Meadowbank Government of Nunavut Presentation to Nunavut Impact Review Board March 2006Baker Lake, Chesterfield Inlet, Rankin Inlet

2 2 Government of Nunavut Overview This is a consolidated submission on behalf of the Government of Nunavut (GN) GN welcomes opportunity to appear before NIRB GN congratulates Kivalliq Inuit Association (KIA) and Cumberland Resources Ltd. on the signing of an Inuit Impact Benefit Agreement (IIBA) In reviewing the FEIS the GN acknowledges the openness, effort and level of cooperation shown by the company GN is offering some recommendations to reduce, mitigate and monitor environmental, socio-economic & archaeological impacts

3 3 Government of Nunavut Overview A key GN goal is the expansion Nunavut’s economy, as indicated in Pinasuaqtavut. GN is guided by Inuit Qaujimajatuqangit (IQ) principles while working to meet Pinasuaqtavut goals. One principle is Avatittinnik Kamatsiarniq – respect for and care for the land, animals and environment. GN’s recommendations to NIRB focus on environmental and socioeconomic issues. The submission also recommends measures to reduce potential impacts on archaeological sites. The GN proposes to work in partnership with Cumberland Resources, Inuit organizations, hamlets and the Government of Canada to address environmental and socioeconomic issues and ensure that economic and other benefits, especially in Baker Lake, Chesterfield Inlet and Rankin Inlet, are maximized.

4 4 Government of Nunavut Overview Two ways to structure this partnership are through: The use of a Development Partnership Agreement (DPA), as described in the socioeconomic section (Part II) of this presentation A regional monitoring and mitigation committee

5 5 Part I -- Environment GN-DOE Role in Environmental Review Process Legislative Authority 1. Nunavut Wildlife Act 2. Nunavut Environmental Protection Act

6 6 Part I-- Scope of Comments 1. Water Quality 2. Permafrost 3. Wildlife and Terrestrial Environment 4. Cumulative Effects 5. Other Issues -Hazardous Materials Management/Spill Contingency Planning -Reclamation and Closure -Air Quality and Noise Management

Water Quality General Comments -Most issues can be addressed in the permitting phase of the project. -Adaptive management is required to manage potential acid rock drainage (ARD.)

Water Quality Specific Issues Issue: Monitoring and Baker Lake Marshalling Area. -Monitoring of water quality not proposed. -Water supply and waste disposal not addressed. Recommendation: -Monitoring plan be developed specific to the marshalling area. -Water use and waste disposal management be incorporated in final design/engineering phase.

Permafrost General Comments -The Department of Environment (DOE) acknowledges Cumberland’s incorporation of climate change factors into its modelling. -Adaptive management can be used to treat surface runoff if encapsulation does not occur. -Adaptive management for possible groundwater contamination by tailings is more challenging.

10 2. Permafrost Specific Comments Issue: Mitigation Measures for Possible Groundwater Contamination by Tailings. No management plan nor commitment for mitigation in the case of groundwater contamination by tailings. Recommendation: -Conduct permeability tests and monitoring of any faults. -Identify mitigation measures in case of groundwater contamination.

11 3. Wildlife & Terrestrial Environment General Comments DOE has no significant wildlife concerns. DOE has noted some baseline information gaps (particularly with the few data collected for the access road), but these outstanding issues should not result in any significant changes to the conclusions of the impact assessment. Proper mitigation and monitoring should ensure protection of wildlife and terrestrial environment. DOE places an emphasis on appropriate design and implementation of the Terrestrial Ecosystem Management Plan (TEMP). There are some outstanding issues with the TEMP that will be important for follow-up monitoring. The plan should be revised prior to project construction.

12 3. Wildlife & Terrestrial Environment Specific Issues Issue: RSA (Regional Study Area) maybe too small to determine natural variability from project-related effects. Recommendation: -The proponent should be prepared to expand monitoring efforts should results prove unsuccessful at determining natural variability from operations-related effects.

13 3. Wildlife & Terrestrial Environment Issue: Annual analyses of road kills may have been too infrequent. Recommendation: -The acceptable mortality of ungulates and furbearers resulting from road-related mortalities should be set at “1”. -Mortalities of all ungulates and furbearers should be reported immediately, and mitigation measures be immediately enacted.

14 3. Wildlife & Terrestrial Environment Issue: No quantified assessments of natural environmental changes provided as a baseline Recommendation: -Natural trend analyses be provided to DOE in the 2007 summary monitoring report, as promised by the proponent. Issue: : Ineffective method used to monitor the effects of aircraft over- flights on Valued Ecosystem Components (VECs) Recommendation: -Correlate wildlife distribution/movement with aircraft movements. -Incorporate detailed and ground-based behavioral observations to determine the effects of localized disturbances.

15 3. Wildlife & Terrestrial Environment Issue: Data/monitoring not distinguishing sensitive caribou cow/calf from other caribou group observations. Recommendation: -Distinguish cow/calf caribou from other caribou groups during surveys. Issue: No details/methods provided on hunter harvest study used to determine effects of access road. Recommendation: -Provide details of the harvest study. -Consider results from the Nunavut Wildlife Management Board’s harvest study as a baseline.

16 3. Wildlife & Terrestrial Environment Issue: Insufficient information on caribou ecology/herd delineation in the region Recommendation: -Revise the TEMP to include at least three (3) years of an inventory that includes a component of population delineation-based studies (including satellite-collaring) and assess the efficacy of those studies at the end of the three- year “trial”.

17 3. Wildlife & Terrestrial Environment Issue: Insufficient details on survey methods in the TEMP. Recommendation: -Provide complete survey methodology in revised TEMP. Issue: Insufficient details on statistical methods. Recommendation: -Provide statistical justification for sample sizes in the TEMP.

18 4. Cumulative Effects General Comments DOE agrees with Cumberland there are no measurable cumulative effects, except for the issue of greenhouse gas emissions as a result of this project. This issue is discussed in the air quality section of this presentation.

19 5. Other Issues: Hazardous Materials and Spill Contingency Plan General Comments  DOE found most hazardous materials management plan issues not to be significant and can be dealt with during permitting stages.  DOE believes, notwithstanding the critique in its intervention, the Spill Contingency Plan is acceptable for the current phase of the project. Nevertheless, Cumberland is expected to re ‑ visit and revise its contingency plan as and when conditions require.

20 5. Other Issues: Hazardous Materials Management Issue: When is Cumberland going to become a signatory of the International Cyanide Management Code (ICMC)? Recommendation: -Cumberland becomes a signatory of the ICMC prior to any storage or handling of cyanide in Nunavut. -Cyanide spill responses be included at the permitting stage

21 5. Other Issues: Reclamation and Closure General Comments The Reclamation & Closure Plan is conceptual, and a more detailed/complete plan will need to be submitted closer to the closure of the project

22 5. Other Issues: Reclamation and Closure Issue: Duration of re-vegetation monitoring post closure. Recommendation: -Extend monitoring proposals for re-vegetation post-closure. -Complete re-vegetation trials as early as possible in the mine life.

23 5. Other Issues: Reclamation and Closure Issue: The management of Vault waste rock piles. Recommendation: -Cap Vault waste rock pile with fine grain materials and/or provide corridors through the pile to ease the passage for wildlife. -Quarry sites should be restored in a manner that allows for wildlife passage and for creation of appropriate wildlife habitat.

24 5. Other Issues: Air Quality and Noise Management General Comments DOE is satisfied with the Air Quality & Noise Management plan, except for issues in regard to GHG emissions, incinerator emissions, and the impact of blasting on wildlife.

25 5. Other Issues: Air Quality and Noise Management Specific Issues Issue: Greenhouse gas emissions and energy conservation. Recommendation: -Develop an Energy Conservation Plan. Issue: Emissions of furans & dioxins from onsite incinerators Recommendation: -Ensure that emissions meet CCME Canada-Wide Standards. -Monitoring of emissions is included in the air quality & noise monitoring plan.

26 5. Other Issues: Air Quality and Noise Management Issue: Environmentally sensitive times for blasting. Recommendation: -Elaborate on what the sensitive times for blasting are. -Develop a plan to ensure blasting does not result in sensory disturbance to wildlife.

27 Part I -- Summary The FEIS for Meadowbank is significantly improved from the Draft and provides greater technical analysis to support the conclusions. The current DOE review of the FEIS identifies a number of issues of detail that can likely be resolved at the later permitting or operational stages; and are therefore considered of low importance at this time. There remain a number of issues relating to water quality, groundwater management, wildlife management and monitoring, hazardous materials, closure, air quality and noise management that will require further consideration by Cumberland at the current stage of the project. The GN will continue to work with the proponent to resolve these issues.

28 Part II-- Socioeconomic The Government of Nunavut has identified six areas that contain socioeconomic implications: 1.Monitoring, Mitigation & Reporting 2.Training & Employment 3.Business Opportunities 4.Infrastructure 5.Health & Safety 6.Culture

29 1. Monitoring, Mitigation & Reporting –Baseline Data – proponent and affected parties should work together to ensure sufficient baseline data is collected –Socioeconomic Monitoring Committees – the GN sees a role for community and regional monitoring and mitigation committees –Mitigation – the GN has a role to mitigate impacts of the project that may not be defined in the IIBA – this may require the proponent, the GN and KIA work together –Community Consultation & Communication – the GN supports the hiring of a Community Liaison Coordinator –Nanisivik Experience – valuable lessons should be included in the monitoring process.

30 2. Education & Training 1.Education & Training Plan – GN will develop a plan with proponent, in consultation with KIA, to maximize education and training opportunities. 2.Inuit, Local Hire, Training & Advancement – GN commends the establishment of trainee positions and encourages proponent to develop clear training and advancement targets for entire life of project 3.Scope & Timing of Hiring Goals – GN will work with proponent to identify training initiatives needed to build skill level of local workforce to take advantage of the employment opportunities. 4.Youth Specific Initiatives – GN will work with proponent to maximize youth education and training opportunities. 5.Spin-off Effects on Local Business – hiring of skilled labour from communities may have impact on ability of communities and businesses to provide services. Needs to be monitored, mitigated.

31 3. Business Opportunities for Baker Lake & Kivalliq Business Opportunities – GN will work with proponent, KIA and the Kivalliq Chamber of Commerce to provide information on potential opportunities for the Kivalliq business community.

32 4. Infrastructure 1.Infrastructure Pressures – project has potential to overtax infrastructure of impacted communities (Baker Lake and Rankin Inlet.) GN, affected communities and proponent should jointly identify potential pressures for monitoring and mitigation. 2.Final Disposition of the All-Weather Road –final decision to use of the road after mine shut-down will be made when sufficient data on its socioeconomic impact is available. 3.Community Fuel Supplies – storage facilities in Baker Lake and Rankin Inlet may not be sufficient - GN and proponent will meet annually to determine impact on community fuel supplies. 4.Baker Lake Lay Down and Fuel Storage Area – proponent GN and Baker Lake should review the proposals related to the marine infrastructure and fuel storage in the community.

33 5. Health & Safety Impacts on Wellness, Health & Safety – GN would like to see Cumberland develop comprehensive wellness strategy for workers and families. Emergency Responses – GN will work with proponent to consult communities on emergency response plan to ensure roles of GN, communities and proponent are well defined. Road Safety – need to determine who will be responsible for road safety laws on the all-weather road.

34 6. Culture –Traditional Way of Life – project has potential to affect ability of Inuit workers to participate in harvesting activities. –GN would like proponent to consult with Hunter and Trapper Organizations to identify traditional harvesting periods and permit increased flexibility for Inuit workers during these periods. –GN is encouraged by commitment by proponent to identify role models and implement policies that promote traditional values of sharing. –Traditional Knowledge – use of traditional knowledge will help development of the project – its use should be monitored.

35 Development Partnership Agreements A framework the GN and proponent may chose to use to increase benefits of a major development project such as Meadowbank Development partnership agreements are voluntary. After completion of a development partnership agreement, major development projects will qualify for the fuel tax rebate. Development partnership agreements may include: –Socioeconomic monitoring and mitigation –Hub community identification –Infrastructure development –Training and employment –Business development Government of Nunavut questions about the Meadowbank project can be addressed in a development partnership agreement.

36 Monitoring and Mitigation Committees Monitoring and mitigation committees can help increase participation of Nunavummiut in a major development project. Committees should be established for the region and be encouraged in affected communities Both GN and Cumberland should participate, as well as others. A regional monitoring and mitigation committee can address: –Baseline data and development indicators –Mitigative measures –Opportunities for participation of Nunavummiut –Reporting requirements A community monitoring and mitigation committee can provide: –A forum for community discussion of perceived socioeconomic impacts of a major development project –Information sharing in the community about a major development project –Recommendations for action to regional monitoring and mitigation committee

37 Part III – Archaeology The Division of Culture and Heritage of the Dept. of Culture, Language, Elders and Youth (CLEY) is pleased that the project design has changed to reduce potential impacts on archaeological resources It is recommended that Cumberland Resources Ltd. provide more detail about a few statements made in the FEIS: 1) Details about revised project design that result in archaeological sites being avoided 2) Clear statement of what future mitigation and monitoring procedures will be taken 3) Clarification of method used for the age determination of archaeological sites 4) Clear statement as to whether sites mentioned in the Traditional Knowledge Study were recorded as archaeological sites 5) CLEY’s role in archaeological resource management

38 Part III – Archaeology: Revised Project Design The Division of Culture and Heritage requests that more details be provided about the revised project design because currently it is not clear how the project design has been changed to avoid sites that Cumberland’s Baseline Archaeology Report indicates are within the development area. The GN’s written submission includes a listing of sites for which this review is requested

39 Part III – Archaeology: Mitigation and Monitoring The FEIS indicates mitigation of, and monitoring for archaeological sites will take place; however, details as to how this will be undertaken are not clear. The Division of Culture and Heritage would like to know Cumberland Resources’ clear plan that shows how sites will be mitigated and what future plans there are for continued monitoring

40 Part III – Archaeology: Age Determination The Baseline Archaeological Report indicates that most of the sites recorded are less than 50 years old. The Division of Culture and Heritage would like a clear statement as to how these ages determinations were made.

41 Part III- Archaeology: Connection between Traditional Knowledge and Archaeology The Traditional Knowledge Study asks specific questions about the location of archaeological sites. It is unclear if locations mentioned by informants were recorded as archaeological sites and submitted to the Canadian Museum of Civilization for an official designation. If they were recorded as archaeological sites it is unclear if a site visitation was made by the project archaeologist

42 Part III – Archaeology: Archaeological Resource Management Broad participation is always desirable concerning archaeological resource management issues; however Cumberland Resources Ltd. should be aware that CLEY is the primary regulatory agency for archaeological resource management in Nunavut

43 Conclusion With this consolidated presentation the GN is providing recommendations and observations that will, subject to NIRB’s report and the ministerial decisions in relation to permits, enable Cumberland to proceed with its gold project. The points raised in the presentation will help minimize environmental issues and the impact on archaeological sites. The presentation also underlines the GN’s commitment to working with Cumberland, KIA and Kivalliq communities to ensure the best possible socioeconomic outcomes. Based on Cumberland’s FEIS, the GN is confident its concerns will be addressed by the company.