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 2 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 3 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. 4 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. 5 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. 6 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 7 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 8 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. 9 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 10