Summary of the public consultation session (Gogama, Ontario)
Proposed authorization for mine waste disposal under the Metal and Diamond Mining Effluent Regulations for the Côté Gold Project
Location: Gogama Community Centre, 15 Low Avenue, Gogama, ON
Date: August 27, 2019, Gogama, ON
Time: 6:00pm to 8:00pm
Participants
David Brown: IAMGOLD (Proponent), Presenter
Don Carr: Wood Environment & Infrastructure Solutions (Wood), Presenter
Krista Maydew: Wood
Kim Connors: Minnow Environmental Inc. (Minnow), Presenter
Augusto Gamero: Environment and Climate Change Canada (ECCC), Presenter
Angelique Petropoulos: ECCC
Brandi Mogge: Department of Fisheries and Oceans (DFO), Presenter
Poster session and opening remarks
The doors opened at 5:30pm and the Proponent, along with Wood and Minnow, set up printed boards around the room with information on: the tailings management facility, the mine rock area, the new lake design, among others. Attendees walked around the room and discussed the posters at their leisure. At 6:30pm, the Proponent began the presentations by giving a status update of the project such as the construction deferral, continuing engagement efforts, permitting and engineering plans, as well as early work programs like tree clearings.
Explanation of the regulatory process
The poster session was followed by a presentation by ECCC to explain the regulatory process associated to the proposed regulatory amendments to Schedule 2 of the MDMER for mine waste disposal for the Côté Gold Project. The presentation included information about the objective of the consultations, the scope of the MDMER, the mechanics of the regulatory process and the timelines associated with the approval of the Schedule 2 amendments. ECCC also emphasized that a streamlining approach for the approval of the proposed amendments is available and would exempt the regulatory proposal from pre-publication in the Canada Gazette, Part I. ECCC is seeking the views of Indigenous groups and the public on the application of this approach.
Questions from audience members and answers provided
How does the government make sure that the mines are operating in compliance with the law?
The MDMER contain provisions on monitoring and reporting results to ECCC. If the Proponent is not in compliance, any violation can be subject to Enforcement. In addition, Enforcement can conduct inspections to verify compliance. ECCC also reminded the attendees that regulating the mining area is a shared responsibility between the Federal and Provincial Government.
A participant noted that the Government must inspect mine sites rather than enforcing only once a violation has occurred.
Where is the accountability for the Federal Government if the mine closes and the proponent leaves the area?
ECCC clarified that, in the context of the proposed authorization for mine waste disposal, the Proponent must submit a Letter of Credit that gives a financial guarantee that the fish habitat compensation plan will be implemented to offset for the loss of fish habitat resulting from the disposal of mine waste. ECCC also added that the project is subject to provincial requirements for closure plans. IAMGOLD added that it consulted on the provincial closure plan and that the province has approved said closure plan. Proponent stated that the Province currently holds $47 million for the proposed disturbance under the mine closure plan and additional financial assurance for the proposed fish habitat compensation will be provided.
What about chemical leaks that could enter clean waters?
ECCC responded that the Canadian Environmental Assessment Agency (CEAA) makes sure that the environmental effects of the project are analyzed and that appropriate mitigation measures are identified. In terms of compliance with the MDMER, the Proponent is required to monitor effluent and comply with the limits of certain substances present in mine effluent, including monitoring the downstream receiving environment as well as background. ECCC also added that provincial water quality requirements also apply. IAMGOLD added that they would also need to comply with provincial limits, which can be more stringent than federal requirements. IAMGOLD added that they are responsible for all water leaving the site. They have a monitoring program setup that they have been sampling over 30 locations since 2012 to develop a baseline. The Proponent has incorporated ditching and collection ponds around the tailings management facility and the mine rock area in order to capture, collect and monitor site water.
Why one area close to sources of drinking water for neighbouring towns is chosen as the preferred location for the tailings management facility? Could other areas further away be more appropriate?
ECCC noted that the purpose of the consultation is to get the views from the public and Indigenous communities on the proposed location of the tailings management facility. ECCC added that IAMGOLD undertook a very detailed analysis to determine the best location and that a presentation on how IAMGOLD assessed different alternatives for mine waste disposal will follow ECCC’s presentation. The Proponent described how the Project area is upstream of Gogama and all the alternatives assessed through the multiple accounts analysis are located in areas that drain past Gogama, either through Mesomikenda Lake or the Mollie River.
Assessment of the compensation plan
DFO delivered a presentation on DFO’s role in the assessment of the offsetting/compensation plan. DFO provided an overview on the following:
- How effects on fish habitat are categorized by the Fisheries Act (FA) (section 35 vs section 36 of the FA).
- How DFO supports ECCC in the MDMER regulatory process.
- The principles that guide DFO’s assessment of a compensation plan.
- What the key considerations are in assessing a compensation plan to offset for the loss of fish habitat.
Questions from audience members and answers provided
What is DFO’s involvement in the regulatory process?
DFO indicated that the Department is engaged from the beginning of the offsetting planning process and that it stays involved throughout its implementation and does annual site visits throughout the lifespan of the project.
What would happen if the mine proponent leaves without restoring the mine site? Does the government have a closure plan and financial securities?
ECCC indicated that a closure plan is required by the province and IAMGOLD added that the plan was approved in December 2018 and includes a financial security from the mine proponent to ensure that the closure plan will be implemented. The Proponent stated that the Province currently holds $47 million to implement the mine closure plan if something should happen to the company.
Analysis of the alternative assessment for mine waste disposal
Wood (IAMGOLD consultant) presented the analysis of the alternatives assessment for mine waste disposal: the waste rock storage area and the tailings management facility. Wood explained in detail the process involved in selecting the best alternative for waste rock and tailings disposal from an environmental, socio-economic, economic and technical perspective and in accordance with Environment and Climate Change Canada Guidelines for the assessment of alternatives for mine waste disposal.
Questions from audience members and answers provided
What kind of chemicals would be used in the mining process?
Wood responded that cyanide would be used to extract gold and then would be treated in the process plant prior to being discharged to the tailings management area. This primary treatment was not provided by historic mines, which is why some historic mines had problems with cyanide management in the tailings facilities. Wood added that the residual cyanide in the tailings management area would be further reduced by volatilization to air and degradation by sunlight. The Proponent does not expect cyanide to be a problem given that water will be re-circulated in a closed loop and that the Proponent will need to comply with cyanide limits present in any effluent that enters into the environment.
Why were only four options studied, why and how was the proposed TIA chosen, why was the proposed TIA selected if there are high risks to groundwater and are there more environmentally friendly options?
Wood responded that it looked at multiple sites during approximately 10 years of evolving project design. 17 candidate sites were considered in the assessment of alternatives. Most of the sites are not viable due to fatal flaws and four sites were carried through the multiple accounts analysis and assessed based on the environmental, technical, economic, socio-economic impacts. The chosen site demonstrates the least impact. Wood added that all alternatives would require seepage collection systems to capture seepage from the tailings management facility, and that the ground conditions are very similar between the alternatives with tight bedrock that reduces the potential for seepage to bypass the tailings management facility’s seepage collection systems. The combination of seepage collection systems and tight bedrock reduces the potential for groundwater to affect watersheds around the Project site.
Proposed fish habitat compensation and offsetting plan
Minnow Environmental (IAMGOLD consultant) delivered a presentation on the proposed combined fish habitat compensation and offsetting plan. The presentation explained that one compensation plan had been developed to offset losses under both Section 36 and Section 35. Minnow explained which water bodies will be lost (Côté Lake, a portion of the Mollie River, a portion of Upper Three Duck Lake, a small portion of Clam Lake and other small water bodies), which areas were associated with Section 36 of the Fisheries Act (Schedule 2 amendment under MDMER) and which are associated with Section 35 of the Fisheries Act. Minnow outlined that key habitat offsetting components include, the creation of a new lake, realignment of the Mollie River and connections between disconnected lakes providing fish better access to habitats. The presentation described key habitat features of the proposed plan including diversity of habitat (e.g., pool, riffle, complex shoreline / islands), cover (e.g., large woody debris, shoals, cobbles, boulders, vegetation) and spawning habitat. Minnow also outlined mitigation measures to support success of the offsetting plan such as: construction sequencing, fish salvage / relocation, construction best management practices and monitoring. Measures to reduce lag times were also presented, including incorporation of physical habitat features, planting of floodplains and shorelines, transplanting aquatic invertebrates and strategic transfer of fish.
Conclusion
A recurring comment from the public was the concern for the effects of climate change on water levels, water bodies and the ecosystem as a whole. Participants were also concerned about protecting the environment for when the project ends or when the Proponent leaves the area. Wood noted that the tailings management facility is designed for more extreme flood events than required, which helps to reduce the risk of failure at the facility from potential weather changes associated with climate change, and that the dam engineer of record is required to perform regular dam safety reviews that consider the effects of climate change on the integrity of the dams.
One general comment regarding the Notice was that people in the area only received the Notice 5 days before the public meeting and the Facebook post only the weekend before. ECCC indicated that the consultation documents are available through the consultation webpage and committed to sending a follow-up email with all necessary documentation.
Note: Following the public session in Gogama, ECCC sent out an email to all interested parties with all the relevant links and documentation related to this consultation process. ECCC is accepting comments from the public until November 1, 2019.
The session ended at 9pm.
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