Information Request 15.1

Vegetation

References:

EIS Guidelines - Section 2.6.1.7, p. 37 (PDF 42) EIS Main Report - Section 6.2.6.1.1, p. 6.73 (PDF 579) - Section 6.6.1.4.5, p. 6.212 (PDF 718)

Rationale:

Section 6.6.1.4.5 of the EIS states that a limited number of provincially and regionally rare plants will be lost within the Project footprint.

Information Request: Provide the distribution range for the rare plants that will potentially be affected by the Project. In light of the distribution ranges, re-examine the significance of the loss of the population of the rare plants on local, regional and provincial populations of the rare plants (i.e. address the issue of whether any of the plants are at the limit of their range).

Provide a discussion on the potential cumulative effects on rare plants from this Project and reasonably foreseeable future projects in the context of the distribution ranges.

SCI RESPONSE

For the assessment of rare plants, the Local Study Area is a 5 km radius around the project footprint and the Regional Study Area is Thunder Bay District for which there is a comprehensive list of plant species and status. A full understanding of the distribution of these species is hampered by the lack of botanical inventory and monitoring data at the local and regional scales.

Provincially rare plants generally have fewer than 80 occurrences in Ontario as determined by the Natural Heritage Information Centre (S1 to S3; NHIC 2013). Regionally rare plants are rare in Thunder Bay District (TBFN 2003) (typically with 5 or fewer occurrences in the district), but are common elsewhere in Ontario. Additional occurrences have been documented for many of the species since the publication of TBFN 2003.

None of the provincially rare or regionally rare species is listed under endangered species legislation. The distribution, potential impacts, and conservation significance of these species occurrences is discussed in Table 1 to Table 3.

Of the 16 provincially or regionally rare plant species on the Project Site, nine do not occur within the project footprint and no impacts are expected (Table 1, Table 2). Two species (Common Ragweed and Narrow-leaved Cattail) occur within the footprint, but are weedy and are expected to disperse to disturbed habitats within the footprint. Of the four remaining species, three (Alga Pondweed, Oakes' Pondweed, and Northern St. Johnswort) occur in the small headwater lakes near the centre of the project site, which will be removed during Project development/operations. Alga Pondweed and Oakes' Pondweed are aquatic species and development of the Project would result in regionally significant impacts with an anticipated loss of one of about four documented occurrences and two of five known occurrences in Thunder Bay District respectively, in the absence of mitigation Northern St. Johnswort is a shoreline species and are more common in the region and impacts are assessed to be locally significant.

The Broad-lipped Twayblade inhabits moist sites along streams and lake shores (NatureServe 2013). Loss of this occurrence is assessed to be locally significant.

Proposed Mitigation

The following mitigation is recommended for Alga Pondweed and Oakes' Pondweed: 1. Conduct further inventory of nearby waterbodies and transplant Alga Pondweed and Oakes' Pondweed from existing habitat to appropriate small lakes nearby. 2. Minimize disturbance within the Project Footprint.

Residual Effects

The significance of environmental effects are summarized in Table 3. With mitigation, the residual effects are expected to be insignificant.

Cumulative Effects

Little is known about the distribution or abundance of these species in the LSA or RSA due to the lack of botanical inventory in inland areas north of Lake Superior. Alga Pondweed and Northern St. Johnswort were previously documented in the “Peninsula” area, roughly corresponding to the LSA (Soper et al. 1989). Oakes' Pondweed and Broad-lipped Twayblade were not and may be less common or more restricted in their distribution.

Historical human activity has probably had little influence on the habitat of Alga Pondweed, Oakes’ Pondweed, and Northern St. Johnswort. These small isolated headwater lakes have few development pressures and are outside the direct influence of forest management activities. Future mining developments could destroy habitat, but the cumulative impacts are very difficult to assess given the uncertainly of those projects proceeding and the poorly known distribution of the plant species. Broad-lipped Twayblade inhabits moist sites along streams and lake shores and may be more vulnerable to the impacts of forest management and mining exploration.

Given the insignificant residual effects predicted from the Project, however, no material cumulative impacts are anticipated.

Table 1: Provincially rare plant species. Distribution information from Argus et al. White (1982-1987), Coffin and Pfannmuller (1988), Oldham and Brinker (2009).

Species and S-rank Distribution Range Limit of Observed in Comment Range Footprint Appalachian Firmoss Eastern North America from Labrador, Yes No Found on the shore of Bamoos Lake Huperzia appalachiana south through the Appalachians and east to where no impacts are anticipated. (= H. appressa) Lake Superior. Most Ontario records are on the north shore of Lake Superior and in the Hudson Bay area. Numerous records in Thunder Bay District. Alpine Woodsia Widespread across northern Canada, south Yes No The only observed location is about Woodsia alpina through the Maritimes and to Lake 200 m outside the project footprint Winnipeg. In Ontario largely confined to the and no impacts are anticipated. north shore of Lake Superior. Braun's Holly Fern Northeastern North America from Yes No The only observed location is about Polystichum braunii Newfoundland, south to New York, and 750 m outside the project footprint west through the Great Lakes to the and no impacts are anticipated. Thunder Bay area. In Ontario, occurs primarily near Lake Superior. Alga Pondweed Eastern North America from Newfoundland Yes Yes 25% (1 of 4) of the occurrences in Potamogeton confervoides to Wisconsin and south to North Carolina. RSA (Lakehead University Herbarium Highly disjunct within this range. In Ontario and author’s databases) will be found in the Georgian Bay area and impacted. The site is within the northeast shore of Lake Superior. process solids management area. About 3 ha of habitat will be lost when this small lake is filled in. This species is near the western limit of its Ontario range here. There are 13 known occurrences province wide, although the species is aquatic and rather obscure, so may be more widespread than known. Shore Plantain Eastern North America from Nova Scotia No No Found on the shore of Hare Lake Littorella americana through the Ottawa area and upper Great where no impacts are anticipated. Lakes to Minnesota and Lake of the Woods. Whitlowgrass Widespread in northern North America from Yes No Found on Bamoos Lake where no Draba cana Alaska to Newfoundland. In Ontario, impacts are anticipated. largely restricted to the Bruce Peninsula and the north shore of Lake Superior. Recently designated as provincially rare (S3) (Oldham and Brinker 2009).

Table 2: Regionally rare plant species. Distribution information from Dore and McNeill (1980), FNA (1993+), Gillett and Robson (1981), Scoggan (1978-1979), Whiting and Catling (1986), Northern Ontario Plants Database (2013).

Species Distribution Range Limit of Observed Comment Range in Footprint Common Ragweed Widespread across much of No Yes Although locally uncommon north of Lake Superior, this Ambrosia artemisiifolia North America. Common in species is common and weedy in much of Ontario and southern Ontario, becoming likely to colonize roadsides and other disturbed ground local north of Lake Superior. within the project footprint. Northern St. Johnswort Widespread in eastern North No Yes 7% (1 of 14) of the known occurrences in RSA Hypericum mutilum America from Newfoundland to (Lakehead University Herbarium and author’s northwestern Ontario, south to databases) will be impacted. The location is within the Texas and Florida. In Ontario, process solids management area. Shoreline habitat occurs in the southern part of along this small lake will be lost when it is filled in. the province, west and north to the Atikokan area. Broad-lipped Twayblade Northeastern North America Yes Yes 14% (1 of 7) of the known occurrences in RSA Listera convallarioides from Newfoundland west (Lakehead University Herbarium and author’s through the upper Great Lakes databases) will be impacted. to northwestern Ontario. Also in the western cordillera from BC to southern California. In Ontario occurs mainly on the Bruce Peninsula, Manitoulin I, and the north shore of Lake Superior to Lake Nipigon. Wood Millet Grass Northeastern North America No No The two observed locations are at least 200 m from the Milium effusum from Newfoundland to southern project footprint and no impacts are anticipated. Manitoba south to South Dakota, Ohio, and Maryland. Throughout southern Ontario to the north shore of Lake Superior and west to Lake of the Woods. Small-flowered Evening Widespread across Canada. No No The only observed location is about 1000 m outside the Primrose Uncommon and local in project footprint and no impacts are anticipated. Oenothera parviflora northern Ontario, north to James Bay. Canadian Mountain Rice Widespread across Canada No No The only observed location is about 100 m outside the Species Distribution Range Limit of Observed Comment Range in Footprint Oryzopsis canadensis from BC to Nova Scotia and project footprint and no impacts are anticipated. south to California, Minnesota and New Hampshire. In Ontario, occurs in the Ottawa area, west to Lake Nipissing and the northeast shore of Lake Superior. Oakes' Pondweed Northeastern North America Yes Yes 40% (2 of 5) of the known occurrences in RSA are Potamogeton oakesianus from Newfoundland west to the within the process solids management area. About 3.5 northeast shore of Lake ha of habitat will be lost when these two small lakes are Superior and south to filled in. The species is aquatic and rather obscure, so Wisconsin and New Jersey. may be more widespread than known. Slender Pondweed Widespread across North No No The only observed location is about 100 m outside the Potamogeton pusillus America from Alaska to Nova project footprint and no impacts are anticipated Scotia, south to California and Virginia. In Ontario, north to the Fawn River. Narrow-leaved Cattail Widespread in eastern North No Yes This species is abundant in much of Ontario and Typha angustifolia America and spreading north spreading rapidly through northwestern Ontario. It is and west. Probably introduced likely to colonize shores of process water ponds. from Europe. Marsh Speedwell Widespread across North No No The only observed location is several hundred metres Veronica scutellata America from Alaska to outside the project footprint and no impacts are Newfoundland, south to anticipated California and Virginia. In Ontario, north to the Severn River.

Table 3: Significance of environmental impacts on rare plant species.

Species Nature Magnitude Spatial Timing Duration Reversibility Likelihood Mitigation Extent without Mitigation Alga Pondweed Negative Regional 3 ha Construction Permanent Irreversible Likely -Conduct further inventory to determine if there are additional occurrences within the Local Study Area. -Transplant Alga Pondweed and Oakes' Pondweed from existing habitat to unoccupied small lakes nearby. -Minimize disturbance within the Project Footprint Oakes' Pondweed Negative Regional 3.5 ha Construction Permanent Irreversible Likely Conduct further inventory to determine if there are additional occurrences within the Local Study Area. -Transplant Alga Pondweed and Oakes' Pondweed from existing habitat to unoccupied small lakes nearby. -Minimize disturbance within the Project Footprint Northern St. Johnswort Negative Local < 1 ha Construction Permanent Irreversible Likely -Minimize disturbance within the Project Footprint Broad-lipped Negative Local ~ 1 ha Construction Permanent Irreversible Likely -Minimize disturbance Twayblade within the Project Footprint

Literature Cited

Argus, G.W., K.M.Pryer, D.J. White, and C.J. Keddy. 1982-1987. Atlas of the rare vascular plants of Ontario. Four Parts. National Museum of Natural Sciences, Ottawa. (looseleaf).

Coffin, B. and L. Pfannmuller, eds. 1988. Minnesota’s Endangered Flora and Fauna. University of Minnesota Press, Minneapolis. Dore, W.G. and J. McNeill. 1980. Grasses of Ontario. Ottawa: Research Branch, Agriculture Canada, Monograph 26.

Flora of North America Editorial Committee, eds (FNA). 1993+. Flora of North America North of Mexico. 16+ vols. New York and Oxford. Vol. 1, 1993; vol. 2, 1993; vol. 3, 1997; vol. 4, 2003; vol. 5, 2005; vol. 7, 2010; vol. 8, 2009; vol. 19, 2006; vol. 20, 2006; vol. 21, 2006; vol. 22, 2000; vol. 23, 2002; vol. 24, 2007; vol. 25, 2003; vol. 26, 2002; vol. 27, 2007.

Gillett, J.M. and N.K.B. Robson 1981. The St. John's-Worts of Canada (Guttiferae). National Museums of Canada. Publications in Botany No. 11. Ottawa.

Natural Heritage Information Centre (NHIC). 2013. Website: http://nhic.mnr.gov.on.ca/. Accessed March 2013.

NatureServe. 2013. NatureServe Explorer: An online encyclopedia of life [web application]. Version 7.1. NatureServe, Arlington, Virginia. Available http://www.natureserve.org/explorer. (Accessed: March 27, 2013 ).

Northern Ontario Plants Database. 2013. Website: http://www.northernontarioflora.ca/ . Accessed March 2013.

Oldham, M. J., and Brinker, S. R. 2009. Rare Vascular Plants of Ontario, Fourth Edition. Natural Heritage Information Centre, Ontario Ministry of Natural Resources. Peterborough, Ontario. 188 pp.

Scoggan, H.J. 1978-1979. The flora of Canada. National Museum of Natural Sciences, Ottawa, ON. 4 vols.

Thunder Bay Field Naturalists (TBFN). 2003. Checklist of Vascular Plants of Thunder Bay District. Revised Edition. Thunder Bay Field Naturalists.

Whiting, R.E. and P.M. Catling. 1986. Orchids of Ontario. An Illustrated Guide. CanaColl Foundation.

Information Request 15.2

Current Use by Aboriginal Groups

References:

EIS Guidelines - Section 2.6.1.7, p. 37 (PDF 42) EIS Main Report - Section 2.6.6.3, p. 6.78 (PDF 584)

Rationale:

The EIS does not appear to include information on specific plant species used for traditional purposes by Aboriginal peoples.

Information Request: Describe the potential effects of the Project on specific plant species used for traditional purposes by Aboriginal peoples.

SCI RESPONSE

Information on plant species and use for traditional purposes by Aboriginal peoples is drawn from the EIS – Main Report (EcoMetrix et al. 2012), Supporting Information Document (SID) no. 24 – (Northern Bioscience 2009), SID no. 29 – (Golder 2009), and an interview program conducted with Members of Pic River First Nation (PRFN) in January 2013. Section 4.4.2 Early Agreements in the EIS – Main Report notes that Stillwater Canada Inc. (SCI) provided capacity funding to PRFN, Pic Mobert First Nation (PMFN), Pays Plat First Nation (PPFN), Red Sky Métis Independent Nation (RSMIN), Superior North Shore Metis Council through the Métis Nation of Ontario (MNO), and the Ontario Coalition of Aboriginal People (OCAP) and their local affiliate organization, the Jackfish Métis Association (Jackfish Métis), in order to confirm VECs and complete Traditional Knowledge (TK) and Traditional Land Use (TLU) studies. The TK and TLU documents associated with PMFN and PPFN have not yet been made available and were not reviewed in preparing this response, however SCI’s current understanding is that neither group makes regular use of the SSA or LSA for plant harvesting. This response provides information on the following topics: 1. Plant species identified at the Project site. 2. Plant species identified for traditional use by Aboriginal groups. 3. Summary of effects assessment conclusions on vegetation and plants. 4. Summary of effects assessment conclusions on Aboriginal country food use.

Plant Species Identified at the Project Site Section 5.6 of the EIS – Main Report (EcoMetrix Inc. et al. 2012), as well as several sections of SID no. 24 (Northern BioScience 2009) and SID no. 29 (Golder 2009), provide detailed information on the vegetation and plant species located in the Project Site. As noted in Section 5.9.1 of the EIS, the study areas used in the socio-economic and traditional land use assessments differ from those used to describe the biophysical attributes of the environment associated with the Project. Section 2.4 of the EIS describes the spatial boundaries used in the assessment in greater detail. The terrestrial environment related to plants is presented in Section 5.6. Vegetation is generally discussed in terms of the Project Site; as noted in Section 1.4.2.2 of the EIS, the Project Site corresponds to the Site Study Area. Section 5.6 also presents a regional perspective on plants, locating the Project Site within the Big Pic Forest Management Area and the Abitibi Plains Ecoregion (EcoMetrix Inc. et al. 2012). Section 5.6.2.1.2 describes the terrestrial environment at the Project Site. Over 90% of the area is forested, with non-forest communities, including rock barren, wetland and marsh sites, covering less than 5% of the site. The remaining area is characterized by lakes and developed land (see Section 5.7.2.2). Birch-dominated mixedwood forest makes up about 79% of the study area and includes species such as white birch, balsam fir, black spruce, white spruce, mountain maple, beaked hazel and other tall shrubs. Forest stands dominated by jack pine and trembling aspen are absent from the area, although these species are generally common in northwestern Ontario. No provincially significant wetland areas are identified at the project site. Rock barren cover, including lichen, blueberries and other low shrubs are found in the vicinity of the proposed mill site, Malpa Lake, and south of Bamoos Lake (EcoMetrix Inc. et al. 2012). Section 5.6.2.1.3 notes that a total of 340 vascular plant species were observed in the study area. These plant species are detailed in SID no. 24 (Northern BioScience 2009) and SID no. 29 (Golder 2009). Most of the plant species observed in the area were typical of native boreal forest plants common throughout northwestern Ontario. In addition, 30 non-native plants and several other noteworthy species that are geographically separated from their main ranges are identified and discussed in Section 5.6.2.1.3 (EcoMetrix et al. 2012). These plant species include non-native species such as clovers (Trifolium spp.), common dandelion (Taraxacum officiale), oxeye daisy (Chrysanthemum leucanthemum) and common plantain (Plantago major). Geographically separate arctic and alpine plants in the SSA include fragrant cliff fern (Dryopteris fragrans), glaucous bluegrass (Poa glauca), alpine bisnort (Polygonum viviparum), rock cranberry, northern woodsia (Woodsia alpine), and smooth woodsia (Woodsia glabella) (EcoMetrix et al. 2012). As noted in Sections 5.6.2.1.4 and 5.8.2.4, there are no known sites of or occurrences of high value habitat or plant species listed as Endangered, Threatened, or of Special Concern by the provincial or federal governments within the Big Pic Forest Management Area. A number of provincially rare plant species and regionally rare plant species were identified on or near the Project Site in Section 5.8.2.4. Provincially rare plant species are specified in Section 5.8.2.4.1 and include:  Appalachian Firmoss (Huperzia appalachiana);  Alpine Woodsia (Woodsia alpine);  Braun’s Holly Fern (Polystichum braunii);  Alga Pondweed (Potamogeton confervoides); and  Shore Plantain (Littorella Americana) (EcoMetrix et al. 2012).

Regionally rare plant species are common elsewhere in Ontario. Regionally rare plant species identified in the SSA in Table 5.8-2 (Section 5.8.2.4.2) include:  Common Ragweed (Ambrosia artemisifolia);  Whitlowgrass (Draba cana);  Northern St. Johnswort (Hypericum mutilum);  Broad-lipped Twayblade (Listera convallaroides);  Wood Millet Grass (Milium effusum);  Small-flowered Evening Primrose (Oenothera parviflora);  Canadian Mountain Rice (Oryzopsis canadensis);  Oakes’ Pondweed (Potamogeton oakesias);  Slender Pondweed (Potamogeton pusillus);  Narrow-leaved Cattail (Typha angustfolia); and  March Speedwell (Veronica scutellata). (EcoMetrix et al. 2012). No species identified as Endangered, Threatened, or of Special Concern were reported in the SSA (EcoMetrix et al. 2012).

Plant Species Identified for Traditional Use by Aboriginal Groups

Section 5.11.7.2 of the EIS notes that PRFN identified a wide variety of plants that are periodically collected for food, ceremonial and/or medicinal purposes in the Site Study Area and Local Study Area. The plant species identified for these purposes by the PRFN are summarized in Table 5.11-4 (EcoMetrix Inc. et al. 2012).

Table 5.11-4: Plants identified by PRFN on or around the Project site that are Harvested for Food, Cultural and/or Medicinal purposes

Reported Use Food Cultural Medicinal Balsam Fir (seeds) x Bear Root x Birch x x Black Ash x Blueberry x x Bunch Berry x Cedar x Choke Cherry x x Dandelion x Gooseberries x Hazelnut x Highbush Cranberry x x Labrador Tea x Moss x Mountain Ash x x Pine x

Reported Use Food Cultural Medicinal Poplar x Raspberry x Red Osier Dogwood x Red Willow x Rosehip x Sage x 1 Saskatoon Berry x Speckled Alder x Spruce (White) x Spruce (Black) x Sweetgrass x Tamarac x White Ash x Wild Strawberry x Willow x

Key person interviews (KPIs) with resource users from PRFN in January 2013 confirm that plant collection, particularly blueberries, occurs in the SSA and LSA (PRFN KPI Program 2013). The SSA is not particularly productive blueberry habitat, however, as noted in IR response 8.2. In addition to the plant species identified in Table 5.11-4, Section 5.11.7.4 of the EIS reports that timber is harvested by members of PRFN for firewood and other purposes within the LSA; no specific harvest locations for timber were identified in the SSA (EcoMetrix Inc. et al. 2012). Reports provided to SCI by the three Métis Aboriginal organizations note that plant collection and use for food, cultural and medicinal purposes is also important to local Métis people. Each organization provided information on plants collected in the Regional Study Area, and in the case of the MNO, in the LSA. The MNO report blueberry, raspberry and other berry and edible fruit collection in the RSA and LSA, including along the banks of rivers that flow from areas within the Project claim boundaries. The Métis organizations did not provide Site Study Area-specific plant species information. As noted in Section 5.11.8 Country Foods in the EIS – Main Report, the collection, distribution (i.e. sharing, gifting), and consumption of country foods, including plants, have economic, social, cultural and spiritual dimensions for PRFN (EcoMetrix et al. 2012). The MNO reports the same with respect to Métis people.

Summary of Effects Assessment on Vegetation Section 6.2.6 of the EIS assesses the effects of the Project on vegetation during each phase of the Project. Effects were assessed for site preparation and construction, operations, and closure and decommissioning for the four vegetation VECs:

1 Based on review of the specific plants and their uses identified by PRFN in their Final List of VECs (March 30th, 2012) , Saskatoon Berry – identified in Table 5.11-4 as having Medicinal Use – should be relabeled as Food Use.

 Forest cover;  Non-forest cover (including rock barrens and wetlands);  Regionally and provincially rare species; and  Protected species (EcoMetrix et al. 2012). From a spatial perspective the potential effects on vegetation are generally limited to the SSA, although some effects – such as the effects of dusting – could potentially extend to the LSA (EcoMetrix et al. 2012).

Forest Cover Sections 6.2.6.1.1 and 6.2.6.1.2 note that forest cover species – those species associated with the birch-dominated mixedwood forest, including trees, shrubs, and most vascular plant species identified in the SSA – will be most directly impacted by the removal of vegetation and topsoil during the site preparation and construction phase of the Project. There is also some potential for physical disturbance of vegetation as a result of dusting through site preparation and construction. Beyond site preparation and construction, some land clearing affecting forest cover is also anticipated to occur during the operations phase of the Project. The disturbance of the SSA during site preparation, construction and into operations may increase the potential for the introduction of non-native plant species into the margins between forest cover and newly disturbed areas (EcoMetrix et al. 2012). In Section 6.2.6.1.3, SCI reports that at the cessation of operations, the mine site would be reclaimed and revegetated in previously disturbed areas. It is estimated that a total of approximately 400 ha of land will be actively reclaimed to establish a vegetative cover during the first five years of closure. Revegetation alternatives, including grass and herb species as well as establishing forest cover, will be considered during detailed closure planning. Any active revegetation will include the use of native species (EcoMetrix et al. 2012).

Non-Forest Cover Section 6.2.6.1.1 notes that the removal of vegetation and topsoil during site preparation and construction will also directly impact non-forest cover – those species represented in rock barren and wetland sites within the SSA – and these disturbances may increase the potential for the introduction of non-native plant species. Section 6.2.6.1.2 notes that no further effects are anticipated on non-forest cover species for the operations phase of the Project (EcoMetrix et al. 2012). Closure and decommissioning of the Project will entail reclamation and revegetation as described for forest cover above and in Section 6.2.6.1.3 of the EIS (EcoMetrix et al. 2012).

Rare Plant Species Section 6.2.6.1.1 reports that the regionally and provincially rare species identified in the SSA will be affected by the site preparation and construction phase of the Project. Like with forest cover and non-forest cover species, the disturbance of rare species in the SSA may increase the potential for the introduction of non-native plant species into the area. Section 6.2.6.1.2 notes that no further effects are anticipated on regionally and provincially rare species in the SSA for the operations phase of the Project (EcoMetrix et al. 2012).

Closure and decommissioning of the Project will entail reclamation and revegetation as described for forest cover and non-forest cover above and in Section 6.2.6.1.3 of the EIS Section 6.2.6.1.3 also notes that it may be feasible to reintroduce rare native plants to the site during the closure and reclamation (EcoMetrix et al. 2012).

Protected Plant Species Section 6.2.6.1.1 reports that, with no known occurrences of habitats or plant species listed as Endangered, Threatened or of Special Concern, there is no anticipated interaction between the Project and protected vegetation (EcoMetrix et al. 2012).

Summary of Effects Section 6.2.6.2 summarizes the predicted vegetation effects of the Project. As noted, there will be a direct loss of vegetative cover through the development of the SSA. This includes a total of approximately 513 ha of white birch dominated mixedwood forest, 98 ha of black spruce forest, 0.6 ha of rock barren vegetation and 17.4 ha of wetland vegetation. In addition, there is potential for physical disturbance of vegetation as a result of dusting through site preparation and construction, as well as in the operations and early in the closure phases of the Project. Due to disturbances to the current vegetation, there is also potential for encroachment of non-native species in the SSA. Finally, some regionally and provincially rare plant species observed in the area will be displaced by the Project (EcoMetrix et al. 2012).

Mitigation of Adverse Effects Section 6.2.6.3 Mitigation of Adverse Effects notes that the location of site infrastructure and the footprint of the Project have been optimized to minimize the potential effects of the Project on the environment, including vegetation. Furthermore, disturbance to vegetation will generally be limited to the SSA through standard construction best practices. Mitigation measures associated with dust suppression and limiting vehicle traffic will reduce the effects of dust on plants in the SSA and LSA. In addition, the transmission line will be constructed through previously disturbed areas. The loss of vegetation associated with topsoil removal will be reversed through progressive reclamation, commencing as early in the site development process as practical (EcoMetrix et al. 2012). Following closure, approximately 400 ha of the SSA will be covered with topsoil and seeded. Similarly, the transmission line corridor will be seeded with the minimum amount of brushing undertaken to decrease disturbance. In order to prevent the establishment of invasive plants, specific mitigative measures noted in Section 6.2.6.3 will be implemented in the SSA (EcoMetrix et al. 2012).

Residual Effects Residual effects associated with the Project are described in Section 6.2.6.4 of the EIS (EcoMetrix et al. 2012). These residual effects include the permanent loss of approximately 200 ha of forest and the loss of some provincially and regionally rare plants. The section notes that the residual

effect of the loss of rare plants may be reduced by using the same species or other rare plants during reclamation (EcoMetrix et al. 2012).

Assessment of Significance The residual effects of the Project on vegetation generally were advanced to the assessment of significance stage and significance is described in Section 6.2.6.5 (EcoMetrix et al. 2012). Overall, the residual effects were assessed to be not significant due to the limited nature of disturbance and partial reversibility of these effects through site reclamation. The net loss of 200 ha of forest cover is judged to be not of significance given the abundant, similar forest cover found throughout the region (EcoMetrix et al. 2012).

Summary of Effects Assessment on Aboriginal Plant Use Section 6.2.11 of the EIS assesses Aboriginal Considerations, of which Traditional Land and Resource Use and Preponderance of Traditional Dietary Habits are identified as VECs. The following potential/predicted effects of the Project are noted in Section 6.2.11.8:

 Restrictions on traditional land uses, including animal and plant harvesting and country food collection in the SSA, though SCI will continue to provide Aboriginal people guided access to locations in the SSA that are safe to access, as well as access to the LSA; and  The loss of the contribution that the country foods collected in the SSA make to the traditional diet of Aboriginal people.

Generally the effects identified are limited to the SSA and would extend from the time the site preparation and construction phase begins to the time at which it is deemed safe to access the site following decommissioning. Effects related to country food gathering and use of the PRFN community trapline could extend into the closure phase, for a somewhat longer period, as the reclamation process takes hold and plant and animal communities redistribute themselves in the landscape.

As discussed in Section 6.2.11.3, collection of plants for various purposes are reported by PRFN to occur within the SSA and LSA. MNO in a confidential report recently provided to SCI also report on the collection by Métis people of a wide variety of plants for consumption as well as medicinal and ceremonial purposes in the RSA and, in the case of berries, in the LSA. In terms of specific use of plants for food use, PRFN report that the SSA and LSA contribute meaningfully to their diet (EcoMetrix et al. 2012). Plant collection by Métis people in the LSA, while not quantified by MNO, appears to be primarily focused on berries. However, continued access to the LSA will not be affected by the Project for harvesting purposes (EcoMetrix et al. 2012).

Other Aboriginal groups have not to date indicated current use of any plant species associated specifically with the SSA. Access to the LSA and RSA for plant collection by PRFN or other Aboriginal groups will not be affected by the Project.

Mitigation of Adverse Effects A primary mitigation strategy used by SCI to minimize impacts on the Traditional Land and Resource Use and Preponderance of Traditional Dietary Practices VECs has involved the reduction of the extent of disturbed land for the proposed mining operation. The issue of access, which is understood to affect land and resource use and traditional dietary habits, is also described in the EIS, with SCI committing to provide “Aboriginal peoples safe access to areas of the SSA that are outside of the primary areas of mining activity”, including the development of a protocol for use of the Camp 19 road (EcoMetrix et al. 2012: 6.134). Some engagement with Aboriginal peoples, in particular PRFN, over conceptual closure planning has occurred within the context of the EA process and further closure plan-specific engagement is planned and will be integral in the closure planning process. Consultations with local Aboriginal peoples will include discussions of potential end uses of the site, and particularly how the site can be reclaimed to support the land and resource uses envisioned by Aboriginal peoples and other stakeholders. Section 6.2.6.3 notes potential mitigation could include incorporating plants used for traditional purposes, such as country foods and ceremonial plants, into site revegetation plans, the enhancement of reclaimed areas to provide preferred habitat for particular wildlife species, and/or other uses (EcoMetrix et al. 2012). Beyond this, it is anticipated that any impacts benefits agreement with PRFN will include compensation for any impacts to plant collection and use in the SSA.

Residual Effects Section 6.2.11.10 notes restrictions to the use of the SSA for traditional pursuits including country food collection and the loss of the contribution that country foods make to the traditional diet of PRFN in particular as among the residual effects of the Project (EcoMetrix et al. 2012).

Assessment of Significance Section 6.2.11.11 describes the significance of the two residual effects discussed above. In both cases the effects were rated ‘minimal’ for spatial extent as the predicted effects are generally limited to the Site Study Area. The effects are each rated as ‘medium’ in duration insofar as they are limited to the construction, operation and decommissioning phases of the Project. Each effect is rated ‘high’ in terms of probability because if the Project moves forward the effects are certain to occur, while each was rated ‘medium’ in reversibility as it will take some time after closure and reclamation before future end uses are again supported in the SSA. Finally, the societal importance of the predicted residual effects are rated as ‘high’ due to the economic, social, cultural and spiritual dimensions associated with the collection, distribution (i.e. sharing, gifting) and consumption of plants and other country foods by PRFN and, as applicable, other Aboriginal groups or individuals such as the Métis. (EcoMetrix et al. 2012). Section 6.2.11.11 notes SCI’s intent to ongoing discussions with PRFN and other First Nations and Aboriginal organizations on additional mitigation strategies as well as on potential arrangements for any non-mitigatable impacts. Taking into account the mitigation measures described above, no significant residual adverse effects are expected with respect to the use of plant species for traditional purposes as a result of the Project.

References

EcoMetrix Inc., True Grit Consulting Ltd., Northern Bioscience, Knight Piesold Ltd., Calder Engineering, Stantec Consulting Ltd., Engineering Northwest Ltd., Ross Archaeological Resources Associates, and Di Matteo, L. (2012). Marathon PGM-Cu Project: Environmental Impact Statement – Main Report. Prepared for Stillwater Canada Inc., Thunder Bay, Ontario. Golder and Associates [Golder]. (2009). Supporting Information Document no. 29 – Copper Mining Project Baseline Assessment of the Aquatic and Terrestrial Environment. Prepared for Stillwater Canada Inc., Thunder Bay, Ontario. Northern Bioscience. (2009). Supporting Information Document no. 24 – Marathon PGM-Cu Project Terrestrial Baseline Environment Program. Prepared for Stillwater Canada Inc., Thunder Bay, Ontario. Pic River First Nation Key Person Interview (KPI) Program. (2013). Community-based research involving interviews with community members in person in January 2013. CDCI Research (2013), Report on the Finding of the Métis Nation of Ontario’s Lakehead/Nipigon/Michipicoten Consultation Protocol Area Land Use and Occupancy Study (Confidential).