Luis Lapierre Panel Chair Marathon Joint Review Panel Secretariat 160 Elgin Street, 22nd Floor Ottawa, Ontario K1A 0H3 RE: Participation of Parks Canada in the Public Review and Comment Period on the Adequacy of the Environmental Impact Statement Dear Louis: I am responding to your letter dated July 27, 2012 to Mike Walton (Superintendent - Northern Ontario Field Unit), regarding Parks Canada’s input into the review on the adequacy of the Environmental Impact Statement. Our specific comments are included on the attached table in the format requested by the review panel. Pukaskwa National Park’s protected areas status and the availability of suitable Woodland Caribou habitat along its coast and interior contribute to the security and persistence of caribou in the area. This has been identified as an important component of Ontario’s Woodland Caribou Conservation Plan. As Woodland Caribou are also identified as Threatened under Canada’s Species at Risk Act (SARA), Parks Canada is actively involved in recovery actions for this species. Please do not hesitate to contact Christine Drake, A/Resource Conservation Manager or Sharon Hayes A/ Park Manager at (807) 229-0801 should you have any questions or would like to discuss this further. Yours Sincerely, Mark Yeates Environmental Assessment Specialist Natural Resource Conservation Branch, Parks Canada, Ottawa, ON c.c. M. Walton – Superintendent, Northern Ontario Field Unit Attachments: Parks Canada Agency. 2011. Pukaskwa National Park - 2011 Regional Residents Survey. 41 pp Patterson, L. , C. Drake, M. Allen and L. Parent. In preparation for submission to Wildlife Society Bulletin Sept 2012. Detecting a population decline with long-term monitoring data of Woodland Caribou (Rangifer tarandus caribou) in Pukaskwa National Park, Ontario. Marathon PGM-Cu Mine Project – Joint Panel Review Parks Canada Comments on the Adequacy of the Environmental Impact Statement (Note – Parks Canada comments pertain exclusively to Supporting Information Document No. 26: Marathon PGM-Cu Project – Assessment of Impacts on Woodland Caribou) Issue Reference to References to EIS Information Rationale # EIS Guidelines Supporting Request or Panel Terms Information of Reference Document No. 26 1 2.6.1.8 Section 2.3 Moose density of Current moose density for portion of Pukaskwa National Park Cervid Ecological Pukaskwa NP (WMU33P) should be separated from WMU33 to represent Framework / more accurate moose estimate in the coastal zone. Pukaskwa Wildlife has data on moose density up to 2011, which is later than what Management Units was reported in this section and S3.4 2 2.6.1.8 Section 2.4.3 Forest Management More information on managed forest DCHSs for caribou Dynamic Caribou in close proximity habitat protection and enhancement in the coastal areas north Habitat Schedules to Pukaskwa and west of Pukaskwa (e.g. location and anticipated schedules). 3 2.6.1.8 Section 3.2 Greater discussion Just because caribou have not been documented in the study Current Caribou on caribou area does not mean they have not/do not occur there. Further Population occurrences for discussion on the likelihood of historical and current caribou Project Site and detection within the Project Site is requested. A social science vicinity project in Pukaskwa surveyed local residents for caribou sightings in this area. This information should be considered for this project (Parks Canada Agency 2011, Fig 31). Issue Reference to References to EIS Information Rationale # EIS Guidelines Supporting Request or Panel Terms Information of Reference Document No. 26 4 2.6.1.8 Section 3.2.2.3 More clarity on Further explanation on the imminent extirpation of caribou in Pukaskwa population decline Pukaskwa without improved connectivity, habitat restoration, National Park and imminent and alternate prey/habitat management outside the park [see extirpation in also S5.3 population trends]. Pukaskwa 5 2.6.1.8 Section 3.4 More information Further information/consideration should be given to black Populations of on black bear bear populations and associated predation risk to caribou in Alternate Prey and predation on the coastal zone. Predators caribou 6 2.6.1.8 Section 4 Explanation of Further consideration should be given to functional habitat. Woodland Caribou functional habitat Even though Pukaskwa, for example, has lots of great Habitat foraging habitat for caribou over a large area, the overall functional habitat might be limited because of their avoidance of areas with higher predation risks. 7 2.6.1.8 Section 4 Mapping of atypical Habitat modelling should map potential “atypical” habitat in Woodland Caribou caribou habitat the study area rather than habitat suited to northern Ontario; Habitat atypical habitat is more representative of occupied caribou habitat in the coastal zone. Issue Reference to References to EIS Information Rationale # EIS Guidelines Supporting Request or Panel Terms Information of Reference Document No. 26 8 2.7.2.6 Section 5 Clarity and more Discussion is required about the mainland caribou in coastal Cumulative information for zone being described as „Not Self-sustaining‟ despite that the Effects Range Assessment coastal population as identified in the federal draft RS Assessment and population indicates it is „Self-sustaining‟. See Pukaskwa‟s latest analysis trends (Patterson et al. In preparation). Further analyses and consideration are required on effects of any disturbance in the occupied coastal range, given that it is a narrow strip (10 km) of habitat. Maps of “Coldwell complex” and future mining potential should be included, as well as consideration to how this may contribute to cumulative effects. Pukaskwa National Park Regional Resident Survey—Working Together Towards Conservation Table of Contents 1.0 Introduction ……………….…………………………………………………………………………………………………………………………………….3 2.0 The Regional Resident ….………………………………………………………………………………………………………………………………….4 3.0 Awareness and Attitudes Towards Conservation ….………………………………………………………………………………………...5 4.0 Species At Risk ..………………………………………………………………………………………………………………………………………….…10 5.0 Caribou ………………………………………………...………….…………………...……………………………………………………………………...13 6.0 Caribou Conservation ……………………...…………….……………………………………………………………………………………………...18 7.0 Pukaskwa National Park ....……………………………………………………………………………………………………………………………..20 8.0 Caribou Conservation In Pukaskwa National Park …...……………………………………………………………...…………………....21 9.0 Interest In Conservation ...…………………………………………………………………………………………………………………………....24 Appendix I - 2006 Census Information For Communities in the Study Area …………………………………………………………26 Appendix II - Questionnaire …………….…………………………..…………………………………………………………………………………….27 Parks Canada, OSC - Social Science Research & Application - November 2011 Page 1 Pukaskwa National Park Regional Resident Survey—Working Together Towards Conservation 1.0 Introduction: In 2011, Pukaskwa National Park (NP) and Parks Canada’s Ontario Service Centre undertook a study of residents living within the regional area surrounding the park. The study was designed to collect information about the residents that would then be used to enhance communication and stewardship efforts for projects such as the restoration of the park’s Woodland Caribou population. Specifically, the study was designed to collect information regarding residents’ knowledge and awareness of conservation, Species at Risk and caribou. This information will help park staff develop communications and programs with the goal of increasing the regional residents’ knowledge and support towards Pukaskwa’s conservation efforts and caribou protection. The specific information collected from the regional residents included: Level of awareness of and attitudes towards conservation and conservation actions Level of knowledge and understanding of Species at Risk Level of awareness and knowledge of caribou Level of awareness, knowledge and attitudes of caribou conservation and conservation actions Level of awareness and knowledge of Pukaskwa National Park The information collected through this study will provide a benchmark for future evaluations of the success of Pukaskwa’s communication and community efforts. A survey package containing a letter from the Park’s manager with instructions in English, French and Ojibwa, two questionnaires and a self addressed, postage paid return envelope, was delivered to each household within the study area using Canada Post’s Unaddressed Admail service. These packages were addressed to the Head of Household and instructions were provided on how to randomly select two members of each household (age 16 and older) to complete the surveys. In total, 10624 questionnaires were delivered to 5312 households in May 2011. Based on Statistics Canada’s Census Data from 2006, of the 5312 households, 3623 have at least 2 adults in the household and 1689 have only 1 adult, resulting in a maximum response of 8935 completed questionnaires. Despite impacts due to a postal strike, 752 completed questionnaires were returned resulting in a response rate of 8.5%. The number of returned questionnaires is sufficient for a confidence level of 95% with a margin of error of +3.4%. In other words, if the questionnaire was administered repeatedly to different regional residents within the study area, the results would be the same 19 times out of 20 (95%) within +/- 3.4%. Parks Canada, OSC - Social Science Research & Application - November 2011 Page 3 Pukaskwa National Park Regional Resident Survey—Working Together Towards Conservation