’ mitigation measures, Baffinland can change its management plans. Several environmental working groups – with representatives from the federal government, Government of Nunavut, and Pond Inlet Hunters and Trappers Organization – provide advice about changes to management plans. The Inuit Certainty Agreement between Baffinland and the Qikiqtani Inuit Association will create new adaptive management structures, including an Inuit Committee to provide advice on adaptive management. The Hamlet and HTA are concerned that this approach to adaptive management will put our wildlife at risk. Specifically, we are concerned: • The environmental working groups are ineffective and dysfunctional. They are controlled by Baffinland and lack transparency. Only one HTA from the North Baffin region participates in the working groups. Other important aspects of Adaptive Management – including common objectives and relationships of trust – are absent. A report examining the problems with these working groups is appended to this written submission. • Many details in the adaptive management plan are incomplete. For example, there are no details about what sort of environmental effects will trigger a change in protection measures. It is also not clear what specific actions Baffinland will take if these environmental effects are observed. 1 Proposal for incremental expansion The Hamlet and HTA support the proposal from the Hamlet of Pond Inlet to gradually increase production at the Mary River project. Baffinland is proposing to quickly increase production from 6 million tonnes per year to 12 million tonnes per year. Instead, the Hamlet of Pond Inlet wants production to be increased in small increments. According to this proposal, Baffinland will only be able to increase production each year if it meets certain conditions. There must be no significant environmental effects and Baffinland must increase the proportion of Inuit employed at the Mary River mine. This gradual and controlled approach to mining development is endorsed by the North Baffin Regional Land Use Plan. It is also consistent with the principles of adaptive management. Steensby Inlet port and rail option The Hamlet and HTA are very concerned that Baffinland intends to use both Milne Inlet and Steensby Inlet to ship ore. Baffin Island would be cut in two by railways. This could have serious consequences for caribou hunting in our region. Even more concerning is the open-ended approval Baffinland has for the Steensby port and rail. Because there is no sunset clause in Baffinland’s approval for the Steensby project, it can decide to move forward whenever it wants. As the NIRB recognized in its report on the proposed Kiggavik uranium mine, it is unfair to our communities to have to live with this sort of uncertainty. Production rates In its proposal for Phase 2, Baffinland said it will increase shipping through Milne Inlet from 6 million tonnes per year to 12 million tonnes per year, with the possibility of 14.5 million tonnes in some years. However, the Hamlet and HTA are aware of documents filed with the American Securities and Exchange Commission, as well as a report by Moody’s, that claim it will ship 18 million tonnes of ore per year through Milne Inlet. These documents have been previously submitted to NIRB and placed on the public registry. This inconsistency between the production rates communicated to NIRB and production rates communicated to investors creates even more uncertainty about the future of this project. 2 Icebreaking shipping The Hamlet and HTA are opposed to icebreaking shipping in our region. We support the position of the Mittimatalik Hunters and Trappers Organization, which also opposes icebreaking shipping through Milne Inlet. We believe that icebreaking shipping will have serious effects on marine mammals and Inuit use of the sea ice. To be clear, we are not asking Baffinland to shorten the shipping season by increasing the number of ship transits in the open water season. We are asking Baffinland to use larger ships to ship the ore with fewer transits. If Baffinland cannot find enough large ships, they should produce less ore. Compensation for harvesters The Hamlet and HTA are concerned that hunters might not be properly compensated if the Mary River project causes negative effects on caribou and marine mammal hunting. The Inuit Certainty Agreement between Baffinland and the Qikiqtani Inuit Association provides for a Harvester Enabling program. Under this program, Baffinland will pay $750,000 each year for harvester support. This money will be divided among the affected Hunters and Trappers Associations. However, it is not clear that this money will be sufficient to compensate for disruptions caused by Baffinland’s activities. 3 .
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