Beverly and Qamanirjuaq Caribou Management Board 6 May 2011 Nunavut Impact Review Board P.O.Box 1360 Cambridge Bay NU X0B 0C0 [email protected] NIRB File No. 11EN018 – Uranium North Resources Corp. “Aura” Project Proposal On behalf of the Beverly and Qamanirjuaq Caribou Management Board (BQCMB), I am submitting comments on the proposal from Uranium North Resources Corp. (Uranium North) for mineral exploration on their Aura and Nowyak properties in the area of Angikuni Lake, approximately 335 km west of the community of Arviat. This is in accordance with the mandate of the BQCMB, which is to advise governments and caribou range communities on ways to protect the Beverly and Qamanirjuaq caribou herds and their ranges. Many of our comments are similar to those we submitted in March regarding Uranium North’s Mallery Lake project proposal. Concerns about Cumulative Effects of Mineral Exploration As we have stated repeatedly, the BQCMB remains concerned about both the cumulative effects of mineral exploration activity occurring across the Beverly and Qamanirjuaq caribou ranges and the lack of cumulative effects assessment and land use planning underway throughout the region, including the Kivalliq region of Nunavut. The increasing potential for significant cumulative effects of mineral exploration activities on caribou and caribou habitat, as well as consequences for subsistence caribou harvesters, are major issues that needs to be addressed. Reviewing single projects in isolation is clearly not adequate to ensure protection of caribou and caribou habitat, or protection of the irreplaceable renewable resource upon which subsistence harvesters from across the caribou ranges depend. Comments and Recommendations on Uranium North’s Project Proposal Following are comments on Uranium North’s Aura project proposal as outlined in their applications for land use permits to Indian and Northern Affairs Canada and the Kivalliq Inuit Association, commitments made to the Nunavut Planning Commission, information provided in Uranium North’s Part 1 and Part 2 forms to the NIRB, and their non-technical project summary. Importance of the area to caribou - Uranium North is correct in stating that the project area is on the range of the Qamanirjuaq caribou herd, but is not located in traditional caribou calving grounds. However, use of the project area by Qamanirjuaq caribou has been documented for many years both through past government surveys and by the Government of Nunavut’s program tracking collared caribou. It is clear that caribou are likely to use this area during the proposed exploration period (March to September or October 2011 to 2016). Therefore individual caribou and the Qamanirjuaq BQCMB Secretariat: Box 629, Stonewall MB R0C 2Z0 1 Phone: 204-467-2438 E-mail: [email protected] Website: www.arctic-caribou.com herd may potentially be impacted by this project specifically, as well as by the project’s contribution to cumulative effects on caribou resulting from increasing mineral exploration across the caribou range. Timing of activities in relation to caribou. – According to maps produced by the Government of Nunavut’s Department of Environment (GN-DOE) based on tracking locations of collared caribou, the project area has been used in recent years by collared female caribou to the greatest extent during the following periods: summer (Aug. 1 - Sep. 15), fall (Sep. 16 - Oct. 14) and rut (Oct. 15 - Nov. 7). However, they have also used the area to a lesser extent during the calving (May 26-Jun. 25) and post-calving (Jun. 26 - Jul. 31) periods. Uranium North’s proposed Aura project timeline will overlap with these periods. Recommendation: The NIRB should require Uranium North to explain more clearly how they will ensure that they will have no negative impacts on caribou, since their proposed operation will occur during periods when caribou cows will likely use the area (e.g., from late May to mid-October), and other caribou (e.g., bulls and yearlings) may also use the area during this period. Caribou Protection Measures – Uranium North has made a commitment to adhere to the Caribou Protection Measures (CPM) in their responses to NPC’s conformity check. However, they say that their mitigation measures will include “Adhering to the Caribou Protection Measures; specifically not working in any core calving areas.” This statement, which they also made in their permit application for their Mallery Lake project, suggests that they do not understand all the requirements of the CPM, which include restrictions on activities wherever calving occurs, including outside core calving areas. Recommendation: NIRB and INAC should ensure that Uranium North understands that between May 15 and July 15 they will be required to stop operations in areas occupied by cows and/or calves as well as any activities that may interfere with migration, including aircraft flights at heights below 300 m above ground level. They should also be required to consider their potential impacts on caribou at other times outside the CPM-designated period. Disturbance from low level flights – Uranium North plans to use weekly or bi-weekly supply flights from Arviat or Baker Lake, and to move personnel and drill rigs by helicopter. These frequent flights have the potential to cause significant disturbance to caribou if conducted at low levels. They state that their mitigation measures will include “Adhering to the Recommended Environmentally Acceptable Minimum Flight Altitudes” without explaining what these are, or who they are recommended by. They also state that “when feasible” they will conduct flights above 610 metres (2000 feet) above ground level to avoid disturbance to wildlife. Recommendation: We recommend that the NIRB reinforce these commitments and require the Proponent take measures to ensure that their staff, contractors, and sub-contractors adhere to them whenever possible. Uranium North says that low-level airborne geophysical surveys “will only occur when no wildlife are present”. We assume they mean when particular species or numbers of wildlife are present, as there will be no time when “no wildlife” are present. Therefore their plans need clarification. Airborne geophysical surveys at extremely low levels can cause harmful disturbance to caribou and other wildlife, particularly during sensitive periods and if animals are subjected to this stress repeatedly. Recommendation: NIRB should require Uranium North to provide information regarding how the presence of caribou will be determined prior to initiation of surveys, and how the area will be monitored during surveys to ensure disturbances to caribou are avoided. Disturbance from cat train – The proponent makes several inconsistent and/or unsupported statements about their proposed cat train operation. Some statements describe the cat train operating BQCMB Secretariat: Box 629, Stonewall MB R0C 2Z0 2 Phone: 204-467-2438 E-mail: [email protected] Website: www.arctic-caribou.com during the month of March, elsewhere they say it “will only be conducted in April”. They also say the timing “will not interfere with any wildlife/harvesting in the area as it is proposed to be conducted in March/April which will preceed bird migration and caribou calving” and that timing the operation in April will result in “eliminating any disruption to wildlife or environment”. Recommendation: NIRB should require Uranium North to produce a credible plan for their cat train operation that will ensure that impacts on caribou and caribou habitat are minimal. This plan should include requirements for timing in relation to caribou movement patterns, terrain conditions and snowpack; monitoring for caribou along the planned route; and procedures to follow if caribou are encountered while the cat train operation is underway. They should also be required to consider their potential impacts on caribou at other times outside the calving period, as well as other wildlife in addition to migratory birds (e.g., resident wildlife). Disturbance from noise – The proponent makes several statements about noise created by the project and the significance of that noise that are nonsensical in relation to the potential for disturbance to caribou and other wildlife, including: - “Noise levels in the project area are negligible due to its remote location” - “The only negative aspect of this proposal which cannot be mitigated would be noise from the Cats but as they operate on diesel fuel the sound level will be quite low.” - “Noise issues are mitigated mostly by the remote location of the project area.” Noise from drills, helicopters and other aircraft, low-level survey flights, camp activities, cat trains and people working on the ground could potentially result in changes to behaviour of caribou groups. This could be particularly significant for cows during spring migration, for cows and newborn calves during calving and post-calving periods, and for all caribou during the summer when they need to feed continuously to ensure they are in good condition for the demands of fall migration, rut, pregnancy, winter and spring migration. Recommendation: NIRB should require that Uranium North takes effective action to mitigate the potential impacts of disturbance to caribou resulting from the noise caused by all project activities. Residual impacts - Uranium North again states that “Helicopter usage for purposes of supporting drilling operations is and has been the standard practice of many exploration companies now and in the past with no impact to wildlife or the