16.0 Recommendations
This section describes the recommendations listed in each of the individual activity sections (Sections 6 to 14) of this report.
The majority of the recommendations generated by the Frontier Mine Project ICA focus on offset programs and protection plans, whereas the mitigation measures were largely developed by MMSC in some of their previous responses to the Frontier Mine Project.
The recommendations also take into consideration a number of key Fort McKay Métis planning documents, including:
• FMMCA Strategic Planning Documents (2008-2015).
• Conserving Opportunities for Traditional Activities by the Community of Fort McKay Amongst the Industrial Landscape or Northeast Alberta (2013).
• A Community Approach to Landscape Planning (2013).
• Fort McKay position paper on LARP (2015).
• Fort McKay Healing the Earth Strategy (2010b).
Most importantly, the Frontier Mine Project ICA recommendations align with FMMCA’s strategic goals for sustainability. FMMCA views on sustainability align with the Bruntland Commission definition sustainability, which is: “development that meets the needs of the present without compromising the ability of future generations to meet their own needs” (Bruntland Commission 1987, p. 43). In 1987, Justice Barbier argued that:
As the primary objective is to provide lasting and secure livelihoods that minimize resource depletion, environmental degradation, cultural
disruption, and social instability, sustainable development can be viewed as an interaction among the three systems: the biological and resource system, the economic system and social system. The basic objective is to maximize the goals across all these systems through dynamic and adaptive process of tradeoffs. (Bruntland Commission 1987, p. 109).
In 2013, FMSD wrote, “The culture, society and traditional economy of the people of Fort McKay are inextricably linked to the regional landscapes and ecosystems that support and shape them. The social, cultural and economic health of the community of Fort McKay is dependent on opportunities in the industrial
economy, but is also dependent on functioning ecosystems and the ecological
goods and services provided by these ecosystems” (Berryman et al. 2013, p. 55).
Fort McKay Métis culture is already under a tremendous amount of stress due to the rapid and significant shifts in environmental, social and economic conditions that have occurred since the 1960s. The Frontier Mine Project ICA model
provides a visual representation of the current state of Métis culture. The colours of the lines on Figure 15-3 in Section 15: Impact Assessment Summary, represent the significance of the Frontier Mine Project contribution to cumulative pressures being put on Fort McKay Métis culture.
Due to the desire to both participate in the industrial economy and protect some meaningful level of opportunity to practice traditional land uses,
community members in Fort McKay are faced with decisions that involve finding an appropriate balance between the benefits (primarily economic) and
liabilities (largely ecological and cultural) that industrial development brings (Berryman et al. 2013, p. 8). As such, Frontier Mine Project ICA recommendations are aimed at not only mitigating Frontier Mine Project contributions to cumulative impacts, but also for maintaining and potentially improving the state of current linkages through offset programs and protection plans.
Offset programs and protection plans are seen as a way of strengthening the linkages between the nine activities and the twelve cultural values. As a result, Teck would be contributing to efforts designed to increase the strength of the Fort McKay Métis “cultural fabric”, so that it may better withstand the pressures industry is imposing on their way of life. A stronger linkage (and stronger fabric) means that any stress the Frontier Mine Project would place on the cultural fabric would be less significant.
Mitigation measures are designed to lessen the stress that the Frontier Mine would place on Fort McKay Métis culture. Mitigations do not eliminate
impacts. The mitigation measures are largely drawn from the MMSC August 2015 SIR #4 response to the Teck Frontier Mine Project (MMSC 2015) (Appendix D). In that submission, the FMMCA lists 117 key concerns and requests, many of which are mitigation measures. At the time of writing this ICA, Teck had not yet formally responded to the MMSC and so for consistency, the requests made in that
document are adopted by the ICA. A more detailed discussion of how these concerns and requests integrate with the ICA is included below in Section 16.4.
Monitoring for adaptive management and increased participation in land use planning and resource management decisions around Fort McKay are
fundamental, overarching concepts supporting all ICA recommendations.
Also underlying all the Frontier Mine Project ICA recommendations is the idea
that all programs, plans and measures should work to strengthen the relationship
with the whole Fort McKay community. The Fort McKay Métis see the community
as an interconnected Aboriginal community and want to work closely with the First Nations. As mentioned by community members (Section 11), relations between Métis and First Nations leadership have been strained recently, but Métis will always consider all First Nation members to be family and want all the recommendations to consider how they can keep this relationship healthy and strong.
The following sections summarize ICA recommendations for the Frontier Mine Project according to the following themes:
1. Increased participation in land use planning and resource management:
o Specific to the Frontier Mine Project.
o Support for regional participation.
2. Offsets:
o As discussed in the individual activity sections
3. Protection:o Of important traditionally used lands and watersheds.
o Of important places.
o Of important customs/traditions.
o Of important skills and knowledge.
4. Mitigations to address cumulative and project-specific contributions:
o Environmental Mitigations:
§ Loss of land;
§ Changes in access to land;
§ Changes in animal abundance;
§ Pollution;
§ Changes in water levels and fish habitat;
§ Sensory Disturbance.
o Social Mitigations:
§ Increased population;
§ Loss of agency/power;
§ Industry and government policy;
§ Increased participation in the wage economy.
5. Monitoring:
o Changes in Industry and government-induced stressors placed on Fort McKay; and
o Effectiveness of the mitigation, protection and offset recommendations listed above.
16.1 Increased Participation in Regional Land Use Planning and Resource Management
Underlying all the Frontier Mine Project ICA recommendations is the need for Fort McKay Métis to have increased participation in land use planning and resource management decisions around Fort McKay. Currently provincial government land use planning excludes Métis communities.
This is supported by the findings initially presented in The Fort McKay Cultural Heritage Assessment Baseline(2010a), which concluded that the impact from development on Fort McKay culture as of 2008 was significant and adverse (FMIRC 2010). It is also supported by the findings of the 2013 Joint Review Panel for the Jackpine Mine Expansion, which relied on the Cultural Heritage
Assessment to find the following:
[1742] [p.289] The Panel is of the opinion that people’s cultures are naturally evolving and that the adverse aspects of cultural changes can be mitigated when people have control over the changes experienced in their daily life. In order to mitigate the adverse effects on the land use and culture of Fort McKay and the other Aboriginal groups, the Panel has recommended greater involvement of First Nation and Métis Groups in regional planning and in the stewardship of the traditional resources.
Fort McKay Métis must be more involved in regional land use planning if
significant impact on Métis culture is to be addressed. MMSC has been building their capacity to participate in various initiatives and engage more effectively with government and industry.
“We need to be able to work together as a community to decide these things in order for us to be able to take it to the table, to leadership, or to industry and say o.k., this is what we want. This. And it is going to benefit the whole community. Not just us today, but our grandchildren and our great- grandchildren.” (ID#99, Fort McKay Cumulative Effects Study Workshop 2 2012 in Berryman et al. 2013).
At a regional level, FMMCA recommends Teck provide support, financially and in
kind, to FMMCA efforts to address broader issues related to Métis rights and
regional land use planning initiatives, including:
• Support to FMMCA consultation and participation in land planning and development near Fort McKay in order to protect land for traditional use by Fort McKay Métis in reasonable proximity to Fort McKay;
• Support for the Fort McKay Métis to participate in collaborative management of traditional territory and its resources, including partnering in environmental monitoring and development of management strategies;
• Support for development of reclamation planning and criteria, in consultation with Fort McKay Métis, that is aimed at restoring the land for traditional and other uses by the community, and that incorporates the knowledge held by Fort McKay Métis members regarding the land prior to disturbance;
• Long-term economic arrangements to provide social and physical
infrastructure and assist the community to prepare for and transition to a post oil sands economy; and
• Measures to promote, sustain and protect the health, security, well-being and economic development of the Métis community.
In addition to this the Fort McKay Métis also recommend in August 2015 (Appendix D) that Teck support:
[1] Teck funding and support for ongoing cumulative effects assessments of impacts on Fort McKay’s traditional territory and rights so that
constructive and decisive measures can be developed to address cumulative effects within Fort McKay’s traditional territory, and
[2] that Teck develop and implement, in collaboration with Fort McKay, a Working Group created by Teck, follow-up programs and monitoring that specifically determine if the EIA projections and assumptions are valid and accurate and if proposed mitigation is effective.
16.2 Offset Programs
Offsets are recommended as a means of potentially strengthening the state of current linkages between the nine activities and the twelve cultural values in the Fort McKay Métis cultural model. As mentioned earlier, offset programs are seen as a means of strengthening individual linkages (and overall cultural fabric), thereby lessening the significance of the Frontier Mine Project’s contribution to cumulative effects.
In some cases, offset strategies include cultural management strategies aimed at providing opportunities for community members to rebuild value-linkages through alternate means. As an example, if community members are trapping less, and thus no longer able to instill values linked to trapping such as
understanding nature, adaptability, self-reliance, etc., perhaps there are other
ways (such as participation in cultural camps or environmental monitoring programs) to instill those same values.
In January 2016, HEG explored ideas for offsets with Fort McKay Métis members.
Through facilitated discussions, community members were asked to describe why they thought specific programs or other types of community investment would benefit Métis culture.
The following recommendations are grouped into general programs as they were presented in each of the activities Sections in this report. Sub-programs within the larger programs are briefly outlined to give an idea of the types of initiatives that might be considered. The exact structure and content of the offset programs would need to be finalized in discussion with MMSC, Fort McKay Métis community members and Teck.
Traditional Food Security System
Developing a Traditional Food Security System centers around a community- based approach to ensuring Fort McKay Métis members have access to traditional meats, fish and plants. The details will need to be finalized in consultation with MMSC, Teck, and the federal and provincial Crown, but it would involve support for a group of members who would go out and collect country or traditional food (hunt, fish or gather berries), another group of Métis members who would prepare it for distribution to community members (such as skinning and butchering the meat or cleaning and filleting fish), and another group of community members to coordinate the programs and oversee distribution. The community would need appropriate cold storage (e.g. commercial freezers) that the food would be stored in, and Fort McKay Métis members would be able to get country or traditional food from the cold storage as required. Also associated with this would be annual feasts to honour all of the Métis members who contribute to the program.
Participation in this type of program can help to strengthen some of the value linkages traditionally instilled through harvesting of wild foods.
Cultural Camps
The idea of a Cultural Camp was raised repeatedly as a means of reviving traditional land use pursuits and strengthening cultural values. Initially, community members envision an annual event open to the entire community that provides an opportunity for Métis families and multi-
generational groups to camp and spend time together passing on skills and
traditions tied to land based activities such as Hunting, Trapping, Fishing and
Gathering Plants. This of course creates circumstances that support other
important cultural activities such as Getting Together (including traditional music and dance), Storytelling and Spiritual Practices.
There were a number of variations of this concept that were discussed during Frontier Mine Project ICA workshops and MMSC would like to work with
community members and Teck to finalize the exact structure. The spectrum of camps that could be considered, include:
• Survival camps: This is an approach suggested for smaller groups of youth or young adults to learn from experienced hunters and trappers.
Community members suggested that in this case, only limited food is brought with the group, and the majority is sourced in traditional way.
Supplies are kept to a minimum and tools, skills and materials applied in the bush are based on traditional knowledge.
• Teaching camps: Focused more on kids and youth, with Elders as teachers. Kids would be taught traditional skills such as making and setting snares, how to make dried meat and bannock, how to weave or how to identify berries and other plants. Elders would also tell traditional stories and share photos and stories about Métis families from Fort McKay.
• Trapping camps: Looks more closely at just trapping, using traditional knowledge and techniques. Fort McKay Métis members who still have active trap lines would guide the program. It was suggested this could be integrated with provincial trapping certificate program.
Cultural Center
Fort McKay Métis members want their children to be proud of their Métis heritage. As a means of increasing pride in Métis culture and awareness of how important Métis people have been in shaping the history of the Lower Athabasca Region, community members would like to see a Métis Culture Centre established in Fort McKay.
Fort McKay Métis members repeatedly mentioned the need for a gathering place where Métis cultural programming could be based. The members did not know exactly what the centre would look like, but they indicated it needed to have the following characteristics:
• It needed to be located in Fort McKay, preferably close to the Ells or Athabasca Rivers.
• The center needs to be open on a regular basis. Even if programming
wasn’t taking place on a specific day, the centre should be open for
people to get together. Community members believe this would
encourage more spontaneous, casual gatherings of people, which would help rebuild community relationships.
• The design of the cultural center could incorporate or have space for teepees, sweat lodges and traditional healing sites.
• It could be integrated into a small Fort McKay Métis museum.
• It should not duplicate the role that the existing youth center,
recreation center and the Elders center fill, but should integrate and build off those programs and fill in some of the missing cultural
programming.
• Would be the location for much of the cultural programming mentioned in the following offset program.
Cultural Programming
This would cover a wide array of programs and activities, focused on re- building and maintaining Métis culture. Some of the programs suggested included:
• Cree language classes.
• Music classes (fiddle, guitar, singing, drumming, “calling” for square dances).
• Dancing classes (jig, square dance, round dance, tea dance).
• Storytelling classes: traditional stories, such as those involving “Witiko”.
• Métis history classes: Fort McKay Métis and regional Métis history.
• Fort McKay Métis Family Archives: This could include programs for Fort McKay members to be video-recorded telling stories about life in the past. This could also include Fort McKay Métis members collecting and cataloging photographs of Métis members.
• Traditional healing, working with local members and perhaps involving a medicine man or woman who comes into the community regularly.
• Support for Métis celebrations such as Métis Days Social Services and Programming
Social services and programs are a key need for the Fort McKay Métis, as mentioned in many of the activity sections. The ability to access social
services and programming in Fort McKay would lessen many of the negative
cumulative impacts that the Frontier Mine Project will contribute to. Fort
McKay Métis members identified the following social programs as a way Teck
can help the community strengthen links to culture values:
• Youth programming that integrates Métis Elders and the work that is being done at the Fort McKay youth centre.
• Special programs for Métis Elders building off the programs at the existing Elders centre.
• Support for FMMCA to implement the Fort McKay Métis Housing Strategy.
• Community enhancement beautification programs (paving sidewalks, adding street lighting, community gardens).
• Dog control: spay and neuter programs and working closely with the existing dog catcher.
• Addictions Treatment Programming: Community members feel a variety of treatment options are needed, some based in the community and some based outside, where Fort McKay Métis members can get away for a while. Community members believe healing strategies need to be integrated into an overall program that incorporates training for employment and other incentives that can encourage individuals to finish treatment.
• Support enhanced security, perhaps a camera on the road into McKay, perhaps neighbourhood watch programs.
• Surveys of Métis perceptions annually.
Transportation Programming
Different transportation needs exist in the community. Transportation needs include programs for:
• Travel out to hunting, trapping, fishing and plant gathering sites.
Cumulative loss of land, reduced access to land, and reduced water levels in the Athabasca have made it more and more difficult for Métis community members to access undisturbed areas.
Compounding this effect is the fact few Fort McKay Métis members have vehicles or drivers licences. To facilitate access to harvesting areas for Elders, as well as other community members that lack the means to travel long distances, FMMCA would like to see Teck support in providing flights or other transportation to remote locations such as Moose Lake.
• Regular bussing between Fort McKay and Fort McMurray would help
reduce the strain a number of issues are putting on Fort McKay Métis
members. Providing regular, scheduled transportation service would
help people deposit cheques, pay bills, book appointments and shop
for food and other necessities in Fort McMurray. Ideally, trips could
also be timed so that they allow community members to also take
advantage of programs being offered at the Fort McMurray Friendship Center (such as Bingo and Conversational Cree time).
Community members believe a small fee could be charged similar to the bussing program that used to be in place several years ago, but industry support could help make this program sustainable.
• Fort McKay Métis members want to see the navigability of the Athabasca River improved so that they can travel safely by boat to visit friends and family in Fort McMurray and Fort Chipewyan and to make it easier, faster, and safer for them to reach traditional camps and harvesting areas. The ability to travel on the rivers (the
Athabasca and its tributaries) is fundamental to maintaining critical aspects of their Métis heritage and keeping their history alive. Métis community members remember when the Athabasca River was dredged, safe channels were marked and their relatives helped maintain river safety as snag pullers and scow-pullers. FMMCA want to reopen discussions and explore options with industry and the RMWB and the government for improving travel on the Athabasca River.
Employment and Procurement
Employment, procurement and contracting are ways that industry can enhance the positive regional effects from industry and strengthen cultural linkages. The following are some of the ideas Fort McKay Métis members discussed in relation to the Frontier Mine Project:
• Establish targets for Fort McKay Métis employment and contracting values at the Frontier Mine Project site for construction and operation phases.
• Establish procurement programs to support small business, including start up, training, mentoring, support, etc.
• Develop employment contracts that integrate time off of work so Fort McKay Métis members can undertake traditional activities such as hunting, trapping, fishing and gathering plants.
Hiring Procedures
Hiring protocols are a specific offset that Fort McKay Métis mentioned
numerous times during the workshops for this report. They specifically want
the Frontier Mine Project to establish hiring protocols that will allow good Fort
McKay Métis workers who do not have a high school diploma to be hired for
specific jobs and provided internal training capacity support.
Training and Capacity Building
Training and capacity building are priorities for Fort McKay Métis. A variety of training programs would be of interest to Fort McKay Métis members, but generally they indicated training programs should have the following characteristics:
• Training should be located in Fort McKay.
• A living allowance should be provided to members who are attending training.
• Training should be offered in variety of disciplines:
o regular oil and gas jobs;
o environmental monitoring;
o food safety and cooking;
o social services such as Elder care, child care and counseling services.
• Training that results in employment should be a priority.
• Training should include upgrading for those who don’t have a high school diploma.
• Post secondary education General Agreements
Teck must finalize and sign a Benefits Sharing Agreement with MMSC as a means of formally outlining the relationship between Teck and Fort McKay Métis, and provide structure for many of the mitigation, Protection Plans and Offset Programs that are included in this Section.
16.3 Protection
Fort McKay Métis members would like to see the establishment of protected areas for traditional land use that are in reasonable proximity to the community, and contain sufficient undisturbed areas that support traditional resources.
Community planning documents have identified some special areas that Fort McKay Métis members would like to see receive some level of protection from development. The most common desire is to see a protective buffer around Moose Lake established. The rationale for this has been presented to the
government of Alberta and industrial operators in several documents, including the Conserving Opportunities for Traditional Activities by the Community of Fort McKay Amongst the Industrial Landscape or Northeast Alberta (2013), A
Community Approach to Landscape Planning (2013) and the Fort McKay
position paper on LARP (2015). Over the last two generations, Moose Lake has become an even more important place to Fort McKay Métis members, since it is seen as one of the last “clean” places they can harvest wild foods and escape the sights, smells and sounds of oil sands development. However, Moose Lake facilities are currently on the Fort McKay First Nations Reserve. While Métis
members are currently “allowed” to stay at Moose Lake, some Fort McKay Métis members would feel more confident that future generations will have a place to pursue traditional activities if land was designated for use by the Fort McKay Métis community specifically. Fort McKay Métis members also have strong ties to McClelland Lake, MacKay River, Tar River, the Ells River and of course, the
Athabasca River. Although they would love to see protected areas close to these culturally significant waterways, given provincial policies towards bitumen extraction within surface mineable areas, Métis community members believe it is unlikely that protected areas would ever be established within these watersheds.
Lands in the Birch Mountain Park along the Buffalo (Namur) and Moose (Gardiner) Lake is seen as the most realistic option.
When it is not possible to protect large tracts of land, FMMCA would like to see special places and features (for example burials, important access trails or harvesting areas) protected within development areas. With respect to the Frontier Mine Project, in SIR#4, Request [53] Fort McKay requests that Teck meets with Fort McKay to discuss how it might support the community with access to and preservation of special places identified in the Traditional Land Use study.
FMMCA would like to explore this idea further with their membership to identify priority areas that could be protected for Métis harvesting and other cultural activities.
16.4 Mitigation
Mitigations are aimed at lessening impacts caused by development; they do not
necessarily eliminate the impact (stressors) that industrial development places on
Fort McKay Métis culture. In their August 2015 submission to Teck, Fort McKay
Métis stated that based on their technical review, they do not consider the
mitigation measures outlined in Section 6 of the Frontier Mine EIA to be adequate
as they would not substantially reduce or ameliorate Project effects on Fort
McKay’s Aboriginal Rights. Specific concerns related to the contributions the
Frontier Project will make to cumulative effects in Fort McKay’s Territory, and the
extent to which these effects continue to impact Fort McKay Métis current and
future generations’ traditional livelihood, existence, culture and traditional
economy were outlined in their submission: Fort McKay’s review of Teck
Resources Ltd. Frontier Oil Sands Mine Project Integrated Application. Project
Update June 2015 and Supplemental Information Request No. 4 (August 2015).
The ICA correlates August 2015 requests for mitigation by using [ ]. A table listing each August 2015 request by number [#] is provided at the end of this section.
At the time of writing this ICA, Teck had not yet formally responded to these requests.
To help provide a more fulsome understanding of the how these mitigation requests support the findings of the ICA and the FMMCA and MMSC’s
overarching goals of reducing impacts to Fort McKay Métis culture, the ICA links the mitigation requests provided in August 2015 (Appendix D) to the “stressors”
that have been discussed as affecting each of the nine activities. This will help MMSC to trace project contributions to cumulative industrial pressures over time.
To minimize the negative and enhance the positive effects the Frontier Mine Project has on Fort McKay Métis culture, MMSC has recommended a series of mitigation measures related to:
1. Environmental mitigations to address cumulative and project-specific contributions to stressors affecting Fort McKay Métis Culture:
o Loss of land;
o Changes in access to land;
o Changes in animal abundance;
o Pollution;
o Changes in water levels and fish habitat;
o Sensory disturbance.
2. Social mitigations to address cumulative and project-specific contributions to stressors affecting Fort McKay Métis Culture:
o Increased population;
o Loss of agency/power;
o Industry and government policy;
o Increased participation in the wage economy.
16.3.1 Environmental Mitigations
The following sections discuss environmental mitigations suggested to reduce
impacts to traditional, lands, waters and resources. A complete list of MMSC
requests for mitigations is in Table 16- 1 presented at the end of Section 16.
Loss of Land
To mitigate loss of land in areas that can’t be protected, MMSC made a number of recommendations (MMSC 2015):
• Reclamation [5, 6, 68- 73, 75 – 77, 79, 98 – 100, 102 – 109]
• Trapper Compensation [9]
• Wetlands [64 – 66]
The Frontier Mine Project ICA adopts past mitigation recommendations to accelerate reclamation of disturbed areas in the oil sands area (FMIRC 2010b, Nishi et al. 2013; Berryman et al. 2013). Fort McKay Métis would like to have discussions with Teck regarding some areas they would like to see reclaimed as soon as possible.
In the past, other general mitigation recommendations for reducing impacts related to linear disturbance (seismic lines, roads, well pads) have been made for example in Berryman et al (2013):
• Increase directional drilling for in situ well pads;
• Increased spatial overlap for pipelines and roadways;
• Construct narrower seismic lines, which would reclaim faster than wide lines;
• Increase the reclamation rate for surface mines (reduced from 30 to 20 year lifespan) and in situ (reduced form 40 year to 20 year lifespan) features;
• “Pulse” reclamation of existing seismic lines, where a certain percentage of legacy seismic lines are actively reclaimed each year.
Changes in Access to Land
To mitigate changes in access to land, MMSC have requested that Teck develop and finalize an access management plan (AMP) in consultation with MMSC, and that it includes mitigations to concerns expressed by Fort McKay in order to meaningfully practice traditional activities. Recommendations [7, 8, 60], also relate to access management.
Changes in Animal Abundance
To mitigate changes in animal abundance; in particular moose, caribou, bison
and fisher refer to MMSC (2015) recommendations
[10 – 19, 22-24],Pollution
To mitigate pollution effects, refer to MMSC (2015) recommendations:
• Air: [29 – 33, 80 – 83, 85 – 89]
• Groundwater: [34 -36, 90 – 97]
• Surface Water: [40 – 44, 47 – 52]
• Fish – [55-56]
Air quality and odours are of major concern the Métis. In line with the First Nation, the Fort McKay Métis would like to see:
•
Limits on air emissions to keep them well within Fort McKay’s air quality permissible levels;
•
Reduction of existing emissions and use of Best Available Technically and Economically Achievable emission control technology; and
•
Fort McKay Métis wants to be a partner within the comprehensive monitoring system that reports on the sources of emissions as well as the resultant impacts within the environment, including air quality and odours.
Changes in Water levels and Fish Habitat
To mitigate Frontier Mine Project contributions to changes in water levels and fish habitat refer to MMSC (2015) recommendations
[38, 39, 54, 57-58, 61].Fort McKay Métis made a number of specific recommendations related to aquatic resources in their recent position paper on the Lower Athabasca
Regional Plan (June 2015). The FMMCA were involved in developing this position paper and as such adopt the recommendations put forward in Section 3:
Surface Water Management, Section 4: Groundwater Management, Section 5:
Tailings Management Framework, and Section 7: Watershed Management.
Fort McKay Métis believe that one key approach to protecting surface water, groundwater, fish and aquatic ecosystems is to develop appropriate watershed management plans. Such plans set protection levels up front that provide
direction for appropriate levels and timing of development; land disturbance limits and thresholds; setbacks; groundwater, surface and wastewater
management practices; reclamation; and ecological thresholds and limits (FMSD 2015).
Due to significant development pressures and high cultural sensitivity, Fort McKay
Métis have identified priority areas for the development of detailed watershed
management plans including the following (FMSD 2015):
• Muskeg River watershed;
• MacKay River watershed;
• Namur and Gardiner lakes watershed; and
• Ells River.
The MMSC would like to explore Métis priorities for developing watershed management plans for other areas, for example the Tar River or Firebag River.
The Phase 2 Water Management Plan for the Athabasca River should be implemented with a minimum flow level required for the river.
Sensory Disturbance
The noise, light, odour and other sensory disturbances created by the Frontier Mine Project will negatively Fort McKay Métis’ ability to undertake traditional activities. To mitigate impacts caused by increased sensory disturbance refer to MMSC (2015) recommendations for
Noise: [27-28, 113].16.3.2 Social Mitigations
The ICA suggests a broader approach to monitoring be considered and
supported by Teck: specifically, a monitoring program that helps FMMCA track and understand:
• Ecological, social and economic factors affecting culture (stressors);
• The way the community and cultural activities are is responding to
ecological, social and economic changes (value-based indicators); and
• If management strategies and programs are having the desired effect (value-based indicators).
Systematically tracking information in a way that is designed to answer key questions will help the FMMCA make informed management decisions and develop better tools for coping with these changes.
The following sections discuss social mitigations suggested to reduce impacts to community services, well-being and economies.
Increased Population
To mitigate impacts caused by increased populations refer to MMSC (2015)
recommendations
[115]: Workforce: and [114] Traffic.Loss of Agency/Power
See recommendations in Section 16.1 related to increase participation in regional land use and resource management planning.
Industry and Government Policy
Continue to work with MMSC to address the issues raised in this document.
Increased Participation in the Wage Economy
To mitigate impacts caused by an increase in the wage economy, see
[111, 112].16.5 Monitoring
FMMCA believe long term monitoring is key to understanding if mitigation, protection and offset measures are having the desired effect. This includes monitoring changes in the stressors affecting Fort McKay Métis culture, and in the ways in which culture is changing in response to these stressors.
To help understand linked natural and human activity systems present in Fort McKay Métis culture, the Frontier Mine Project ICA has applied a number of mutually supportive conceptual frameworks. These include participatory action research and collaborative inquiry, soft systems methodologies (Meadows, 2008), ecosystem properties (Holling 1986), and values-based thinking (Keeley 1992;
Keeney 1996). Based on this work, the Fort McKay Métis have suggested a number of value-based indicators that they feel can be used to help track improvements or deterioration in activity-value linkages. These value-based indicators have been presented for each of the nine activities (Section 6-17) and are summarized in Appendix B. A number of indicators were also selected to track changes in “stressors”. These are also presented for each activity, and summarized in Appendix C.
So what I recommend has to happen, if we're going to track quality of
meat and animals ... we have to do it scientifically. I think that that's
the only way that we are going to be able to prove what the Elders
are saying. That the meat is different. For instance fish, they say the
meat is, is mushy. It's not firm like it's supposed to be.... The quality of
meat isn't there. I think the only way we're going to be able to do this
is if we do a comprehensive scientific study. We test the quality of
meat. That way you'll have data to compare to annually and make it
an annual thing, I mean, the only way we're going to beat them is
their own knowledge, ... under their own terms. I’m not, how do you
say “Aboriginal versus industry” I’m talking about government.
(FMM005-WS2)
A community based monitoring program (CBM) that integrates all environmental and socio cultural monitoring efforts and reports back to the community is the model that Fort McKay Métis want to see for the Frontier Mine Project. A CBM would have some of the following characteristics:
• The design and implementation of the program would be a collaboration amongst Métis members, MMSC, consultants, Teck and academics.
• It would include a training component for Fort McKay Métis members.
• It would support long term research initiatives and involve field work to collect samples at sites of interest.
• A key deliverable would be scientific and plain language reports to Fort McKay Métis members.
• Results of this research would be discussed and disseminated through regional groups to industry, government and policy-makers to shape policy.
Monitoring initiatives of interest to Fort McKay Métis include:
• Aquatic ecosystem health initiative;
• Cultural and traditional landscape protection;
• Wildlife population and health;
• Traditional food supply and distribution (traditional food security system);
• Land use access planning and coordination; and
• Reclamation.
MMSC project-specific recommendations related to monitoring and the Frontier project were presented in Fort McKay’s review of Teck Resources Ltd. Frontier Oil Sands Mine Project Integrated Application. Project Update June 2015 and Supplemental Information Request No. 4 (MMSC 2015). The ICA adopts these recommendations:
[4] – Fort McKay supports the above measures listed by Teck in Section 17.6.3 of the Project Update and requests that Teck commits to ensuring that it monitors, follows-up and tracks these commitments to the satisfaction of Fort McKay throughout the project’s life.
Wildlife
[21] - Fort McKay requests that Teck describes the model validation for the wildlife health assessment models and develops a monitoring program to confirm model predictions on wildlife.
[25] - Fort McKay requests that Teck provides additional detail on the monitoring methods that will be used to determine the passageway’s effectiveness and maintenance of connectivity in the Athabasca River corridor. Teck’s response should include a power analysis (e.g., to determine the number of required cameras) and a contingency plan if the underpass is not effective (e.g., installing overpasses and underpasses).
Aquatic resources
[46] - Fort McKay requests that Teck provides results and/or reports on any studies into pit lake sediments and transfer of contaminants to aquatic food webs.
[63] - Fort McKay requests that Teck consults with them about all project-specific aquatic monitoring plans, including community-based monitoring (CBM).
Vegetation Wetlands
[67] - Fort McKay requests that Teck includes Fort McKay in the development and review of wetland monitoring programs. These monitoring programs should focus on wetlands adjacent to the Planned Development Area (PDA) to assess the effects of potential hydrologic alterations to intact wetlands adjacent to the mine disturbance. In addition, a program should be designed and implemented to mitigate any wetland effects that occur.
Non-native vegetation
[74] - Fort McKay requests that Teck implements a monitoring and control program for non-native and invasive species during the project’s construction, operation, reclamation and closure phases to ensure that these species do not invade disturbed sites and compete with native species.
Biodiversity
[78] - Fort McKay requests that Teck commits to establishing a biodiversity
research and monitoring program to better understand changes in biodiversity on reclaimed sites over time and assesses how to increase biodiversity on the post- reclamation landscape
Air and Human Health
[32]: Fort McKay requests that Teck confirms that regardless of regulatory
requirements Teck will install a continuous ambient air monitoring station between its central processing facility and Fort McKay and will consult with Fort McKay on the exact siting of this station.
The following table is a copy of Appendix A of Fort McKay’s review of Teck Resources Ltd. Frontier Oil Sands Mine Project Integrated Application. Project Update June 2015 and Supplemental Information Request No. 4 (MMSC, 2015).
This full submission is included as Appendix D of the ICA.
Number
Fort McKay Key
Concerns Requests Category*
Cumulative Effects Key Concerns 1 Cumulative
Effects Assessment
Fort McKay Métis requests that Teck supports, with funding and data, an ongoing and updated cumulative-effects assessment of impacts on Fort McKay’s Traditional Territory and rights so that constructive and decisive measures can be developed to address cumulative effects within Fort McKay’s Traditional Territory.
Industry
2 Cumulative Effects Assessment
Fort McKay Métis requests that Teck develops and implements, in collaboration with Fort McKay, in a Working Group created by Teck, follow-up programs and monitoring that specifically determine if the EIA projections and assumptions are valid and accurate and if proposed mitigation is effective.
Industry
Access Management Key Concerns 3 Access
Management Plan
Fort McKay Métis requests that Teck develops and finalizes an access management plan (AMP) in consultation with Fort McKay, and that it includes mitigations to concerns expressed by Fort McKay in order to meaningfully practice traditional activities.
Industry
Traditional Land Use Key Concerns 4 Mitigation
Monitoring Fort McKay Métis supports the above measures listed by Teck in Section 17.6.3 of the Project Update and requests that Teck commits to ensuring that it monitors, follows-up and tracks these commitments to the satisfaction of Fort McKay throughout the project’s life.
Industry
5 Reclamation Fort McKay Métis would like to collaborate with Teck to develop a mitigation and an offset plan in relation to the adverse effects and loss of key cultural and traditional use areas that would be affected by the plan in the Frontier Project Update.
Industry
Number Fort McKay Key Concerns
Requests Category*
6 Reclamation Fort McKay Métis requests that Teck:
i) formalizes a process with Fort McKay outlining how Community input would be part of a jointly developed reclamation criteria development for the Teck Frontier mine; and
ii) supports Aboriginal involvement in developing reclamation criteria in regional committees and research organizations.
Fort McKay Métis also requests assurance from the provincial and federal governments that reclamation criteria will be developed with Aboriginal involvement with the Teck lease and will be binding and upheld during the reclamation certification process and once Teck has returned the land to the Crown.
Industry
Government Agencies 7 Access Fort McKay Métis requests that Teck formalizes an agreement with Fort McKay to
support developing an access management plan on the West side of the Athabasca River than takes into consideration the bridge across the Athabasca River that Teck is proposing in the Project Update.
Industry
8 Trappers Fort McKay Métis requests that Teck establishes access management plans, in
collaboration with Fort McKay, to facilitate Fort McKay community member access to trap lines and other traditional use areas throughout the life of the mine.
Industry
9 Trappers Fort McKay Métis requests that Teck confirms it will continue ongoing consultation with affected trappers regarding project development and provide compensation or implement mitigation measures as needed following the Fort McKay Trapper Compensation Guidelines.
Industry
Wildlife Key Concerns 10 Wildlife
Surveys Fort McKay requests that AMERA validates breeding bird and wildlife survey data and
presents the results to Fort McKay for review. Government
Agencies
Number Fort McKay Key Concerns
Requests Category*
11 Wildlife
Surveys The term “comparable” does not express the expected scientific rigour considering the amount of survey data collected. Fort McKay requests a more scientific description (i.e., statistics) of how the bird and wildlife community compares to other areas of the RSA. Information should include population parameters, community diversity measures, and changes over time, if detected.
Industry
12 Wildlife
Surveys Teck has completed several years of wildlife surveys yet it is unclear if enough data has been obtained to meet the baseline survey objectives. Fort McKay requests that Teck completes an analysis to ascertain if sufficient surveys have been completed to determine if all wildlife species have been detected (e.g., analyze cumulative
observations of species per visit) and if survey effort has been sufficient to confirm the absence of species of concern. Fort McKay also requests that Teck shares the survey data with Fort McKay.
Industry
13 Wildlife
Surveys Fort McKay requests that Teck reviews the scientific rigour of the bird survey methods it employed in comparison to current EIA guidelines (requirement for replication of surveys). Fort McKay wishes to understand the scientific limits of the methods used by Teck and the potential need for additional field work.
Industry
14 Wildlife
Surveys Teck has delayed the mine development. Fort McKay requests that through the work already done and in progress at the Roland Lake Bison Heard Technical Team Teck uses the best and most recent data and information available to redefine the bison herd boundary and study areas and reanalyze impacts to bison.
Industry
15 Wildlife Surveys
Fort McKay is concerned about bison, it is a traditional use species and its sustainable populations are important for Fort McKay’s exercise of its Aboriginal and Treaty rights.
Fort McKay requests that Teck addresses sample size issues with regard to monitoring impacts on bison.
Industry
Number Fort McKay Key Concerns
Requests Category*
16 Wildlife
Surveys Fort McKay Métis requests further discussion with Teck on the extent of the wallow surveys and if they extended into the LSA and how the presence of wallows might be indicative of bison distribution and seasonal land use.
Industry
17 Wildlife
Assessment Fort McKay Métis requests that Teck provides a more detailed explanation for no longer using RNV in the EIA to evaluate environmental consequence. In addition, Fort McKay would like to know how removing RNV improves the EIA.
Industry
18 Wildlife
Assessment Fort McKay Métis requests that Teck becomes an active participant in CEMA or other multi-stakeholder organizations that include Aboriginal participation regarding wildlife issues.
Industry
19 Wildlife
Assessment Fort McKay Métis is concerned that Teck limited the scope of connectivity analysis based on female caribou data. Fort McKay requests that Teck ensures connectivity of caribou populations in the three caribou ranges near the project by securing
movement corridors.
Industry
20 Wildlife Health Assessment
The wildlife health assessment predicts that the project will not adversely affect wildlife.
Fort McKay community members will be skeptical of the results. Teck should consider writing a plain-language wildlife health assessment for the public and the non-expert readers. Teck should also be prepared to explain the wildlife health assessment to the Community of Fort McKay.
Fort McKay Métis request that Teck supports a Fort McKay Métis Community based monitoring project that assesses culturally based indicators associated to population, habitat health and traditional food supply ratio for Aboriginal peoples that are dependent on Caribou.
Industry
21 Wildlife Health Assessment
Fort McKay Métis requests that Teck describes the model validation for the wildlife health assessment models and develops a monitoring program to confirm model predictions on wildlife.
Industry
Number Fort McKay Key Concerns
Requests Category*
22 Wildlife Health Assessment
Fort McKay Métis requests that Teck provides references for the weights of wildlife species used in the wildlife health assessment and confirms that they are
representative of wildlife found in the LSA.
Industry
23 Wildlife Health Assessment
There is a discrepancy in the diets of the wolverine used in the Teck updated EIA (wildlife health and wildlife habitat assessments). This would change the predicted wolverine habitat use and chemical exposure through ingestion. The correct diet should be determined and the assessment predictions adjusted.
Industry
24 Mitigation and Monitoring
Fort McKay Métis requests that Teck summarizes the scientific support for the planned underpass dimensions for maintaining connectivity. In addition, Fort McKay requests that Teck discusses other options to allow wildlife passage and connectivity in the Athabasca River corridor such as additional underpasses, overpasses, and alternate bridge designs. The feasibility and costs of options should also be discussed.
Industry
25 Mitigation and Monitoring
Fort McKay Métis requests that Teck provides additional detail on the monitoring methods that will be used to determine the passageway’s effectiveness and
maintenance of connectivity in the Athabasca River corridor. Teck’s response should include a power analysis (e.g., to determine the number of required cameras) and a contingency plan if the underpass is not effective (e.g., installing overpasses and underpasses).
Industry
Number Fort McKay Key Concerns
Requests Category*
26 Mitigation and Monitoring
Fort McKay Métis requests that Teck develops a scientifically robust WMMP prior to project approval. Fort McKay Métis restates its requests to be involved in the WMMP’s development.
Fort McKay Métis request that Teck supports a Fort McKay Métis Community based monitoring project that assesses culturally based indicators associated to population, habitat health and traditional food supply ratio for Aboriginal peoples that are dependent on Caribou.
Industry
Noise Key Concerns 27 Noise
Complaint Process
Fort McKay Métis requests that Teck supports establishing a Noise Complaint Process that will hear and respect Community complaints around audible noise.
Fort McKay Métis requests that Teck supports Fort McKay Métis to develop a noise monitoring pilot project to determine acceptable sound levels for traditional use and wildlife (including migratory birds).
Industry
28 Best Practice beyond Directive 038
Fort McKay Métis requests that Teck will work with the Community of Fort McKay to mitigate impacts of audible noise, even though it might be in compliance with AER Directive 038.
Industry
Number Fort McKay Key Concerns Requests Category
Number Fort McKay Key Concerns Requests Category
Air Quality Key Concerns
29 Acid Deposition
and Effects Fort McKay Métis requests that Teck and AER acknowledge that fugitive-dust related base cation emissions cannot be used in offsite PAI calculations as the expectation is that there will be no or minimal offsite dust deposition.
Industry Government Agencies 30 Co-generation
NOx Emission Limits
Fort McKay Métis requests that Teck and the regulators acknowledge that Fort McKay considers that BATEA for co-generation units is SCR and Fort McKay cannot support the NOx emission limits currently being proposed by Teck for its co-
generation units.
Industry Government Agencies
31 Co-generation NOx Emission Limits
Fort McKay Métis requests that the regulators acknowledge that no NOx approval limits should be set for the co-gen units at this time and if an EPEA approval is issued for the project it should indicate that NOx emission limits will established for these units when design details for the unit are being finalized and equipment procurement is planned to occur within a year period.
Government Agencies
32 Compliance or Attribution Continuous Ambient Air Quality Monitoring Requirements
Fort McKay Métis requests that Teck confirms that regardless of regulatory
requirements Teck will install a continuous ambient air monitoring station between its central processing facility and Fort McKay and will consult with Fort McKay on the exact siting of this station.
Industry
33 Air Emission and Ambient Air Monitoring
Fort McKay Métis requests that Teck confirms with Fort McKay Métis its
expectations regarding support for and participation on CEMA and WBEA and that this issue is addressed in any Environmental and Socio-cultural Agreement the Community enters into with Teck.
Industry
Number Fort McKay Key Concerns Requests Category
Groundwater Key Concerns
34 Seepage
Control System Fort McKay Métis requests that Teck provides the opportunity to review annually performance reports on the seepage control wells and estimates of the percent of process-affected seepage captured by the wells.
Industry
35 Seepage
Control System Fort McKay Métis requests that Teck consults with the Community on whether or not it is considered feasible to install the interceptor trench earlier, i.e., before operations cease, if there are indications of process-affected seepage flowing downgradient of the interceptor wells that might travel beyond the proposed location of the interceptor trench by the time of closure.
Industry
36 Seepage
Control System Since far future seepage modelling suggests the potential for off-site migration to the southeast of the ETAs, Fort McKay Métis requests that Teck considers the alternative of continuing to operate the active hydraulic control system (i.e., with pumping wells) for a longer period of time beyond operations.
Teck to develop a comprehensive GWMP and will allow MMSC an opportunity to provide input into the Plan. Also, Teck will provide updates of monitoring results to MMSC on a regular basis and to have an adaptive management plan in place in case monitoring indicates a problem.
Industry
Hydrology/Surface Water Key Concerns
37 Athabasca River and Tributary Water Use
Fort McKay requests that Teck drops all plans for using tributary water as a fresh water source and obtains its entire fresh water supply from the Athabasca River.
Industry
Number Fort McKay Key Concerns Requests Category 38 Athabasca
River and Tributary Water Use
Fort McKay requests that, should Teck not change its Water Act application, AER deny Teck’s proposal to use pristine water from tributaries and diversion channels associated with the Frontier Project.
Government Agencies
39 Athabasca River and Tributary Water Use
Fort McKay requests that Teck ensures that all pristine water in the stream diversion system is diverted around the project and not through the OSSP situated in the Unnamed Creek 2 valley.
Fort McKay Métis request that Teck agrees to support Fort McKay Métis community based monitoring project to assess water diversion and water quality in the
unnamed creeks identified. Teck and the regulators should be aware of the consequences any form of diversion will have on Fish and the quality and quantity of connected watershed in the project area.
Industry Regulatory/Go vernment Agency
40 Athabasca River and Tributary Water Use
Fort McKay requests that Teck drops all plans for using tributary water as a fresh
water source and obtains its entire fresh water supply from the Athabasca River. Industry
41 Athabasca River and Tributary Water Use
Fort McKay requests that, should Teck not change its Water Act application, AER deny Teck’s proposal to use pristine water from tributaries and diversion channels associated with the Frontier Project.
Government Agencies
Number Fort McKay Key Concerns Requests Category 42 Athabasca
River and Tributary Water Use
Fort McKay requests that Teck ensures that all pristine water in the stream diversion system is diverted around the project and not through the OSSP situated in the Unnamed Creek 2 valley.
Fort McKay Métis request that Teck agrees to support Fort McKay Métis community based monitoring project to assess water diversion and water quality in the
unnamed creeks identified. Teck and the regulators should be aware of the consequences any form of diversion will have on Fish and the quality and quantity of connected watershed in the project area.
Industry Regulatory/Go vernment Agency
Water Quality, Fish and Fish Habitat Key Concerns
43 Process Water
Seepage Fort McKay requests that Teck provides contingency plans and potential
mitigation if the barrier walls and seepage capture of the External Tailings Areas do not perform as anticipated in preventing seepage from contaminating groundwater and surface waters.
Fort McKay Métis requests that Teck commits to provide funds and allow MMSC to jointly participate with Teck and other stakeholders in the monitoring of the ETA and connecting tributaries or nearby water courses
Industry
44 Process Water
Seepage Fort McKay Métis requests that Teck assesses the potential impacts of discharging up to 40 L/s (3500 m³/d; Figure 7-13) of process-affected seepage to the fish habitat compensation lake.
Fort McKay Métis requests that Teck commits to provide funds and allow MMSC to jointly participate with Teck and other stakeholders in monitoring the Fish
compensation lake.
Number Fort McKay Key Concerns Requests Category 45 Surface Water
and Sediment Quality
Fort McKay requests that Teck adds dibenzothiophene in sediments to the list of monitored substances for any watercourses downstream of the project, plus sediments of pit lakes and the FHCL.
46 Surface Water and Sediment Quality
Fort McKay requests that Teck provides assurance that the analytical laboratories contracted for water and sediment analyses are capable of achieving detection limits at criteria intended to protect aquatic life.
47 Muskeg and Overburden Drainage - Mercury
Fort McKay requests that Teck models mercury and methylmercury loadings to the FHCL and any downstream waters, including the Athabasca River, considering uptake by piscivorous fish. Models should consider the potential methylmercury production and augmentation of mercury export by muskeg and overburden drainage activities under both the Application and Planned Development (cumulative impact) cases.
48 Pit Lake Residual Toxicity and Research
Fort McKay Métis requests that Teck commits to ongoing participation in pit lake research, including studies of bottom sediments and possible contaminants transfer through the aquatic food chain, as well bioturbation and wind-induced sediments resuspension.
49 Pit Lake Residual Toxicity and Research
Fort McKay Métis requests that Teck provides results and/or reports on any studies into pit lake sediments and transfer of contaminants to aquatic food webs.
50 Pit Lake Residual Toxicity and Research
Fort McKay Métis requests that Teck provides further discussion about the fate and transport of napthenic acids and PAHs over time in its pit lakes, and discuss those substances that are expected to exceed effects benchments, notably in
sediments.
Number Fort McKay Key Concerns Requests Category 51 Derivation of
Site-Specific Guidelines
Fort McKay Métis requests that Teck accepts published CCME guidelines for all substances for which they are available until such time as CCME or a provincial government agency evaluates and approves the newly-derived CEBs presented by the company.
52 Derivation of Site-Specific Guidelines
Fort McKay Métis requests that Teck provides a tabulated comparison of CCME guidelines to its site-specific guidelines (CEBs) for those substances where guidelines exist.
53 Derivation of Site-Specific Guidelines
Fort McKay Métis requests that Teck address the potential impact and toxicity of mixtures of contaminants that might all occur simultaneously.
54 Aerial Emissions and Snowmelt Concentrations
Fort McKay Métis requests that Teck provides an update of the cumulative impacts of aerial emissions in surface waters, including any further snow survey results.
Fort McKay Métis requests that Teck commits to Support Fort McKay Métis
community based monitoring program to participate in monitoring run-off effects of melt-ice on key fish bearing streams that are traditional food sources to the community.
55 Aerial Emissions and Snowmelt Concentrations
Fort McKay Métis requests that Teck commits to sharing with the Community snowmelt data that exceed water quality guidelines, as soon as possible, not just upon request.
Number Fort McKay Key Concerns Requests Category 56 Loss of
Traditionally Significant Surface Waters
Fort McKay Métis requests that Teck meets with Fort McKay to discuss how it might support the Community Based Monitors with access to and preservation of special places, including but not limited to, habitation sites in the Frontier Project lease and the Moose Lake area.
Fort McKay Métis is requesting this to ensure the work of Fort McKay CBM is not hindered.
Fort McKay Métis commits to work with Teck to develop a very transparent and mutually respected joint CMB data collection and reporting protocol.
57 Fish Rescue from Destroyed or Diverted Streams and Lakes
Fort McKay Métis requests that Teck confirms that it will rescue all fish species from all aquatic habitats that will be destroyed or diverted, that support fish during any season, and that it will not limit the rescue operations to only those waters that support large-bodied fish species.
Fort McKay Métis requests that Teck commits to support and jointly work with MMSC monitors in the rescue and re-introduction of captured fish in to suitable aquatic habitats that are specific to their healthy growth and development.
Fort McKay Métis requests that Teck commits to maintaining the habitats to a functioning capacity that ensures healthy growth of the populations, both existing and introduced fish.
58 Tissue Residue Guideline - Mercury
Fort McKay Métis requests that Teck provides justification and further information about the source of information, species and size of fish that show a current concentration that is very low (0.058 mg/kg), and that presumably was used in the prediction of a future concentration that is correspondingly low.
Number Fort McKay Key Concerns Requests Category 59 Tissue Residue
Guideline - Mercury
Given that Teck’s calculation of future fish tissue residue for mercury under the application case is close to seven times higher than the current level, Fort McKay Métis requests that Teck addresses impacts to wildlife consumers of fish that might be caused (the future predicted level is more than ten times higher than the TRG to protect wildlife consumers of aquatic biota).
Fort McKay Métis requests that Teck commit to support MMSC’s community based monitoring program to assess correlation of the food chain between wildlife and fish. The goal is to understand whether there is a correlation in the high levels of mercury in Fish and animal tissues and or fur.
Number Fort McKay Key Concerns Requests Category 60 Accounting for
Residual
Impacts on Fish Abundance and
Productivity
Fort McKay Métis requests that Teck:
i) clarifies statements that indicate effects on fish abundance are not anticipated in the aquatics LSA, when it is known that the compensation lake will not likely account for all losses in the LSA;
ii) provides values and percent reduction of low flows (e.g., 7Q2, 7Q10) in addition to reduction in mean annual flows, including whether there might be occasions when there is no flow in these watercourses compared to the current scenario, since fish might occur in the lower reaches of Big and Redclay creeks during any open water season;
iii) identifies which species will lose habitat in Big Creek and Redclay Creek that will not benefit from the compensation lake;
iv) justifies ranking residual effects to fish as ‘reversible’ and ‘medium duration’ when the timespan to reversibility spans several generations of most species; and
v) discusses possible mitigative solutions that might provide additional instream flow needs to these watercourses rather than gradually diminishing flows over the course of operations, given the cause of lost habitat in lower Big and Redclay creeks is lack of flow (due to withheld or re-directed water).
61 Pit Lakes as Fish
Habitat Fort McKay Métis requests that Teck further explains the functionality as fish habitat and planned incorporation into local ecosystems of its large end pit lakes that will be located far from fish that might naturally colonize them.
62 Fish Habitat
Offsetting Plans Fort McKay Métis requests that Teck summarizes how its calculations (HADD versus
“serious harm to fish”) related to fish habitat offsetting might have changed for the Updated project scenario as a result of recent amendments to the Fisheries Act (input values, not compensatory plans).
