KITSAULT MINE PROJECT ENVIRONMENTAL ASSESSMENT. Section Summary of Commitments

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Section 24.0

Summary of Commitments

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TABLE OF CONTENTS ... 24-I 24.0 SUMMARY OF COMMITMENTS ... 24-1 24.1 Summary of the Proponent’s Commitments ... 24-1

List of Tables

Table 24.1-1: Summary of the Proponent’s Commitments ... 24-1

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24.0 SUMMARY OF COMMITMENTS

This section presents the Kitsault Mine Project (proposed Project) Project commitments in tabular format as per the approved Application Information Requirements (AIR).

24.1 Summary of the Proponent’s Commitments

Table 24.1-1 presents Avanti Kitsault Mine Ltd. (proponent)’s commitments based on the

project design, mitigation, monitoring and follow-up, consultation, and the Environmental

Management System (EMS).

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Table 24.1-1: Summary of the Proponent’s Commitments

Commitment

Number Commitment Project Phase

Source of Commitment (by

Section)

Responsible Agency Status

Consultation

1 The proponent must continue with the consultation program established during the pre-Application period and must adhere to the proposed consultation program during the EA review period.

Pre-certificate 4.3 4.4 4.5

BC EAO Pending

Environmental Management Plans

2 Prior to the commencement of construction activities, the proponent would implement an EMS for the proposed Project according to the framework outlined in Section 11 of the Application. The following EMPs must be developed:

 Air Quality Management Plan;

 Aquatic Resources Management Plan;

 Archaeology and Cultural Heritage Resources Management Plan;

 Construction Management Plan;

 Dust Management Plan;

 Emergency and Spill Response Plan;

 Erosion and Sediment Control Plan;

 Hazardous Materials Management Plan;

 Hazardous Waste Management Plan;

 Mine Waste Management Plan;

 Noise Management Plan;

 Occupational Health and Safety Plan;

 Reclamation and Closure Plan;

 Recruitment, Training and Employment Plan;

 Soil Management Plan;

 Solid Waste Management Plan;

 Tailings and Mine Water Management Plan;

 Transportation and Access Management Plan;

 Vegetation Management Plan;

 Waste Water Management Plan; and

 Wildlife Management Plan.

The proponent must consult with the Nisga’a Nation and Aboriginal groups with respect to site-specific mitigation and management strategies.

C, O, D/C, PC 11 BC MEM

BC MOE BC MOTI

Archaeology Branch DFO

EC BC EAO

Pending

Monitoring and Follow-up Program

3 The proponent must develop and implement monitoring and follow-up programs which meet and / or exceed regulatory requirements as stated in the proposed Project permits, approvals, and authorisations. The following must be developed:

 Atmospheric monitoring and follow-up program;

 Water Quality Monitoring and Management Plan;

 Aquatic effects monitoring and follow-up program;

 Marine monitoring program;

 Fish and fish habitat monitoring and follow-up program;

 Terrain and geotechnical monitoring and follow-up program;

 ML/ARD monitoring and follow-up program;

 Soils monitoring and follow-up program;

 Vegetation monitoring and follow-up program; and

 Wildlife monitoring and follow-up program.

C, O, D/C, PC 22.3 BC MEM

BC MOE DFO EC BC EAO

Pending

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Commitment

Section)

Monitoring and follow-up programs must be developed in consultation with the proposed Project’s RAs, DFO and NRCan. The proponent must also consult with other federal government agencies, provincial government agencies, the Nisga’a Nation and Aboriginal groups to ensure the monitoring and follow-up programs meet applicable provincial and federal permits and authorisations, and consideration of community interests.

4 The proponent commits to an adaptive management approach at the proposed Project site. To facilitate this adaptive management approach, the proponent must make an effort to develop, define, and monitor clear, measurable indicators and / or thresholds where relevant.

C, O, D/C, PC 11.1 11.2.21 22.3

BC MEM BC MOE DFO EC BC EAO

Pending

Air Quality

5 The on-site meteorological station must be operated for the life of the proposed Project. C, O, D/C, PC 22.3.4.1 EC

BC MOE

Pending

Noise

6 Noise control equipment must be used and maintained on all equipment. C, O, D/C, PC 11.2.12 BC MEM Pending

Water Quality

7 The proponent must conduct water treatment, if needed, to meet water quality objectives. C, O, D/C, PC 6.6, 6.7 BC MOE

EC

Pending

8 EEM programs must be implemented to monitor downstream aquatic effects, to meet federal and provincial requirements. C, O, D/C, PC 6.6 BC MOE EC

Pending

9 An ongoing water quality monitoring and management plan must be implemented to comply with discharge permits. C, O, D/C, PC 6.6 BC MOE

EC

Pending

Water Management

10 Diversions must be constructed to minimise contact water discharges. C, O 11.2.2 BC MEM

BC MOE EC

Pending

11 The water balance must be updated with ongoing site data collection and the Water Management Plan adjusted as required to manage water on-site and prevent uncontrolled releases.

C, O, D/C 11.2.20 BC MEM

BC MOE EC

Pending

Aquatic Resources

12 The Fish Habitat Compensation Program must be implemented and monitored to follow the final Fisheries Act Authorisation requirements. C, O, D/C 11.2-A DFO Pending 13 The proponent must institute a No Fishing policy for all of the proponent’s employees and contractors while engaged in their work on the proposed Project. C, O, D/C, PC 6.7 BC EAO

BC MOE

Pending

14 EEM programs must be implemented to monitor downstream aquatic effects, to meet federal and provincial requirements. C, O 12 and 22.3 BC MOE EC

Pending

15 The proponent must implement the provisions in the final Water Management Plan. These must include erosion and sediment control, as well as BMPs regarding water usage.

C, O 6.4-B BC MEM

BC MOE EC

Pending

16 The proponent must follow the provisions provided in Schedule 5 of MMER. This includes effluent characterization, sublethal toxicity testing and water quality monitoring

C, O 11.2.2 EC

BC MOE

Pending

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Commitment

Section)

Vegetation and Plant Communities

17 Prior to construction, the proponent must develop a site map of important environmental features, including old forests, riparian areas, wetlands, ecosystems at risk, to be considered during final footprint alignment and identification of construction laydown areas.

C 6.10 BC MOE

EC

Pending

18 Prior to construction, the proponent must conduct a timber-cruise survey to assess the amount, age, and condition or timber, including cedar that overlaps with the proposed Project footprint development. Based on the amount of high-quality cedar that cannot be avoided, the proponent must work with relevant agencies and the Nisga’a Nation to determine mutually beneficial options for the end use of cut cedar trees.

C 6.10 MFLNRO Pending

Wildlife and Their Habitat

19 Prior to works around wetlands and ponds during the amphibian breeding period (from mid-May to late June) or mass dispersal (early to mid-August), the proponent must survey water bodies and shorelines for western toad breeding or dispersal activity that could be affected by the proposed Project.

C,O 6.11 11.2.21

BC MOE EC

Pending

20 The proponent must schedule vegetation clearing activities outside of the general breeding bird period between 1 April and 31 July where practical. If clearing is required during this period, surveys must be conducted no more than seven days prior to work taking place to identify and avoid active ground and tree nests that could be affected by the proposed Project.

C 6.11 11.2.21

BC MOE EC

Pending

21 In suitable habitat, the proponent must survey the immediate area of works for the nests of eagles, peregrine falcons, ospreys, herons, and burrowing owls. If a nest is found where clearing is required, the proponent must consult with BC MOE and EC to and determine appropriate avoidance or mitigation strategies.

C 6.11 11.2.21

BC MOE EC

Pending

22 Prior to construction, the proponent must develop a bear management plan in consultation with BC MOE. This plan must include consideration to fencing in areas of increased risk to wildlife and human safety.

C 6.11 11.2.21

BC MOE Pending

23 The proponent must develop and implement a No-Hunting Policy for all mine employees and contractors on site and during Project-related transport along the transportation route.

C, O, D/C, PC 6.11 11.2.21

BC EAO Pending

24 During winter ploughing, the proponent must provide breaks in snow banks where feasible along the FSR used for access to the mine site to allow wildlife escape routes from the road.

C, O, D/C, PC 6.11 11.2.21

MFLNRO Pending

25 The proponent must manage solid waste associated with the proposed Project in a way that minimises wildlife attraction and reduces the risk of wildlife- human interaction.

C, O, D/C, PC 6.11 11.2.21

BC MOE Pending

Reclamation and Closure

26 The proponent must reclaim the mine site following the prescriptions in the Closure and Reclamation Plan. These include site preparation, placement of reclamation material, fertilizer application as needed, and re-vegetation.

D/C, PC 11.2.14 BC MEM Pending

Geochemistry

27 The proponent must confirm and / or update geochemical characterisation and source-term predictions for the proposed Project. This would include:

 Data collection and ongoing characterisation of waste rock, low-grade ore, tailings, and construction material;

 Ongoing inventorying of waste and low-grade ore production and placement for future assessments of facility performance;

 Monitoring of water chemistry (seeps, pit wall run-off, supernatant); and

 Updates of the water and load balance to verify and / or refine water quality predictions for the proposed Project.

C, O, D/C, PC 3.4.4.2 BC MEM

BC MOE

Pending

Economic

28 The proponent must seek to recruit employees from the LSA, particularly from the Nisga’a communities. C, O, D/C, PC 7.2.3 BC EAO Pending

29 The proponent must insist that its contractors comply with the proponent’s policies related to recruitment, training, safety, procurement, and environmental responsibility, to the extent practical.

C, O 7.2.3 BC EAO Pending

30 The proponent must use local and regional suppliers when these suppliers can provide products and services at competitive prices and timeframes C, O 7.2.3 BC EAO Pending Social

31 The proponent commits to training programs for the unemployed and under-employed, and changes to employment packages to meet individual and family needs.

C, O 8.2.2 BC EAO Pending

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Commitment

Section)

32 The proponent must give preference to candidates with Grade 12 education and to those that are committed to completing their Grade 12 on a part-time basis while working at the proposed Project.

C, O 8.2.6

8.2.7

BC EAO Pending

33 The proponent must provide a flexible rotating schedule that could vary based on the needs of the local hires. C, O 8.2.6 BC EAO Pending

Heritage

34 Employees and contractors of the proponent must be aware of and follow the procedures outline in the Chance Find Procedure. C, O, D/C, PC 11.2.3 Archaeology Branch Pending

Project phase: C - construction; D/C - decommissioning and closure; O - operations; PC - post-closure

Note: BC EAO - British Columbia Environmental Assessment Office; BC MEM - British Columbia Ministry of Energy and Mines; BC MFLNRO - British Columbia Ministry of Forests, Lands and Natural Resource Operations; BC MOE - British Columbia Ministry of Environment; BC MOTI - British Columbia Ministry of Transportation and Infrastructure; BMP - Best Management Practice; DFO - Fisheries and Oceans Canada; EA - Environmental Assessment; EC - Environment Canada; EEM - Environmental Effects Monitoring; EMP - Environmental Management Plan; EMS - Environmental Management System; FSR - Forest Service Road; LSA - Local Study Area; ML/ARD - metal leaching / acid rock drainage; MMER - Metal Mining Effluent Regulations; RA - Responsible Authority; NRCan - Natural Resources Canada

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