110614-11EN030-GN Comments-IT4E

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ᒐ ᕙᒪ ᓕᕆᔨ ᒃ ᑯ ᑦ
Kavamaliqiyikkut
Ministère de l’Exécutif et des Affaires Intergouvernementales
Department of Executive & Intergovernmental Affairs
June 14, 2011
Amanda Hanson
Technical Advisor
Nunavut Impact Review Board
P.O. Box 1360
Cambridge Bay, NU
X0B 0C0
via Email to: info@nirb.ca
RE: NIRB: 11EN030- GN Comments on Golden Bull Resources Corp’s “Committee Bay
Greenstone Belt: Walker Lake” Project Proposal
Dear Ms. Hanson:
As requested by the Nunavut Impact Review Board (NIRB) in its correspondence dated May 24,
2011, the Government of Nunavut (GN) has reviewed the documents for Golden Bull Resources
Corporation’s Committee Bay Greenstone Belt: Walker Lake project proposal. The Government
of Nunavut recommends that the Nunavut Impact Review Board advise the Minister that the
project proposal be processed without a review under Part 5 or 6 pursuant to article 12.4.4 (a) of
the Nunavut Land Claim Agreement.
Please see the specific comments from the Department of Culture, Language, Elders and Youth,
the Department of Economic Development and Transportation, and the Department of
Environment, included in Appendix 1.
We thank NIRB for providing the GN with the opportunity to review and provide comments
regarding Golden Bull Resources Corp’s Committee Bay Greenstone Belt: Walker Lake project
proposal and we look forward to receiving further information on this project from NIRB. Please
contact me at (867) 975-6026 or at mduchaine@gov.nu.ca if you have any questions or
comments.
Thank you,
Marie Duchaîne
Avatiliriniq Coordinator
Executive and Intergovernmental Affairs
APPENDIX A
Culture, Language, Elders and Youth (CLEY)
At your request, the Department of Culture, Language, Elders and Youth (CLEY), Government
of Nunavut, has reviewed the above-noted application. Our recommendations are limited to
CLEY’s mandate and follow.
Golden Bull Resources Corp is aware of the recorded archaeological site within their
development area and therefore no attachment with the archaeological data is being provided.
Golden Bull Resources Corp is being required to report any archaeological sites encountered
during their activities (NLCA Section 33.5.12 and 33.5.13). Golden Bull Resources Corp is
encouraged to hire a consulting archaeologist (list below) to conduct an overview assessment of
the Committee Bay Greenstone Belt: Walker Lake property and any other properties which
Golden Bull Resources Corp has exploration interest in.
Julie Ross
Professional Archaeological Consultants known to be able to conduct Overview
Assessments in Nunavut
Arctic Archaeology
Sylvie LeBlanc PhD
Arctic Archaeology
10035-114 St # 701
Edmonton, Alberta
T5K 1R6
780 482-7040
sylvieleblanc@shaw.ca
Northern Lights Heritage Services Inc.
Virginia Petch, Ph.D., RPA, CEP
Northern Lights Heritage Services Inc.
2739 Pembina Highway
Winnipeg, Manitoba
R3T 2H5
Phone: (204) 231-8190
E-mail:
vpetch@northernlightsheritageservices.ca
www.northernlightsheritageservices.ca
FMA Heritage
Gloria J. Fedirchuk, Ph.D.
FMA Heritage
200, 1719 Tenth Avenue S.W.
Calgary, Alberta
T3C 0K1
Phone: (403) 806-1312
Fax: (403) 244-4701
E-mail: Gloria.Fedirchuk@FMAHeritage.com
Points West Heritage Consulting Ltd.
Jean Bussey
Points West Heritage Consulting Ltd.
2595 - 204th Street
Langley, B.C.
V2Z 2B6
Phone: (604) 534-5054
Fax: (604) 534-6381
E-mail: pointswest@telus.net
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Golder Associates Ltd (www.golder.com)
Brad Novecosky
Golder Associates Ltd.
1721 8th Street East,
Saskatoon, Saskatchewan,
S7H 0T4
Phone: (306) 665 7989
Fax: (306) 665 3342
Cell: (306) 222 5412
E-mail: Brad_Novecosky@golder.com
Thomson Heritage Consultants
Callum Thomson and Jane Sproull Thomson
12 Moodie Cove Road
RR2, Trenton, NS B0K 1X0
Phone: (902) 752-4633
E-mail: jmthomso@ucalgary.ca or
jmthomso@gmail.com (Callum)
E-mail: jsthomso@ucalgary.ca or
jsthomso@gmail.com (Jane)
Brent Murphy
Golder Associates Ltd
102, 2535 - 3rd Avenue S.E.,
Calgary, Alberta,
T2A 7W5
Phone: (403) 299 5600
Fax: (403) 299 5606
Cell:(403) 828 2214
E-mail: Brent_Murphy@golder.com
Sandra Ratch
Thomson Heritage Consultants
5313 51 Ave
Wetaskiwin, AB T9A 0V7
Tel: (780) 352-3836
E-mail: snratch@telus.net
Robert McGhee
1154 Bayview Drive
Woodlawn ON, K0A 3M0
phone 613-832-2244
cell 613-608-5170
rbrtmcgh@sympatico.ca
http://www3.sympatico.ca/robert.mcghee
Economic Development and Transportation (ED&T)
The Department of Economic Development & Transportation (ED&T) has reviewed the
documents provided for the Committee Bay Greenstone Belt: Walker Lake project proposed by
Golden Bull Resources Corp. The multi-season project as proposed involves early exploration
activities and a small camp of 12-15 people onsite with a possible maximum of 25 employees for
a drilling program proposed for a subsequent field season
The Department of ED&T expects that Golden Bull Resources Corp. provide maximum social
and economic benefits to nearby communities, including hiring local residents and utilizing local
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businesses whenever possible. As this is a multi-season project, any effort to build technical
capacity and improve job skills with local residents is also strongly encouraged.
Pursuant to Parnautit (the Nunavut Mining Strategy), the Government of Nunavut expects that
mineral exploration and mining companies use a Nunavut community as a logistical centre for
their operations (Policy 3-1, Parnautit). Therefore, Golden Bull Resources is encouraged to
utilize nearby communities as hubs for their operations as much as possible.
Dianne Lapierre
Environment (DoE)
The Department of Environment (DOE) has reviewed the project proposal and all supporting
documents from Golden Bull Resources Corp.’s on behalf of Aboriginal Affairs and Northern
Development (AAND) in accordance with its mandate under the Environmental Protection Act
& the Wildlife Act.
The DOE notes that the Proponent intends to carry out the following activities:
 Exploration program to consist of prospecting, geologic mapping, geophysical
exploration, diamond drilling, and environmental baseline work including:
o Airborne magnetic/EM and ground geophysical surveying;
o Exploration drilling to a maximum hole depth of approximately 300 metres, to an
initial total of 2000 to 3000 metres of on-land diamond drilling;
o Limited exploration stripping, trenching or overburden removal, possible blasting;
 Establishment of a temporary base camp to accommodate a maximum of 25 persons
 Production of human, combustible, and non-combustible wastes;
 Use of water, production of grey water and waste water;
 On-site incineration of combustible solid wastes, sewage, and waste oil;
 Movement of personnel and drills supported by helicopter;
 Camp supply supported by twin otter aircraft (using skis, floats, or tundra tires, dependent
upon seasonal conditions);
 Transportation, storage and use of chemical and hazardous materials;
 Transportation, camp and cache storage, and ongoing use of fuels
 Potential transportation and storage of explosives for blasting.
The following information and recommendations have been provided for the Board’s, as well as
the Proponent’s, information and consideration.
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A. WILDLIFE
The project is located in an area in the Kitikmeot mainland where known distributions of Polar
Bears (Ursus maritimus), Barren ground caribou (Rangifer tarandus groenlandicus), Muskoxen
(Ovibos moschatus) and various bird species are likely to be encountered. To prevent and
minimize project related impacts on wildlife, it is important that the proponent is aware of the
types, distribution and abundance of wildlife species in the project area prior to the start of the
project. DOE therefore asks that the proponent records all wildlife observations in a ‘wildlife
log’, and maps the location of any sensitive wildlife sites such as denning sites, calving areas,
caribou crossing sites, and raptor nests. The timing of critical life history events (i.e., calving,
mating, denning and nesting) should also be identified. Additionally, the proponent should
indicate potential impacts from the project, and ensure that operational activities are managed
and modified to avoid impacts on wildlife and sensitive sites; the log and maps will be a useful
tool to achieve this. Below are wildlife specific recommendations that DOE advises the
proponent to implement.
1. Caribou
Presently, caribou populations are known to be at a decline. Nunavut’s largest herd, the
Qamaniruaq has experienced an estimated overall decline of 2% annual since 1994 population
(Campbell et al, 2010). Elsewhere in the territory the Bathurst herd has declined from an
estimate of 100,000 animals in 2006 to 31,900 in 2009 (Nesbitt and Adamczekski, 2009). Peary
caribou were recently listed as Endangered under the Federal Species at Risk Act (Canadian
Gazette Part II, 2011), and future research initiatives will be assessing the Beverly and Ahiak
herd (Campbell - per com, 2011). Every effort should be made to ensure that caribou and their
habitat are not impacted.
During the period of May 15 to July 15 when caribou are observed calving in the area, the
proponent should suspend all operations, particularly blasting, overflights by aircraft of less than
610 m above ground, and the use of snowmobiles and ATV’s (all-terrain vehicles) outside the
immediate vicinity of the camp. Furthermore, following July 15 when caribou with new calves
are observed in the area, all operations should also be suspended.
Flights of less 610 m above ground should be avoided when caribou are in sight of operation.
During caribou migration, the proponent shall not locate and operate so as to block or cause
diversion to migrating caribou. The proponent shall cease activities that may interfere with
migration such as airborne geophysics surveys or movement of equipment or personnel, until the
caribou have passed.
Between May 15 and Sep. 1, the proponent shall not construct any camp, cache any fuel, conduct
blasting or drilling operations, operate ground, air or water based mobile equipment, including
geophysics surveys, within 10 km of caribou crossings.
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2. Muskoxen
Muskoxen are known to occupy the study area and similar to caribou can be adversely affected
by human disturbances. The calving and post calving season occurs April through August. The
same actions taken for caribou should be applied to Muskoxen. Notably when Muskoxen are
disturbed (E.g., an over-flight) it can cause animals to stampede, resulting in abandonment or
trampling of young. Bull Muskoxen also have the potential to display aggression towards the
proponents’ activities by charging.
The rutting season extends from early or mid July to early October. This period is particularly
challenging for bull Muskoxen as a disturbance can interrupt a vital period for the replenishment
of fat and muscle tissue that will be necessary for mating and successful reproduction, but also to
survive the winter..
Every effort must be taken to avoid muskoxen during the critical calving, post calving and
rutting time periods.
3. Human-carnivores conflicts
Inevitably there is always the potential for predator-prey interactions and the field protocol
should be in place to avoid wildlife interactions, and to mitigate any predator interactions.
Sightings and occurrences, such as wildlife near human activities, close encounters, and attacks,
should be recorded. Carnivores may approach humans or disturbances out of curiosity; however,
their keen sense of smell can detect food or waste odors from great distances. Potential humancarnivore encounters can result in injury or death to the animal or the humans, all possible efforts
to avoid human-carnivore encounters must be made, and negative reinforcement is encouraged.
Clean camp standards are essential and deliberate feeding of any wildlife is absolutely
prohibited.
Mortality resulting from mismanagement during a proponent’s activity is not an excuse for an
emergency kill and can be a significant loss to the nearest community who can request
compensation for the loss (Article 6, NLCA; Wildlife Act, 97 (3)).
The proponent should take all possible measures to avoid wildlife encounters, specifically bears.
DOE supports the proponent’s use of a secured bear fence around camp. However, DOE
recommends that the proponent also utilizes a fence for the fuel cache. Both fences should be
electrified. The proponent shall also install an alarmed trip wire around the site perimeter.
At the very least a proponent should:

Ensure appropriate licensing, training, and experience is acquired for firearm use.

Include non-lethal deterrent rounds (scare cartridges, rubber bullets, and bean bag
rounds) for use with a 12 gauge shotgun in bear deterrence plans. Ensure designated
personnel are familiar with the appropriate use and storage of these.
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
Employ wildlife monitors to assist in the protection of personnel and equipment from
wildlife, and to monitor levels of wildlife activity in the area, and work to identify and
resolve sources of human-wildlife conflict around camp. They should be equipped and
knowledgeable on non-lethal deterrent techniques.

Be prepared to take lethal action to resolve an imminent or occurring attack by wildlife
on a human. Have a suitable caliber firearm and shoot to kill.

Bears can be disturbed by over-flights. It is recommended that the proponent not fly over
any bear, especially if they have made a kill or cubs are present.
The proponent should contact the nearest Conservation Office:

If a situation occurs where wildlife becomes a nuisance (returning frequently, or unable
to deter).

Immediately if you have killed wildlife (either to resolve a conflict or unintentionally).

Immediately if you have injured wildlife and have not been able to relocate or destroy.

Immediately if a human has been attacked or bitten by wildlife. Note: Current policy is
for any wildlife that attack humans to be destroyed; only in special circumstances would
wildlife not be destroyed. If no further injury or human life is in danger contact the
Conservation Officer to report and for further instructions.
Contact the Regional Biologist, or Wildlife Manager indicated below for information and advice
on measures which should be taken to minimize wildlife-human conflict.
4. Raptor nesting areas
The following is a list of general precautions that must be considered when conducting activities
near Peregrine Falcon, Gyrfalcon, and other raptor nests (most of these precautions will also
apply to all nesting bird species):

Disturbance is most harmful early in the nesting period (May and June for Peregrine
Falcon and Gyrfalcon, similar for Rough-legged Hawk):
o Raptors will attempt to maximize their chances of successfully raising young. If
they decide early in the breeding period that their nest is at risk, they may
abandon it. If nests are disturbed at this stage of nesting, there may not be
sufficient time to re-nest. All disturbances to nests during the early part of the
nesting cycle must be avoided (avoid nest sites from late May through to midJuly).

Individuals show variability in their response to disturbance:
o Different birds will show different responses to varying levels of disturbance.
This may result from the general health of the bird, weather conditions, previous
life experiences, and adaptability. Therefore, treat all nest sites with equal
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precaution, regardless of the response of the bird. Do not disturb raptor nests
during conditions of poor weather (rain, snow, high winds).

Approaching the nest site near the time of fledgling (where chicks fly from the nest) often
leads to premature nest departure:
o During the last few weeks of nesting, severe disturbance at the nest often causes
young raptors to jump out of the nest. This can cause death from exposure,
predation, starvation, or trauma from the fall itself. All activity within 100m of a
nest site during the latter part of the nest stage (10-20 August for peregrine
falcons in this region) must be avoided.
5. Aircraft Disturbance
Aircraft activities have been shown to affect wildlife such as caribou, muskoxen and birds in
behaviour, development and reproductive success as well as subject the wildlife to adverse
weather conditions and accidental damage or injury. Furthermore, the timing of activities is
during the Barren-Ground caribou and Muskoxen calving season. By raising flight altitudes,
studies have shown that it will alleviate some of the negative effects. Therefore, DOE
recommends that the following protection measures are taken to reduce aircraft disturbance on
wildlife:
DOE asks the proponent to shift their over-flight activities to begin after July 15th to prevent any
impact during Barren-Ground caribou and Muskoxen calving season. DOE asks the proponent to
increase their flight height from 300m to at least 610 meters if wildlife is spotted within their
area of interest to minimize disturbance. In areas where there are observed large concentrations
of birds, flight level is restricted to 1,000 meters vertical distance and 1,500 meters horizontal
distance from the birds. As a good practice, it is recommended to avoid critical and sensitive
wildlife areas at all times by choosing alternate flight corridors.
B. SPILL PREVENTION
Based on DOE’s Spill Contingency Planning and Reporting Regulations, and Contingency
Planning and Spill Reporting in Nunavut: a Guide to the New Regulations, DOE recommends
the following:
Caches of drummed fuel are particularly subject to spillage, because they often become buried in
snowdrifts and are thus, susceptible to damage from heavy equipment. Furthermore, once buried,
leaking containers cannot be detected until after the snow melts, by which time, most, if not all,
of the spilled material has escaped off site with the spring melt. Drum cache locations should be
clearly defined and marked so that they are visible even during the winter season.
To prevent spreading in the event of a spill, fuel stored in drums should be located, whenever
practical, in a natural depression a minimum distance of 31 meters from all streams, preferably in
an area of low permeability. All fuel storage containers should be situated in a manner that
allows easy access and inspection as well as removal of containers in the event of leaks or spills.
For long term storage (> 6 months), it is strongly recommended that drummed fuel be stored on
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pallets to prevent the bottoms from rusting out. Drum caches should ideally be enclosed in a
fenced-in compound to prevent unauthorized access.
Since the proponent has yet to identify spill kit locations, DOE recommends that spill kits be
placed at all fuel caches and refueling stations. All spill kits should include materials such as a
shovel, pick-axe, drums, booms, absorbent pads/sheets, disposable protective gloves/coveralls,
and disposal bags. Also include in the spill kit all MSDS sheets for all chemicals on site. Finally,
include a list of local contractors or clean up specialists who may be called upon to assist in
responding to spills and a list of emergency numbers such as fire, ambulance and police.
In the event of a spill, it is also beneficial to have accurate contact information available to those
implementing the spill response plan. It is recommended that the spill prevention and response
plan be updated to list Robert Eno as the DOE Environmental Protection contact @ (867) 9757729.
C. ABANDONMENT & RESTORATION
To ensure proper restoration of the project site after project closure, DOE recommends the
following:

Sumps should be located at least 30 m away from high water marks of water bodies.

Sumps should only be used for inert drilling fluids, not any other materials or substances.
If hydrocarbon based drill additives such as rod grease is used, DOE recommends the use
of a filtration system aimed towards reduction of harmful substances to the environment.

Final inspections of the entire site should be conducted by the proponent and lead agency
to make sure that all areas of the site have been reclaimed as much as possible to its
previous condition. Soil samples and pictures before and after the project would make
this process easy on the proponent and leading agencies involved in determining areas of
concern.
D. CUMULATIVE EFFECTS
The proponent has not adequately described the potential cumulative effects of this project in the
proposed work area. The program work of Golden Bull Resource Corp is spatially and
temporally overlapped with another proponent’s project (North Country Gold’s Committee Bay
Project (07EN021)). The impacts are cumulative and are difficult to separate in terms of their
environmental impact (waste water, air transport, noise, etc). Cumulative effects, wildlife data
deficiencies, and the lack of meaningful impact and mitigation measures are a concern and these
components must comprise a comprehensive part of any future study. As well, particular aspects
of this proposal must be addressed more fully to ensure the collection of baseline data, and that
the location and timing of activities (i.e., exploration drilling, aircraft operation) does not
interfere with sensitive wildlife activities. Future expansions to the proponent’s activity will be
reviewed cumulatively and this may result in further terms and conditions.
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REFERENCES
Campbell, M., Nishi, J., and Boulanger, J. 2010. A Calving Ground Photo Survey of the
Qamanirjuaq Migratory Barren-Ground Caribou (Rangifer tarandu groenlandicus) Population –
June 2008
Nesbitt, L., and Adamczewski, J. 2009. Decline and Recovery of the Bathurst Caribou Herd:
Workshops Oc. 1 & 2 and 5 & 6 in Yellowknife. Government of the Northwest Territories.
Nunavut Tunngavik Inc. January 1993. Nunavut Land Claim Agreement (NLCA)
Species at Risk Act, P.C. 2011-42, 4 February, 2011, SOR/2011-8, ch.29, Canada Gazette, Part
II, 145(4): 78-457.
Wildlife Act, S.Nu. 2003, c.26
DOE CONTACTS
Biologist, Kitikmeot Region
Mathieu Dumond, (867) 982-7444, mdumond@gov.nu.ca
Director of Environmental Protection
Robert Eno, (867) 975-7729, reno@gov.nu.ca
Original signed by
Joel Fortier
Environmental Analyst
Department of Environment
Government of Nunavut
PH: (867) 975-7733
FX: (867) 975-7739
EM: joel.fortier@gov.nu.ca
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