Environment Environnement Canada Canada Environmental Protection Operations Qimugjuk Building 969 P.O. Box 1870 Iqaluit, NU X0A 0H0 Tel: (867) 975-4639 Fax: (867) 975-4645 March 19, 2007 Our File 4703 001 Leslie Payette Manager of Environmental Administration Nunavut Impact Review Board P.O. Box 1360 Cambridge Bay, NU X0B 0C0 Tel: (867) 983-4607 Fax: (867) 983-2594 via e-mail lpayette@nirb.nnavut.ca RE: Scoping comments on Baffinland’s Mary River Bulk Sampling Project Thank you for the opportunity to provide comments to the Nunavut Impact Review Board (NIRB) on the type of review required for the Baffinland Iron Mine Corporation Mary River Project, pursuant to Part 4, Article 12 of the Nunavut Land Claims Agreement (NLCA), as well as on the scope of the project for environmental assessment purposes. Environment Canada (EC) has no regulatory authorizations associated with this project; however, EC will be providing specialist advice pursuant to our mandated responsibilities for the enforcement of the Canadian Environmental Protection Act, Section 36(3) of the Fisheries Act, the Migratory Birds Convention Act, and the Species at Risk Act. Environment Canada is of the opinion that the project proposal may cause significant adverse effects on the ecosystem and wildlife habitat and be a cause of significant public concern based upon the type of activities and associated scale of the project. EC recommends that the project be reviewed pursuant to 12.4.4 (b) of the NLCA. Potential significant impacts to the ecosystem may include, but not be limited to: Disturbance to waterfowl and seabirds in coastal areas along the proposed shipping route, which pass within close proximity to Bylot Island, a Migratory Bird Sanctuary and the surrounding Key Migratory Bird Habitat Marine Area. Surface freshwater quality as a result of run-off from open pit mining, drilling activities and the open stockpiling of iron ore. Water quality and migratory birds resulting from accidents or malfunctions which may occur during transfer, storage and shipping of ore concentrate and 80 ML of fuel. Air quality as a result of emissions from incineration, crushing and other mine activities. Drilling and blasting activities that negatively contributes to noise, air and water quality. Species at risk and migratory birds as a result of habitat loss and disturbance at the proposed project site facilities, roads, and shipping route. While EC believes that there is potential for the bulk sample project to cause significant adverse impacts, it is also recognized that this project is not a full scale mining operation. Environment Canada recommends that the scale of the review under 12.4.4(b) be appropriate to the size of the project. -1– Environment Environnement Canada Canada Scope of Project Based on EC’s mandated responsibilities and the information provided in the Mary River bulk sample project proposal, the following is a description of the physical works and the activities of the Mary River bulk sample project proposal that have potential impacts on areas of federal jurisdiction: The construction, operation, maintenance and decommissioning of a 200-person camp. o Air quality, surface water quality, migratory birds, and species at risk. The construction, operation and decommissioning of two open pit mines o Surface water quality/quantity, ground water quality, migratory birds, species at risk Construction and maintenance of a 100 km all-weather road, including associated quarries. o Migratory birds, species at risk, air quality, surface water quality The transfer and storage of 80 ML of fuel o Surface water quality(spills), Hazardous materials management Stockpiling of iron ore and waste rock o Surface water quality, migratory birds, species at risk The incineration of camp waste, sewage and waste oil o Air quality, migratory birds, species at risk The construction, operation, maintenance and abandonment of a landfill site. o Surface water quality, ground water quality, migratory birds, species at risk Shipping activities along Eclipse Sound. o Species at risk, migratory birds, emergency response, marine water quality Environment Canada is able to offer the NIRB specialist advice on these project components within areas under our jurisdiction, including surface water quality (freshwater and marine), surface water quantity, groundwater quality, groundwater quantity, air quality, migratory birds, species at risk, hazardous materials management, spill contingency and emergency response planning. Environment Canada looks forward to working with the NIRB in this review of the Mary River bulk sampling project. If there are any changes in the proposed project, EC should be notified, as further review may be necessary. Please do not hesitate to contact me with any questions or comments with regards to the foregoing at (867) 975-4631 or by email at cindy.parker@ec.gc.ca. Yours truly, Original signed by Cindy Parker Environmental Assessment Technician cc: (Colette Spagnuolo, Environmental Assessment & Contaminated Sites Specialist, Environment Canada, Iqaluit) -2–