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
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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:
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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 nearshore 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 KIAC8, 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 midfield 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 realigned 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 fishbearing, 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 330 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