Kitikmeot Inuit Association Presentation on Sabina Gold & Silver Corp.’s Back River Project FEIS Addendum

KIA Mandate “To manage Kitikmeot Inuit Lands and Resources to protect and promote the social, cultural, political, environmental, and economic well-being of the Kitikmeot Inuit.”

Project Location on Inuit Owned Land The Back River Project footprint overlaps 5 Inuit Owned Land Parcels BB-02 BB-13 BB-15 BB-16 BB-27 BB-27 BB-16 BB-15 BB-02 BB-13

Sabina Mineral Claims in the Kitikmeot Region

KIA Participation KIA has participated fully and to maximum capacity throughout the NIRB process KIA and Sabina have a positive working relationship Sabina has been receptive to KIA’s concerns and comments, and engaged KIA on many occasions to discuss and resolve issues

KIA Review Team Jared Ottenhof – KIA Lands and Environment Officer Technical Review Lead John Donihee – Willms & Shier Environmental Layers LLP KIA Legal Counsel

KIA Specialists Wildlife Zoetica Environmental Research Services Inc. Geotechnical Engineering BGC Engineering Inc. Water Quality Hutchinson Environmental Sciences Ltd. Fish and Fish Habitat Palmer Environmental Consulting Group Inc. Air Quality Pottinger Gaherty Environmental Consultants Ltd. Socio-Economics Shared Value Solutions Ltd. Traditional Knowledge Banci Consulting Ltd.

Information Requests KIA submitted approximately 140 Information Requests for the DEIS review phase, and 67 Information Requests to the NIRB for the FEIS phase 25 Traditional Knowledge issues (mostly editorial in nature) were identified in the FEIS and resolved with outcomes included in the KIA’s final written submission prior to the 2016 FEIS Hearing

Technical Comments & Joint Submissions KIA presented the NIRB with 26 technical comments in the initial FEIS review, and 20 technical comments on the FEIS Addendum KIA and Sabina presented 2 joint submissions on proposed terms and conditions for the project certificate to minimize or eliminate KIA concerns: 3 related to water quality 3 related to geotechnical matters 3 related to fish / fish habitat 7 related to wildlife and caribou .

KIA-Proponent Interaction Following the release of the Nunavut Impact Review Board Report on the project, Sabina engaged KIA, making significant efforts to resolve KIA’s technical comments and requests This occurred through continual talk and contact between KIA and Sabina that is well documented by Sabina, and was presented at the pre-hearing conference KIA’s submissions to the Board as part of the review process were the results of this ongoing constructive communication

Resolved Technical Comments

TC1: Placement of Monitoring Stations in Near- and Mid-Shore Marine Environment Monitoring locations may not accurately represent the near-shore and mid-shore areas; project effects may not be detected and can adversely affect implementation of appropriate adaptive management and mitigation. Sabina responded with a clearer definition of near- shore and mid-shore areas Sabina concurs with KIA that these areas be further defined and addressed in future regulatory processes

TC2: Baseline Water Quality Data Comprehensive baseline water quality data is required to accurately reflect seasonal variation in project area streams KIA proposed adding language to commitment KIA- C8, which Sabina agreed to: The Proponent will ensure sampling is an appropriate and accurate representation of at least one (1) full year of seasonal data.

TC3: Freshwater Monitoring Locations KIA recommended that sampling Station BRP-31 should be moved to a point upstream of the “neck” of Goose Lake to ensure water quality is accurately characterized through AEMP monitoring, and leaving the Station upstream or potential potent sources may only capture diluted influences Sabina agreed to adjust sampling station locations

TC4: Water Quality Sampling Frequency KIA recommends that mid-field water quality samples should be collected at least 3 times per year, and far-field samples be collected 3 times per year should changes in water quality be detected in near-field and mid-field locations Sabina responded that there is sampling 4 times per year in the exposure area, and 2 times per year in all other areas, in compliance with MMER; Sabina agreed that far-field sampling frequency will be increased should changes in near-field and mid- field be identified.

TC5: Water Quality Monitoring Suite KIA recommended physicochemical profiles (temperature, dissolved oxygen, pH, and conductivity) should be added as a field parameter for monitoring the receiving environment Sabina responded that this suite is already included in the AEMP (Table 5.1-1 and text in section 5.1.3) but will add clarity to future AEMP versions

TC6: Data Evaluation and Response Framework KIA recommended that Sabina should provide discussion on which statistical tests will be used for determining if water quality has differed from baseline conditions. KIA also requested that low action level triggers and responses be included in the AEMP. Sabina responded with a suitable discussion, indicating that a combination of guidelines, percentile or guidelines or percentile of baselines will be used as benchmarks and triggers for water quality; additional baseline data will be collected prior to construction, adding that these triggers and additional data will contribute to adaptive management

TC7: Exclusion of Zooplankton from the AEMP KIA recommended that zooplankton be included in the AEMP to assess potential biological responses to Project effects and whether the Site-Specific Water Quality Objective is protective of the environment Sabina agreed with KIA and committed to adding these sampling requirements to the next version of the AEMP

TC8: Clarify Representation of Impacts to Fish Habitat KIA requested that Sabina clarify specifically which streams and reaches will be impacted, requested that consistency in naming is maintained, and to add flow directions on applicable maps. In their response package, Sabina responded by providing a table and preliminary revised graphic indicating flow directions and clarifying names on streams and reaches

TC9: Mitigation by Design vs. Offsetting KIA requested that the construction of the fish migration channel be added as an offsetting measure to the Project Fisheries and Offsetting Plan. Sabina responded by stating that this “fishway” is a re-alignment of an existing watercourse (Rascal Stream East), and is therefore better included as a mitigation measure

TC10: Detail on the Design and Construction, and Conceptual Feasibility, of the Fish Passage Mitigation KIA requested additional information including conceptual design, channel alignment using LiDAR imagery, hydrologic information on the seasonal discharge, and evidence to ensure adequate fish migration regarding the fishway Sabina responded that the level of detail of the fishway requested by KIA will be addressed in the near future as it is a requirement of the DFO authorization stage

TC11: Baseline for Rascal Stream Fishway Memo KIA requested a more comprehensive and accurate description of baseline conditions including but not limited to baseline data with respect to effects assessment, clarification on fry and spawner surveys and habitat types within the stream reaches. This was in relation to the fishway memo in the Addendum Sabina responded that a majority of the information can already be found in the FEIS in various sections

TC12: Reporting on Timing of Fishway Mitigation Activities KIA requested clarification of timing of construction and year of effective mitigation measures and to clarify whether losses will be fisheries losses or habitat losses Sabina responded that all habitat losses are accounted for on the basis of fish productivity in the Conceptual Fish Offsetting Plan, and will update the Plan to include reach 7 of RSW as habitat lost. Sabina also responded that the fishway is to be constructed during the winter season prior to habitat losses, and clarified their reference to “Year 1”.

TC13: Clarification of Terminology and Characterization of Effects KIA requested clarification on the meaning of “fishway”, “re-aligned stream”, and “enhanced RSW” Sabina responded that the terms fishway and re- aligned stream refer to the same activity and construction project in the Rascal Stream West. Sabina committed to clarifying these discrepancies in their application for a Fisheries Act Authorization

TC14: Monitoring of Proposed Mitigation Measure KIA requested baseline information collection in “Year 0”, prior to construction activities. KIA also requested clarification or references for the proposed methodologies for fish spawner counts. Sabina responded that an error was made and that baseline data will be collected in Year 0. Sabina also provided more detail on spawner count methodologies.

TC15: Evaluating Success as part of the Monitoring Program KIA requested that in addition to the measures described in the monitoring program, the evaluation of success must include comparison to relative abundance and/or densities of fish existing prior to the Project activities Sabina responded in agreement with KIA, and stated that the monitoring program in Year 0 will look at density in spring and late summer along RSW to allow comparison of density and abundance during late spring and fall migrations. Sabina stated it is critical that the methods used are the same

TC16: Clarification on the Timing of Satellite Imagery for Bathymetric Maps KIA requested clarification the timing of the satellite imagery that was obtained/or will be obtained, to generate bathymetric maps for water withdrawal lake sources along the ice road alignment. Sabina responded that satellite imagery is anticipated to be collected between July and August 2017

TC17: Serious Harm to non-Fish Bearing Lakes and Ponds KIA requested clarification on the approach to the assessment of serious harm to non-fish bearing waters, and whether non-fish bearing status can be confirmed (i.e. no small-bodied fish), or whether a conservative approach was taken (i.e. direct connectivity so fish presence assumed). Sabina responded with a list of water bodies that had potential for serious harm to fish, and stated that these were conservatively characterized as potentially fish- bearing, and clarified a statement regarding residual serious harm to fish. Sabina also stated that these clarifications will be included in the next version of the Conceptual Fish Offsetting Plan

TC18: Losses in Fisheries Productivity KIA requested strengthening of section 6.4 regarding Losses in Fisheries Productivity by providing discussion and assessment on the potential impacts at a fisheries level on loss of habitat for lake trout, arctic grayling, round whitefish and small-bodied forage fish Sabina responded that sufficient discussion was provided in FEIS Volume 6 Chapter 6, and the Conceptual Offsetting Plan in the Addendum, and that they are confident that their assessment will meet DFO requirements

TC19: Mitigation Plan Continuity between WMMP Versions KIA requested that Sabina revisit original recommendations made during the Yellowknife wildlife workshop held in October 2016 for improving mitigation for smaller group sizes and adding back previous commitments Sabina responded that this was a versioning error, as some information was left out between versions, and would include all commitments from Version 3 of the WMMP

TC20: Caribou Mitigation and Protection (1 of 2) KIA requested that Sabina better define the term “group” when referring to protection of groups of 3-30 caribou. KIA proposed the following definition: A group of caribou is defined as an aggregation of caribou that are sufficiently close together that they can see and react to another animal’s behaviour, and have the potential of responding should one or more animal in the aggregation become startled KIA also stated that actions to protect groups of 3- 30 caribou, and trigger distance should be added to the WMMP after being removed in version H.1

TC20: Caribou Mitigation and Protection (2 of 2) Sabina responded in agreement to KIA’s proposed definition, and agreed to update the WMMP accordingly This definition was carefully crafted, as defining a group of caribou in the field can be left open to interpretation. It is, however, apparent that this definition will require skilled wildlife monitors to observe caribou and determine if their grouping and behaviour constitutes a group under this definition.

Recommendations to NIRB

KIA Recommendations KIA would like to reiterate their support for the commitments, terms and conditions that were jointly submitted with Sabina at the 2016 FEIS Hearing KIA also acknowledges and accepts Sabina’s proposed modification to commitment DFO-T-2 with the following modification (bold, underlined): “The Proponent commits to work in conjunction with DFO, KIA, and other interested parties during the regulatory phase…”

Future Processes and Agreements

Future KIA Matters Though there have been progressive technical discussions with Sabina, there are several key project components not yet in place Inuit Impact Benefit Agreement Compensation Agreements under the Nunavut Agreement Land Tenure / Lease Agreement Nunavut Water Board Water License Fisheries Act Authorization KIA anticipates ongoing discussions with Sabina on these matters

Concluding Remarks

Koana-Quana-Thank You