appendix 10.12 · reduce gullying and channel erosion by developing robust and sustainable...
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Appendix 10.12: Established or Asserted Aboriginal and Treaty Rights, Current Use of Lands and Resources for Traditional Purposes or Physical and Cultural Heritage and Mitigation Measures, per Indigenous Group February 2018
Frontier Oil Sands Mine Project Appendix 10.12
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February 2018
TABLE OF CONTENTS
1 Athabasca Chipewyan First Nation ........................................................................................................ 1
2 Fort Chipewyan Métis Local 125 ......................................................................................................... 15
3 Fort McKay First Nation ....................................................................................................................... 28
4 Fort McKay Métis ................................................................................................................................. 41
5 Fort McMurray Métis Local 1935 ......................................................................................................... 54
6 Lac La Biche Métis Local 1909 ............................................................................................................ 66
7 Métis Nation of Alberta Region 1 ......................................................................................................... 78
8 Mikisew Cree First Nation .................................................................................................................... 90
9 References ......................................................................................................................................... 103
9.1 Personal Communications ......................................................................................................... 105
LIST OF TABLES
Table 10.12-1: Athabasca Chipewyan First Nation Rights, Land Uses and Cultural and Physical Heritage Features ......................................................................................................... 1
Table 10.12-3: Fort Chipewyan Métis Local 125 Rights, Land Uses and Cultural and Physical Heritage Features ....................................................................................................... 15
Table 10.12-4: Potential Adverse Environmental Effect and Mitigation Table – Fort Chipewyan Métis Local 125 .................................................................................................................... 16
Table 10.12-5: Fort McKay First Nation Rights, Land Uses and Cultural and Physical Heritage Features...................................................................................................................... 28
Table 10.12-6: Potential Adverse Environmental Effect and Mitigation Table – Fort McKay First Nation ......................................................................................................................... 29
Table 10.12-7: Fort McKay Métis Rights, Land Uses and Cultural and Physical Heritage Features . 41 Table 10.12-8: Potential Adverse Environmental Effect and Mitigation Table – Fort McKay Métis ... 42 Table 10.12-9: Fort McMurray Métis Local 1935 Rights, Land Uses and Cultural and Physical
Heritage Features ....................................................................................................... 54 Table 10.12-10: Potential Adverse Environmental Effect and Mitigation Table – Fort McMurray Métis
Local 1935 (Métis Local 1935) ................................................................................... 55 Table 10.12-11: Lac La Biche Métis Local 1909 Rights, Land Uses and Cultural and Physical Heritage
Features...................................................................................................................... 66 Table 10.12-12: Potential Adverse Environmental Effect and Mitigation Table – Lac La Biche Metis
Local 1909 .................................................................................................................. 67 Table 10.12-13: Métis Nation of Alberta Region 1 Rights, Land Uses and Cultural and Physical
Heritage Features ....................................................................................................... 78 Table 10.12-14: Potential Adverse Environmental Effect and Mitigation Table – Métis Nation of
Alberta Region 1 ......................................................................................................... 79 Table 10.12-15: Mikisew Cree First Nation Rights, Land Uses and Cultural and Physical Heritage
Features...................................................................................................................... 90 Table 10.12-16: Potential Adverse Environmental Effect and Mitigation Table – Mikisew Cree First
Nation ......................................................................................................................... 92
Frontier Oil Sands Mine Project Appendix 10.12
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1 Athabasca Chipewyan First Nation
A summary of established or asserted Aboriginal and treaty rights, current use of lands and resources for
traditional purposes and cultural and physical heritage features as described by Athabasca Chipewyan
First Nation (ACFN) is presented in Table 10.12-1.
Table 10.12-1: Athabasca Chipewyan First Nation Rights, Land Uses and Cultural and Physical Heritage Features
Established or Asserted Aboriginal and Treaty Rights, Current Use of Lands and Resources for Traditional
Purposes
Cultural and Physical Heritage Feature
Hunting for sustenance and livelihood, as well as for ancillary practices
Fishing for sustenance and livelihood purposes, as well as for ancillary practices
Trapping for sustenance and livelihood purposes, as well as for ancillary practices
Gathering for sustenance and livelihood purposes, as well as for ancillary practices
Access the land for traditional use practice according to traditional patterns of activity and occupation
Safe water quality and adequate water quantity
Sufficient lands and resources, which includes: o Routes of access and transportation o Construction and habitation of cabins and other
infrastructure o Water quality and quantity o Healthy populations of preferred fish and game in
preferred harvesting areas o Cultural and spiritual relationships with the land o Abundant berry crops in preferred harvesting areas o Traditional medicines in preferred harvesting areas o Timber in preferred harvesting areas o The experience of remoteness and solitude on the
land o Feelings of safety and security o Lands and resources accessible within constraints of
time and cost o Sociocultural institutions for sharing and reciprocity o Spiritual sites
Use and enjoyment of Reserve lands
Engage in, preserve, and enhance cultural and spiritual practices
Traditional way of life
Sharing
Individual and community health and wellbeing
Language
Cultural practices
Traditional knowledge
The land, which sustains the heart of ACFN culture, traditions, identity, spirituality and rights
ACFN cultural protection areas
ACFN traplines, reserves, the Athabasca River and its tributaries, and the Peace-Athabasca Delta
Site-specific cultural or spiritual values
Potential adverse Project effects on ACFN’s established or asserted Aboriginal and treaty rights, current
use of lands and resources for traditional purposes or cultural and physical heritage are presented in
Table 10.12-2, along with mitigation proposed by ACFN in their TLU study (Candler and Firelight 2013)
and mitigation that Teck has committed to implement to reduce these potential effects of the Project. The
ACFN CIA is currently not available. On October 12, 2016, Teck was informed by letter that ACFN would
not be providing Teck with a copy of the ACFN-led CIA unless ACFN chooses to submit the CIA to the
JRP as part of ACFN’s evidence for the public hearing. On April 24, 2017, Teck was informed by letter
that:
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[ACFN] does not expect to produce a single "Cultural Impact Assessment", written by a
consultant or academic, which filters the complexity of Project impacts on our nation and
members through a colonial lens for ease of consumption on a project-specific basis. In our
experience, Cultural Impact Assessments leave "lost in translation" the voices of our Elders,
our values, and the obligations that Dene law imposes upon us in our interactions with the
environment (amongst other things).
Teck respects the views of ACFN and appreciates the information ACFN has provided to date as part of
consultation activities and the Project regulatory process. Teck agrees that potential Project effects on
ACFN culture are best assessed by ACFN, as is also the case for other Indigenous communities.
As noted elsewhere in Teck’s submissions, Teck’s preferred approach to developing mitigation and other
commitments identified in traditional land use or traditional knowledge studies, or other submissions, is to
seek to negotiate long term agreements directly with Indigenous groups. Teck is continuing to pursue
negotiation and consensus building efforts with ACFN and will periodically update regulators on the
progress of those discussions.
Teck is committed to continuing discussions with ACFN and its members to determine how Project-
related and cumulative effects can best be addressed through mitigation and other measures. To that
end, Teck will work cooperatively with ACFN towards resolution of outstanding issues and concerns,
including discussion of the impacts, concerns and recommendations identified by ACFN.
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Table 10.12-2: Potential Adverse Environmental Effect and Mitigation Table – Athabasca Chipewyan First Nation
Potential Adverse Effects Mitigation Proposed by Athabasca Chipewyan
First Nation in TLU Study Mitigation Teck Commits to Implement
Hydrology and Water Quality
Changes in flows, water levels and open water areas
None. The Athabasca River will satisfy the Project’s makeup water requirements, and an off-stream storage pond (OSSP) will supply the Project with water during periods when river water withdrawal is restricted (see the response to Joint Review Panel (JRP) Information Request (IR) 10.26, Appendix 10.26, Section 7.1).
Teck commits to implement the following mitigation measures to reduce changes in flows and water levels in receiving waterbodies (see the response to JRP IR 10.25, Appendix 10.25, Table 10.25-1):
Reduce changes to flows in Ronald Lake by using a flow splitter on the Redclay Creek diversion during operations.
Reduce changes to flows in Big Creek by using a flow splitter on the Big Creek diversion during operations.
Distribute muskeg drainage operations through the mine life, thereby avoiding a large increase in flows in the receiving waters.
Reduce effects of closed-circuit operations on flows and water levels in receiving waters by diverting natural watercourses that will not be disturbed by the mining operations around the mining area to receiving watercourses.
Reduce river-water withdrawal requirements from the Athabasca River by maximizing closed-circuit recycling of surface and groundwater where practical, and by storing sufficient amounts of water in an off-stream storage pond in the event of extended withdrawal restrictions from the Athabasca River.
Progressively construct and develop diversion systems, which helps limit the change in open-water areas during construction and operation by providing new drainage channels to replace the loss of natural watercourses and waterbodies.
Reduce changes to flows and water levels in receiving waters by developing a closure drainage layout that will limit changes in drainage areas contributing flows to the receiving watercourses relative to predevelopment conditions.
Design watercourses, waterbodies and wetlands during reclamation to attenuate floods.
Teck is committed to continue to consult meaningfully with, and engage, all potentially affected Indigenous groups at both a Project-specific and regional level to reduce and mitigate potential Project and cumulative effects on hydrology and surface water quality, including continuing discussions regarding hydrology and surface water quality concerns and is prepared to consider additional mitigation measures to address these concerns (see the response to JRP IR 10.25, Appendix 10.25).
Teck has developed a Draft Hydrology and Water Quality Mitigation, Monitoring and Adaptive Management Plan (see the response to JRP IR 10.25, Appendix 10.25). Once finalized, the plan will include a communication management section, which will outline how findings of the program will be communicated to interested parties.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Changes in sediment yields, concentrations and channel regimes (geomorphology)
None. Teck commits to implement the following mitigation measures to limit release of Total Suspended Solids (TSS) (see the response to JRP IR 10.25, Appendix 10.25, Table 10.25-1):
Follow relevant regulatory guidelines, standards and best management practices during construction and operation to reduce the risk of increased sediment loadings to receiving watercourses.
Construct and operate sedimentation ponds to settle TSS where necessary.
Control sediment generation in diversion channels through revegetation of streambanks, overbank areas and berms as soon as possible after construction and by the use of channel armour (riprap), where required.
Direct muskeg and overburden drainage waters to polishing ponds equipped with oil-separation capability.
Reduce sediment yields from reclaimed surfaces by developing appropriate final topography and soil moisture conditions.
Resuspension of sediments from the bottom of polishing ponds, wetlands and pit lakes will be reduced through appropriate hydraulic design.
Reduce gullying and channel erosion by developing robust and sustainable reclamation drainage systems with built-in self-healing capability and robustness similar to natural drainage systems.
Teck commits to implement the following mitigation measures to reduce changes in flood flows and geomorphology downstream of the Project (see the response to JRP IR 10.25, Appendix 10.25, Table 10.25-1):
Limit changes in flood flows in receiving watercourses relative to predevelopment conditions. Mitigation measures listed for the “reduce changes in flows and water levels” above are relevant for mitigating flood flows.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Direct water emissions:
Muskeg drainage and overburden dewatering flows
Drainage from operating and reclaimed mine site
Basal water sands depressurization
Process-affected seepages from backfilled mine pits and tailings disposal areas
None. Teck commits to implement the following mitigation measures to limit the release of ions, nutrients, metals, polycyclic aromatic hydrocarbons (PAHs) and other parameters during operations and closure and protect sediment quality in downstream watercourses and waterbodies (see the response to JRP IR 10.25, Appendix 10.25, Table 10.25-1):
o Recycle process-affected waters and runoff within the Project disturbance area (PDA) in a closed-circuit system during operations.
o Using a perimeter ditch and groundwater wells to capture and pump back seepages and runoff from the external tailings areas (ETAs) back into the tailings areas during operations.
o Design the closure drainage system to capture seepage and runoff from ETAs, external disposal areas (EDAs) and the Frontier Project plant site and directing it to wetlands, pit lakes or constructed reclamation lakes during the mine closure management phase.
o Use wetlands, constructed reclamation lakes and pit lakes during and after the decommissioning and closure phases to provide biological remediation and settling of particulate materials in reclamation waters before discharge.
o Respond to spills using best management practices. Project activities will follow safety protocols designed to limit accidents and reduce effects if an accident should occur.
Teck commits to the following mitigation measures to manage depressurization water during preproduction (see Volume 1, Section 7.6.5 and 7.8.4 of the Project Update):
o Teck plans to manage depressurization water during preproduction by storing approximately half of it in a storage pond at surface and reinjecting the remaining half into the BWS aquifer.
Teck is committed to continue to consult meaningfully with, and engage, all potentially affected Indigenous groups at both a Project-specific and regional level to reduce and mitigate potential Project and cumulative effects on hydrology and surface water quality, including continuing discussions regarding hydrology and surface water quality concerns and is prepared to consider additional mitigation measures to address these concerns (see the response to JRP IR 10.25, Appendix 10.25).
Teck has developed a Draft Hydrology and Water Quality Mitigation, Monitoring and Adaptive Management Plan (see the response to JRP IR 10.25, Appendix 10.25). Once finalized, the plan will include a communication management section, which will outline how findings of the program will be communicated to interested parties.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Pit lake releases None. Teck will leverage the knowledge gained through its other reclamation efforts, along with research through regional initiatives such as Canada’s Oil Sands Innovation Alliance (COSIA), to develop healthy, functional ecosystems in the Project pit lakes (see the response to JRP IR 2.3).
Teck also commits to implement the following mitigation measures when designing closure drainage and pit lakes for hydrological sustainability and to promote effective passive treatment of process-affected waters and to
Frontier Oil Sands Mine Project Appendix 10.12
Table 10.12-2: Potential Adverse Environmental Effect and Mitigation Table – Athabasca Chipewyan First Nation (continued)
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Potential Adverse Effects Mitigation Proposed by Athabasca Chipewyan
First Nation in TLU Study Mitigation Teck Commits to Implement
support a viable aquatic ecosystem prior to release and to sequester tailings and other mine waste in the most appropriate location at mine closure (see the response to JRP IR 10.25, Appendix 10.25, Table 10.25-1):
Exclude tailings from pit lakes.
Do not release water from pit lakes until acceptable quality is achieved.
Maintain the water balance of the pit lakes with sufficient inflows to compensate for evaporative losses.
Manage the rate of Athabasca River water input to pit lakes as appropriate to confirm water quality filling targets are met and to comply with Athabasca river low flow restrictions.
Include wetlands reclamation lakes for treatment purposes in reclamation drainages to the pit lakes.
Teck is committed to continue to consult meaningfully with, and engage, all potentially affected Indigenous groups at both a Project-specific and regional level to reduce and mitigate potential Project and cumulative effects on hydrology and surface water quality, including continuing discussions regarding hydrology and surface water quality concerns and is prepared to consider additional mitigation measures to address these concerns (see the response to JRP IR 10.25, Appendix 10.25).
Teck has developed a Draft Hydrology and Water Quality Mitigation, Monitoring and Adaptive Management Plan (see the response to JRP IR 10.25, Appendix 10.25). Once finalized, the plan will include a communication management section, which will outline how findings of the program will be communicated to interested parties.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Changes in quality of groundwater and surface water downgradient of EDAs
None. Teck commits to implement the following mitigation measures to maintain surface water quality in consideration of surface flows into and out of the Project area and groundwater discharge (see the response to JRP IR 10.25, Appendix 10.25, Table 10.25-1):
Groundwater and surface waters draining EDAs will be captured if monitoring data indicate that the drainage waters are unsuitable for release.
Teck is committed to continue to consult meaningfully with, and engage, all potentially affected Indigenous groups at both a Project-specific and regional level to reduce and mitigate potential Project and cumulative effects on hydrology and surface water quality, including continuing discussions regarding hydrology and surface water quality concerns and is prepared to consider additional mitigation measures to address these concerns (see the response to JRP IR 10.25, Appendix 10.25).
Teck has developed a Draft Hydrology and Water Quality Mitigation, Monitoring and Adaptive Management Plan (see the response to JRP IR 10.25, Appendix 10.25). Once finalized, the plan will include a communication management section, which will outline how findings of the program will be communicated to interested parties.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Air Quality and Odour
NOX emissions None. Teck commits to implement the following mitigation measures to reduce NOX emissions from combustion sources (see the response to JRP IR 3.18, Table 3.18-1):
Use natural gas as a fuel for the cogeneration plant and boilers and heaters.
Dry low NOX technology to reduce NOX emissions and increase cogeneration plant efficiency.
Boiler and heater technology that will meet provincial and federal government emission requirements.
Purchase Tier IV compliant haul trucks when they become available.
Optimize mine planning to reduce haul distances.
Develop and implement an anti-idling program for the mine fleet.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
SO2 emissions None. Teck commits to implement the following mitigation measures to reduce SO2 emissions from combustion sources (see the response to JRP IR 3.18, Table 3.18-1):
Use natural gas as a fuel for the cogeneration plant and boilers and heaters.
Use ultra-low sulphur diesel for the mine fleet.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
PM2.5 and dust emissions None. Teck commits to implement the following mitigation measures to reduce PM2.5 emissions from combustion sources (see the response to JRP IR 3.18, Table 3.18-1):
Use natural gas as a fuel for the cogeneration plant and boilers and heaters.
Boiler and heater technology that will meet provincial and national government emission requirements.
Purchase Tier IV compliant haul trucks when they become available.
Optimize mine planning to reduce haul distances.
Develop and implement an anti-idling program for the mine fleet.
Teck commits to implement the following mitigation measures to reduce fugitive dust emissions (see the response to JRP IR 3.18, Table 3.18-1):
Dust mitigation measures to be applied to onsite roads during construction include appropriate selection of road materials, limiting vehicle speeds, surface watering, progressive reclamation, temporary vegetation of disturbed land and retain natural vegetation as windbreaks.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Hydrocarbon and reduced sulphur emissions and secondary organic aerosol precursor emissions
None. Teck commits to implement the following mitigation measures to reduce fugitive plant emissions (see the response to JRP IR 3.18, Table 3.18-1):
Use floating roof tanks where appropriate and a vapour recovery system to condense and recover vapours from storage tanks and process areas.
Use dual solvent vapour recovery units to provide full redundancy.
Conduct a leak detection and repair (LDAR) program to identify leaking components and to prioritize associated repairs.
Teck commits to implement the following mitigation measures to reduce fugitive mine face emissions (see the response to JRP IR 3.18, Table 3.18-1):
Mitigation not currently known.
Frontier Oil Sands Mine Project Appendix 10.12
Table 10.12-2: Potential Adverse Environmental Effect and Mitigation Table – Athabasca Chipewyan First Nation (continued)
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Potential Adverse Effects Mitigation Proposed by Athabasca Chipewyan
First Nation in TLU Study Mitigation Teck Commits to Implement
Teck commits to implement the following mitigation measures to reduce fugitive tailings area emissions (see the response to JRP IR 3.18, Table 3.18-1):
Tailing solvent recovery unit to maintain losses to less than four volumes of solvent to 1,000 volumes of bitumen produced.
Teck commits to implement the following mitigation measures to reduce hydrocarbon and reduced sulphur emissions from combustion sources (see the response to JRP IR 3.18, Table 3.18-1):
Use natural gas as a fuel for the cogeneration plant and boilers and heaters.
Purchase Tier IV compliant haul trucks when they become available.
Optimize mine planning to reduce haul distances.
Develop and implement an anti-idling program for the mine fleet.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Odour None Teck has developed a draft Odour Management and Response Plan (see the response to JRP IR 3.13, Appendix 3.13). The draft Plan. The Plan’s goals are mitigation, monitoring, participation in regional complaint process, and correlation of complaints to Project activities to determine response actions. The Plan will be finalized following consultation with Indigenous communities, regulators and stakeholders.
At any time during Project operation, nearby residences will be able to contact Teck if they are concerned that Project operations are causing odours. The contact will be documented, investigative action will be initiated to determine the potential source, and the caller will be notified. If a source can be identified, a review will be undertaken to implement corrective action to reduce the potential for future occurrences (ERCB Round 1 SIR 113a; Appendix 3.13).
Acoustics
Change in sound levels None. Teck has made an overall commitment to managing and promptly addressing all noise-related concerns (see Volume 3, Section 3.4.9.2, Project Update) and will develop a Noise Management Plan (see Volume 3, Section 3.4.9.1, Project Update).
Teck also commits to implement the following mitigation measures to reduce changes in sound levels (see Volume 3, Appendix 17H, Section 17H.5 of the Project Update and the response to JRP IR 1.3, Table 1.4-1):
Vehicles will be maintained in good working condition (e.g., mufflers will be maintained) and speed limits will be enforced.
Emergency alarms will be tested during daytime, where reasonably practical.
Acoustic performance of building wall construction will meet a minimum sound transmission class (STC) rating of 29, based on published data in the North American Insulation Manufacturers Association for a pre-engineered structure.
For outdoor equipment, the manufacturer incorporates mitigation in the equipment design to achieve the published sound power level.
Noise effects will be mitigated using various measures, including but not limited to the following:
o haul trucks exhaust silencer
o haul truck speed
o trip frequency (number of trips per daytime and nighttime period)
o route location or alignment
Ventilation openings (i.e., air intake and exhaust openings) will be fitted with appropriate acoustic silencers, louvers, or plenums, where applicable, to reduce outdoor sound transmission from indoor equipment.
Buildings housing indoor noise-generating equipment will be appropriately sealed to reduce noise.
Where practical, flanking path and penetrations from plumbing, heating ducts and electrical wire in the buildings will be properly insulated and covered to reduce noise.
Appropriate acoustical lagging will be installed to provide additional attenuation to the steel casing, where practical.
Vibration isolation pads, resilient mounts on equipment, resilient pipe support systems, and dampers will be installed where appropriate.
Teck will incorporate best management practices to reduce Project-related noise into Daily Operational Procedures, Long-Term Operational Procedures, design for low-noise facilities, and performance measurement as described in SPOG (2012) Best Practices Document, where appropriate (ERCB Round 1 SIR 116; Volume 3, Section 3.4.9.1 of the Project Update), including:
Daily Operational Procedures
Keeping compressor station doors and windows closed
Using belt dressing
Inspecting and repairing mufflers
Running fans slower at night (variable frequency drive [VFD])
Using vent silencers on buildings
Using soundproofing (insulation and lagging)
Troubleshooting transient noise
Minimizing flaring and venting
Considering gravel pack around compressor building skids
Developing noise check in daily reading sheets
Long-Term Operational Procedures
Responding quickly to noise concerns
Establishing baseline noise levels (in plant, at fence-line, or both) and resurvey to determine trends
Conducting regular assessment of noise control opportunities
Using best practical technology for noise control
Maintaining communication links with noise sensitive receptors and communities
Being aware of noise from contractors (e.g., service rigs) and developing processes to meet best practice expectations
Scheduling work to create the least amount of noise effects on noise sensitive receptors and keeping those affected informed
Frontier Oil Sands Mine Project Appendix 10.12
Table 10.12-2: Potential Adverse Environmental Effect and Mitigation Table – Athabasca Chipewyan First Nation (continued)
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Potential Adverse Effects Mitigation Proposed by Athabasca Chipewyan
First Nation in TLU Study Mitigation Teck Commits to Implement
Design for Low Noise Facilities
Considering low noise electric drives versus engine driven compressors
Designing cooler fans for low tip velocity
Orienting noise sources away from residents
Using acoustical pipe lagging
Installing VFDs on coolers
Performance Measurement
Conducting measurements and establishing baseline data
Using best practices as part of the company’s operating procedures
Visual
Change to visual environment None. Teck commits to implement the following mitigation measures to reduce changes to visual effects (see Volume 1, Section 8.3.6, Volume 3, Section 16.4.6, Volume 3, Section 18.10.4.2, Volume 3, Section 18.11.5.4 and Volume 3, Appendix 17H, Section 17H.7 of the Project Update):
Maintaining vegetated buffers between the Project and the Athabasca River as well as along Project transportation corridors to the extent feasible where safety concerns are not an issue.
Using construction materials that reduce contrast, limit visual attraction to Project features, and blending built structures into the natural surrounding environment.
Using construction materials, where practicable, that minimize light reflection, potentially reducing viewing distances of Project features
Reclamation techniques will be used that integrate closure plans with the surrounding landscape.
Teck will seek to develop closure plans that:
o Include integration and contouring of slopes that mimic natural topography.
o Focus on establishing a variety of vegetation communities.
o Avoid unnatural-looking breaks at development boundaries.
Planting a narrow band of white spruce along the edge of the river water intake (RWI) cofferdam and plant dogwood on the cofferdam, except in areas where tall vegetation would impede any maintenance or present safety concerns.
Completing reclamation in the RWI area to minimize erosion and slope instability.
Using lighting that minimizes light pollution.
At closure, infrastructure will be removed and the Project will be reclaimed using vegetation types similar, though not identical to existing conditions, creating a continuous vegetated landscape.
A lighting plan will be developed during future stages of engineering to avoid over-illumination. Lighting design will be part of future stages of engineering, and Teck will consult with interested Indigenous communities about lighting considerations.
Finish the Athabasca River Bridge with low-glare materials and plant vegetation buffers near the bridge. Teck also commits to clear minimal vegetation and to vegetate cleared areas.
Retain treed buffers around or near watercourses.
Fish and Fish Habitat
Change in productive fish habitat None. Fish habitat of equivalent or higher productivity than that affected by the Project will be created through offsetting measures where prevention of adverse habitat alteration or loss (i.e., reduced habitat productivity or loss of productive habitat area) is not feasible (see the draft Detailed Fisheries Offsetting Plan, the response to JRP IR 2.1, Appendix 2.1).
Teck also commits to implement the following mitigation measures to avoid or reduce changes in fish habitat quantity or quality (see the response to JRP IR 2.1, Table 5):
To avoid or reduce sedimentation:
o Temporary and permanent erosion and sediment control measures for construction activities and disturbed areas.
o Stabilization and revegetation of disturbed areas.
o Isolation of instream work areas where they are required.
o Best management practices and regulatory guidelines for construction activities in and near watercourses/waterbodies for erosion and sediment control.
o Polishing ponds or other measures to reduce suspended sediment concentrations in discharge waters to avoid increases in sedimentation in the receiving environment.
o Appropriate design of constructed channels and ponds to reduce internal erosion and generation of suspended sediments.
o Appropriate design and construction of reclaimed landscape to reduce sediment yield.
To avoid or reduce changes to water quality:
o Passing muskeg drainage and overburden water through polishing ponds and drainage ditches to reduce changes in water temperatures and dissolved oxygen concentrations.
o Recycling of process affected waters during operations.
o Capture and recycling of ETA seepage and run off water during operations, and use of a passive seepage control system at closure.
o Use of wetlands, pit lakes and constructed reclamation lakes in the closure drainage system to provide biological remediation before release to the environment.
o Removal of organic material from fish habitat compensation lake (FHCL) area prior to flooding.
To avoid or reduce changes to habitat area:
o Diversion of watercourses around the PDA to return natural upslope water back to the diverted watercourse to preserve flows and avoid elimination of downstream habitats.
o Provision of a flow splitter on the diversion channel that will collect water from both upper Redclay Creek and Unnamed Creek 17 to appropriately apportion the flows in lower Redclay Creek and Unnamed Creek 17 to avoid flow changes in the Ronald Lake watershed.
o Operation of the RWI and Off Stream Storage Pond (OSSP) in compliance with the Lower Athabasca River Surface Water Quantity Management Framework.
o Design of the closure drainage channels and pit lakes to provide habitats capable of supporting aquatic ecosystems.
o Best management practices and regulatory guidelines to ensure construction and operation of the RWI, Athabasca River bridge and watercourse crossings associated with access roads do not interfere with fish
Frontier Oil Sands Mine Project Appendix 10.12
Table 10.12-2: Potential Adverse Environmental Effect and Mitigation Table – Athabasca Chipewyan First Nation (continued)
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Potential Adverse Effects Mitigation Proposed by Athabasca Chipewyan
First Nation in TLU Study Mitigation Teck Commits to Implement
passage and access to available habitats.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Change in fish abundance None. Teck commits to implement the following mitigation measures to avoid or reduce changes in fish abundance (see the response to JRP IR 2.1, Table 5):
Fish rescue operations to capture and relocate fish prior to habitat dewatering.
Screening of the RWI in compliance with regulatory guidelines to mitigate fish entrainment or impingement.
Best management practices and regulatory guidelines for scheduling construction activities in and near waterbodies/watercourse to avoid sensitive time periods in adjacent or downstream fish-bearing watercourses.
Education of Project personnel on sustainable fishing practices to support a Teck applied prohibition on their fishing in watercourses or waterbodies in the PDA to mitigate potential increases in recreational fishing pressure.
Access Management Plan for the PDA to limit access to fish bearing habitats to mitigate increased fishing pressure.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Change in fish and fish habitat diversity None. Teck commits to implement the following mitigation measures to avoid or reduce changes in fish and fish habitat diversity (see the response to JRP IR 2.1, Table 5):
Several of the measures intended to avoid or mitigate effects to fish habitat and fish abundance also apply to fish and fish habitat diversity, in cases where they preserve fish and productive fish habitats or create new habitats, including:
o Diversions designed to preserve flows and avoid elimination of downstream habitats.
o Closure drainage channels and pit lakes designed to provide habitats capable of supporting aquatic ecosystems.
o Fish rescue operations.
o Screening of the RWI.
o Education and prohibition of Project personnel from fishing in the PDA.
o Access Management for the PDA to limit access to fish bearing habitats.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Wildlife
Change in wildlife habitat availability None. Teck commits to implement the following mitigation measures to reduce direct habitat loss (see the response to JRP IR 7.14, Table 7.14-1):
Limit the size of the east side access road right-of-way (ROW) and temporary workspace to the extent practical.
Limit the Athabasca River bridge footprint in riparian areas.
Carry out progressive reclamation to reclaim disturbed wildlife habitat as portions of the mine footprint become available.
Develop a weed management plan.
Teck commits to implement the following mitigation measures to reduce indirect habitat loss (see the response to JRP IR 7.14, Table 7.14-1):
Implement strategies to reduce noise and light effects, including design considerations (e.g., Frontier Project plant site engineering and aerodrome operation within regulatory and safety constraints).
Limiting employee and contractor access to identified areas of high-quality habitat adjacent to Project footprint.
Teck commits to developing a Biodiversity Management Plan (BMP) with the underlying goal of optimizing reclamation during operations to reduce offsetting of residual environmental effects (see the response to JRP IR 7.15).
Teck has developed a Draft Wildlife Mitigation, Monitoring and Adaptive Management Plan (WMMP; see the response to JRP IR 7.14, Appendix 7.14). Teck has proposed steps to Indigenous groups that would provide the opportunity for land users and community members to provide direct input into developing wildlife mitigation measures. Input will refine this draft WMMP. Once finalized, the plan will include a communication management section, which will outline how findings of the program will be communicated to interested parties.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Change in wildlife landscape connectivity None. Teck commits to implement the following mitigation measures to reduce change to landscape connectivity (see the response to JRP IR 7.14, Table 7.14-1):
Carry out progressive reclamation to restore habitat for movement as portions of the mine footprint become available.
To maintain connectivity between Birch Mountains and Athabasca River:
o Coordinate development activities with Canadian Natural Resources Limited (CNRL) who acquired the Pierre River Mine oil sands leases formerly held by Shell Canada Limited should CNRL reapply for and develop the Pierre River Mine project.
o Develop an integrated land management strategy for the Project in consultation with industry, the province, Indigenous communities, and stakeholders.
Provide wildlife passage under both sides of the Athabasca River bridge and river water intake bridge to Dalkin Island to allow north–south wildlife movement along river banks using crossing design considerations (e.g., bridge height and length) outlined in Clevenger and Huijser (2011) and GOA (2011).
Set up educational signage to limit human use of wildlife underpasses.
Evaluate wing fencing along the approach to crossing passages (at least 2.4 m high for large mammals as per GOA 2011) as part of the crossing structure design.
Provide appropriate walking substrate along the wildlife underpass.
Create vegetated buffers adjacent to wildlife underpasses to increase movement opportunities for a variety of species.
Provide coarse woody debris (e.g., stumps) along the wildlife underpass to provide cover and increase use by furbearers and other small mammals.
Teck has developed a Draft WMMP (see the response to JRP IR 7.14, Appendix 7.14). Teck has proposed steps to Indigenous groups that would provide the opportunity for land users and community members to provide direct input into developing wildlife mitigation measures. Input will refine this draft WMMP. Once finalized, the plan will include a communication management section, which will outline how findings of the program will be communicated to interested parties.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Change in wildlife mortality risk None. Teck commits to implement the following mitigation measures to reduce wildlife mortality risk resulting from vehicle–wildlife collisions (see the response to JRP IR 7.14, Table 7.14-1):
Implement fly-in/fly-out policy for workers to reduce vehicular traffic volume.
Frontier Oil Sands Mine Project Appendix 10.12
Table 10.12-2: Potential Adverse Environmental Effect and Mitigation Table – Athabasca Chipewyan First Nation (continued)
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Erect wildlife cautionary signage on access roads.
Foster environmental awareness with speed restrictions on access roads report Project-related wildlife fatalities.
Provide vegetation maintenance at roadsides (vegetation will be trimmed regularly to discourage roadside foraging and prevent visual obstruction of wildlife).
Develop seed mixes for roadside reclamation from less palatable species to reduce wildlife attraction to road edges.
Design the road to maximize line of sight.
Remove road kill as soon as practical.
Teck commits to implement the following mitigation measures to reduce wildlife mortality risk resulting from wildlife interactions with equipment (see the response to JRP IR 7.14, Table 7.14-1):
Implement preconstruction surveys for active wildlife habitat features (e.g., nests, breeding wetlands) before starting early works.
Avoid vegetation clearing during the recommended May 1 to August 10 migratory bird-breeding period for the boreal ecozone per Environment Canada guidelines; note that in species at risk habitat, a more conservative breeding window of April 1 to August 31 might apply (Gregoire 2014, pers. comm.); complete nest surveys if clearing activities occur during the breeding window.
Conduct owl nest search if clearing is scheduled within the non-migratory breeding bird window, March 1 to April 15 (based on Enhanced Approval Process guidelines for barred owl, GOA 2013).
Reduce on disturbance of amphibian breeding and overwintering habitat (where possible).
Teck commits to implement the following mitigation measures to reduce wildlife mortality risk resulting from interactions with Infrastructure (see the response to JRP IR 7.14, Table 7.14-1):
Create fuel and chemical spill contingency and response plans.
Confirm adequate spill protection for all fuel storage facilities.
Monitor and maintain waste disposal sites, wastewater storage areas and runoff control structures to prevent surface water impacts.
During overburden dewatering, intermittently backslope the sides of drainage ditches to allow for wildlife crossings and to reduce the potential for entrapment.
Use visible markers, such as aviation spheres and spiral vibration dampeners to make transmission lines near waterfowl staging and potential stopover areas more visible to birds, and where possible, design transmission lines to match the height of surrounding trees to reduce wire strikes by birds.
Teck commits to implement the following mitigation measures to reduce wildlife mortality risk resulting from wildlife–human conflicts (see the response to JRP IR 7.14, Table 7.14-1):
Implement a food waste-management strategy to prevent attraction of nuisance wildlife.
Confirm wildlife is not harassed or fed (to prevent habituation).
Provide wildlife awareness training to Project staff and contractors to reduce disturbance and negative human/bear interactions.
Provide all field staff with bear-aware training courses, personal protective equipment (e.g., bear spray, bear bangers, air horns) and training on proper use of equipment.
Develop a nuisance wildlife mitigation and monitoring plan in cooperation with the regulators.
Teck commits to implement the following mitigation measures to reduce wildlife mortality risk resulting from increased hunter access (see the response to JRP IR 7.14, Table 7.14-1):
Implement deactivation plans for roads no longer in use.
Prohibit construction and operations personnel and contractors from hunting and trapping while working.
Disallow personal recreational vehicle use onsite.
Prohibit firearms on Project lands or at Project facilities.
Consider requesting a Directors Order to limit public access to the west side of the Athabasca River along Project roads.
Teck has developed a Draft WMMP (see the response to JRP IR 7.14, Appendix 7.14). Teck has proposed steps to Indigenous groups that would provide the opportunity for land users and community members to provide direct input into developing wildlife mitigation measures. Input will refine this draft WMMP. Once finalized, the plan will include a communication management section, which will outline how findings of the program will be communicated to interested parties.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Waterfowl
Change in bird mortality risk
None. Teck commits to implement the following mitigation measures to reduce migratory water bird mortality risk resulting from the use of ponds (see the response to JRP IR 7.10, Table 7.10-1):
Develop detailed construction and operational procedures and mitigation measures to reduce wildlife mortality during tailings area start-up.
Design the sides of wastewater ponds to reduce attractiveness to birds (e.g., using gravel for sides).
Clear trees and above-ground vegetation including shrubs, herbs and the ground layer prior to placement of tailings into tailings disposal areas.
Remove peat from tailings area prior to flooding.
Develop detailed construction and operational procedures and mitigation measures to reduce wildlife mortality during tailings area start-up.
Reduce attractiveness of tailings areas for birds by keeping the inner walls of the tailings dyke free of vegetation.
Keep slopes of tailings areas as steep as possible to reduce “black beach” areas.
Implement procedure for removing any peat mats that float to the surface of the tailings area.
Implement procedure for controlling floating bitumen mats.
Manage the use and operation of anthropogenic lighting around wastewater ponds and tailings areas.
Bird deterrent systems will be used to discourage birds from landing on wastewater ponds and tailings areas.
Teck commits to implement the following mitigation measure to reduce the potential for birds to land in ponds containing process-affected water (see the response to ESRD/CEAA Round 3 SIR 64):
Bird deterrent systems will be installed on all ponds associated with the Project that have process-affected water that could be detrimental to birds.
Teck commits to implement the following mitigation measures to maximize recovery efficiency should birds use ponds (see the response to JRP IR 7.10, Table 7.10-1):
Develop procedure for handling of any bird recovered from wastewater ponds or tailings areas.
Frontier Oil Sands Mine Project Appendix 10.12
Table 10.12-2: Potential Adverse Environmental Effect and Mitigation Table – Athabasca Chipewyan First Nation (continued)
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Procedure will be in compliance with directions received from the local Alberta Fish and Wildlife office and/or the Alberta Environment and Parks (AEP) wildlife biologist.
Procedure will also be in compliance with directions from Environment and Climate Change Canada with respect to whooping cranes.
Teck commits to implement the following mitigation measures to reduce the potential for bird mortality risk resulting from interaction with transmission and distribution lines (see the response to JRP IR 7.10, Table 7.10-1):
Designing transmission and distribution lines, where possible, to match the height of surrounding trees to reduce wire strikes by birds.
Marking of transmission and distribution lines in areas near waterfowl staging and potential stopover areas.
Teck has developed a Draft Waterfowl Protection Plan (see the response to JRP IR 7.10, Appendix 7.10). Teck will continue to pursue collaborative engagement processes, as outlined in the WMMP for the Project as the primary mechanism in which it will engage with potentially affected Indigenous groups regarding the Waterfowl Protection Plan. Once finalized, the plan will include a communication management section, which will outline how findings of the program will be communicated to interested parties.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Bison
Change in bison habitat availability None. Teck commits to implement the following mitigation measures to reduce direct habitat loss (see the response to JRP IR 7.5, Table 7.5-1):
Limit the size of the east side access road right-of-way (ROW) and temporary workspace to the extent practical.
Limit the Athabasca Rive bridge footprint in riparian areas.
Carry out progressive reclamation to reclaim disturbed wildlife habitat as portions of the mine footprint become available.
Develop a weed management plan.
Teck commits to implement the following mitigation measures to reduce indirect habitat loss (see the response to JRP IR 7.5, Table 7.5-1):
Implement strategies to reduce noise and light effects, including design considerations (e.g., Frontier Project plant site engineering and aerodrome operation within regulatory and safety constraints).
Limiting employee and contractor access to identified areas of high-quality habitat adjacent to Project footprint.
Teck has developed a Draft Ronald Lake Bison Mitigation, Monitoring and Adaptive Management Plan (see the response to JRP IR 7.5, Appendix 7.5). Teck has proposed steps to Indigenous groups that would provide the opportunity for land users and community members to provide direct input into developing wildlife mitigation measures, including those specific to bison. Once finalized, the plan will include a communication management section, which will outline how findings of the program will be communicated to interested parties.
Teck will also work with the responsible authority to explore possible mitigations for which Teck does not have the authority to implement independently.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Change in bison landscape connectivity None. Teck commits to implement the following mitigation measures to reduce change to landscape connectivity (see the response to JRP IR 7.5, Table 7.5-1):
Carry out progressive reclamation to restore vegetated corridors as portions of the mine footprint become available.
To maintain connectivity between Birch Mountains and Athabasca River:
o Coordinate development activities with Canadian Natural Resources Limited (CNRL) who acquired the Pierre River Mine oil sands leases formerly held by Shell Canada Limited should CNRL reapply for and develop the Pierre River Mine project.
o Develop an integrated land management strategy for the Project in consultation with industry, Indigenous stakeholders and the Province.
Provide wildlife passage under both sides of the Athabasca River bridge and river water intake bridge to Dalkin Island to allow north–south wildlife movement along river banks using crossing design considerations (e.g., bridge height and length) outlined in Clevenger and Huijser (2011) and GOA (2011):
o Set up educational signage to limit human use of wildlife underpasses.
o Evaluate wing fencing along the approach to crossing passages (at least 2.4 m high for large mammals as per GOA 2011) as part of the crossing structure design.
o Provide appropriate walking substrate along the wildlife underpass.
o Create vegetated buffers adjacent to wildlife underpasses to increase movement opportunities for a variety of species.
Teck has developed a Draft Ronald Lake Bison Mitigation, Monitoring and Adaptive Management Plan (see the response to JRP IR 7.5, Appendix 7.5). Teck has proposed steps to Indigenous groups that would provide the opportunity for land users and community members to provide direct input into developing wildlife mitigation measures, including those specific to bison. Once finalized, the plan will include a communication management section, which will outline how findings of the program will be communicated to interested parties.
Teck will also work with the responsible authority to explore possible mitigations for which Teck does not have the authority to implement independently.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Change in bison mortality risk None. Teck commits to implement the following mitigation measures to reduce bison mortality risk resulting from vehicle–bison collisions (see the response to JRP IR 7.5, Table 7.5-1):
Implement fly-in/fly-out policy for workers to reduce vehicular traffic volume.
Erect wildlife cautionary signage on access roads.
Foster environmental awareness with speed restrictions on access roads, report Project-related wildlife fatalities.
Provide vegetation maintenance at roadsides (vegetation will be trimmed regularly to discourage roadside foraging and prevent visual obstruction of wildlife).
Develop seed mixes for roadside reclamation from less palatable species to reduce wildlife attraction to road edges.
Design the road to maximize line of sight.
Teck commits to implement the following mitigation measures to reduce bison mortality risk resulting from bison-human interactions - interactions with infrastructure (see the response to JRP IR 7.5, Table 7.5-1):
Create fuel and chemical spill contingency and response plans.
Confirm adequate spill protection for all fuel storage facilities.
Monitor and maintain waste disposal sites, wastewater storage areas and runoff control structures to prevent contamination of surface waters.
Frontier Oil Sands Mine Project Appendix 10.12
Table 10.12-2: Potential Adverse Environmental Effect and Mitigation Table – Athabasca Chipewyan First Nation (continued)
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During overburden dewatering, intermittently backslope the sides of drainage ditches to allow for wildlife crossings and to reduce the potential for entrapment.
Teck commits to implement the following mitigation measures to reduce bison mortality risk resulting from hunter access (see the response to JRP IR 7.5, Table 7.5-1):
Construct predator access blocks to deter predator use (i.e., reduce line of sight) on linear features in the PDA that may leave core bison areas susceptible to predation.
Deactivate roads in the PDA no longer in use.
Implement employee / contractor policies to prohibit hunting within the Project area.
Reduce linear features in the closure landscape.
Reduce width of linear features in the closure landscape.
Teck commits to implement the following mitigation measures to reduce bison mortality risk resulting from disease transmission to the Ronald Lake bison herd (see the response to JRP IR 7.5, Table 7.5-1):
Implement progressive reclamation in the PDA to create suitable Ronald Lake bison habitat and reduce the potential of shifting habitat use northward.
Mitigations associated with reducing hunter and predator access.
Mitigations associated with reducing wildlife human conflict.
Mitigations associated with reducing indirect habitat loss.
Teck has developed a Draft Ronald Lake Bison Mitigation, Monitoring and Adaptive Management Plan (see the response to JRP IR 7.5, Appendix 7.5). Teck has proposed steps to Indigenous groups that would provide the opportunity for land users and community members to provide direct input into developing wildlife mitigation measures, including those specific to bison. Once finalized, the plan will include a communication management section, which will outline how findings of the program will be communicated to interested parties.
Teck will also work with the responsible authority to explore possible mitigations for which Teck does not have the authority to implement independently.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Vegetation
Change in vegetation None. Teck is committed to continue working with potentially affected Indigenous groups to refine the closure, conservation and reclamation (CC&R) plan through the life of the Project and to incorporate input from Indigenous groups on reclamation monitoring and thresholds and document the establishment of traditional use vegetation in the reclaimed landscape. Teck plans to co-create Reclamation Working Group(s) with potentially affected Indigenous groups to seek input to the Project’s reclamation plan and measures and targets to determine its success. It anticipates that species of traditional importance will be identified by Reclamation Working Group(s) and incorporated into reclamation planning as feasible. In addition, collaborative participation is planned in reclamation research both from a Project and regional perspective. Results of this research will be incorporated into future Project plans (see the response to JRP IR 6.9, Section 4.2).
Teck also commits to implement the following mitigation measures to reduce change in vegetation (see Volume 3, Appendix 17H, Section 17H.4 of the Project Update; response to JRP IRs 6.8 and 6.10):
Reclamation of the closure landscape will focus on generating a sustainable landscape that is designed to maximize diversity through the generation of landforms that include:
o topographic diversity and associated diversity in moisture regimes
o aspect diversity
o substrate diversity including both fine- and coarse- grained landforms
o mesotopography
Removal of existing linear disturbances that are currently fragmenting the landscape.
Mitigation to reduce effects on community diversity will focus on research results and strategies as summarized in:
o Guidelines for Reclamation to Forest Vegetation in the Athabasca Oil Sands Region (2nd Edition) (ESRD 2010)
o Guideline for Wetland Establishment on Reclaimed Oil Sands Leases (3rd Edition) (CEMA 2014)
o Oil Sands Marshes: A Knowledge Transfer (Charette et al. 2012)
o Best Management Practices for Conservation of Reclamation Materials in the Mineable Oil Sands Region of Alberta (MacKenzie 2011)
o Restoration and Reclamation of Boreal Ecosystems: Attaining Sustainable Development (Vitt and Bhatti 2012)
o Riparian Classification and Reclamation Guide, Revised Edition (Mihajlovich 2012)
Include peatlands in detailed CC&R planning should research results and recommendations prove to be feasible and appropriate.
Work with the governments of Alberta and Canada and look to their guidance on the development of a Conservation Agreement.
Plant additional species on the reclamation landscape, including those with traditional value, to supplement those recommended in provincial reclamation guidelines.
Mitigation for rare plant species will be achieved through avoidance whenever possible. In areas where avoidance is not possible, alternate mitigation strategies will be developed to promote conservation of these species and associated genetic diversity.
A weed management plan will be implemented throughout the life of the Project including during reclamation and at closure.
Develop and implement a program to salvage and relocate known occurrences of rare (vascular) plant species to areas outside of the Project area in consultation with Indigenous communities.
Incorporate species of traditional important as identified through the Reclamation Working Group(s) into reclamation planning, as feasible.
Engage Indigenous communities in preparing plans to harvest and collect seeds, and will invite community members to harvest and collect seeds of rare and culturally important species before disturbance, for use in reproducing the species and revegetation of the Project area.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures related to reclamation and evaluate monitoring results to determine if adaptations are warranted.
Historical Resources
Changes to historical resources within the Project disturbance area
None. Teck commits to implement the following mitigation measures regarding changes to historical resources within the Project disturbance area (see Volume 3, Appendix 17H, Section 17H.9 of the Project Update):
Historical resources sites in the PDA that Alberta Culture and Tourism (ACT) determines to have moderate to high heritage value will likely have requirements for further study. These might include some or all of the following:
o Additional shovel testing to identify site boundaries, areas of highest artifact density, activity areas and areas with unique or specialized artifacts.
Frontier Oil Sands Mine Project Appendix 10.12
Table 10.12-2: Potential Adverse Environmental Effect and Mitigation Table – Athabasca Chipewyan First Nation (continued)
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o Archaeological excavation at sites with high interpretive potential.
o Mapping and documentation at specific sites.
Teck will phase the required supplemental historic resources impact assessment (HRIA) studies to ensure completion of all necessary studies in the PDA in advance of vegetation clearing in each development area.
Teck will also work collaboratively with local First Nation and Aboriginal communities on mitigation studies, in an effort to address local concerns and interests in relation to historical resources in the area.
Socio-economics
Change to housing needs None. Teck commits to implement the following mitigation measures regarding housing needs (see the response to JRP IR 5.14(a), Table 5.15a-1):
Provide on-site, lodge-based accommodations during construction and operations to reduce the Project’s effect on the resident population and associated effects on social infrastructure and housing in the region.
Offer lodge amenities and services – including individual rooms and shared spaces, the quality of the food services and free-time activities – that are competitive with other lodge accommodations in the region.
Change to social infrastructure needs None. Teck commits to implement the following mitigation measures regarding social infrastructure needs (see the response to JRP IR 5.14(a), Table 5.15a-2):
Maintain explicit and enforced lodge, workplace and flight policies with regards to the use of alcohol, drugs and illegal activities.
Provide onsite security services, including controlled gates, check-in procedures, perimeter security fencing and lodge-based security officers on duty 24 hours.
Offer in-house security services to assist the Royal Canadian Mounted Police (RCMP) within, and sometimes outside, the Project lease boundaries (e.g., securing accident scenes and assisting with highway closures).
Develop and implement an emergency response plan which includes the required personnel, procedures and equipment resources (e.g., vehicles, fire response, medical response and rescue).
Develop required mitigation measures for areas adjacent to the Project area based on the FireSmart Wildfire Assessment System and implement in the emergency response plan.
Enter into mutual aid agreements with the Regional Municipality of Wood Buffalo (RMWB) and other oil sands companies that include:
o responding to motor vehicle accidents on Highway #63
o responding to forest fire threats to Fort McKay
o responding to regional spills
Participate in the management of regional emergencies at the RMWB’s Regional Emergency Operations Centre.
Make available onsite health services, including an on-site medical facility staffed by qualified health professionals providing 24-hour on-site primary, emergency and occupational health services.
Consider financial and in-kind contributions to the Northern Lights Health Foundation, where appropriate, to support the efforts of Alberta Health Services to meet the needs of Wood Buffalo residents. Recognizing some of the health concerns in the region Teck is prepared to make health promotion and disease prevention initiatives a focus of their community investment policy.
Provide helicopter or fixed-wing aircraft access via the on-site aerodrome for injured workers requiring rapid evacuation for off-site medical care.
Discuss with other industrial proponents near the Project options for coordinating on-site health facilities and resources.
Assess and support school events and education initiatives identified by rural schools in the study area, as appropriate.
Provide employees with access to the company’s confidential Employee and Family Assistance Plan, which provides support for families and individuals who might experience difficulty dealing with personal, family or work-life issues that can affect one’s health and well-being.
Consider support for community level initiatives including social groups providing assistance to those in need.
Continue providing direct support to community initiatives through its social investment programs.
Offer shift schedules that provide workers with sufficient time off to enjoy leisure activities in their home communities.
Make available onsite recreational opportunities and facilities.
Change to transportation needs None. Teck commits to implement the following mitigation measures regarding transportation needs (see the response to JRP IR 5.14(a), Table 5.14a-3):
Construct and operate an aerodrome near the Project site.
Use on-site as well as regional lodge accommodations during both construction and operations to reduce worker commutes.
Use bus service for transporting construction and operations workers.
Limit private vehicles brought to the Project site.
Schedule truck traffic, including oversized loads, to off-peak hours.
Use an on-site concrete batch plant; and attempt to source aggregates from pits near to site.
Enforce lodge, workplace and flight policies with regards to the use of alcohol, drugs and illegal activities.
Work with the local RCMP to confirm communication on local effects.
Support the efforts of RMWB and Oil Sands Community Alliance (OSCA) to work with the provincial government to progress improvements to highway infrastructure in a timely way.
Keep responsible regional and provincial planners informed of the Project’s development plans and their timing.
Consult and cooperate with other operators regarding shift scheduling with a view to reduce overlap in commuter traffic.
Provide funding to assist in the maintenance and safety of applicable segments of Highway #63 from Fort McKay to Fort Chipewyan that are affected by the Project.
Frontier Oil Sands Mine Project Appendix 10.12
Table 10.12-2: Potential Adverse Environmental Effect and Mitigation Table – Athabasca Chipewyan First Nation (continued)
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Change to municipal infrastructure needs None. Teck commits to implement the following mitigation measures regarding municipal infrastructure (see the response to JRP IR 5.14(a), Table 5.14a-4):
Provide water and sewer services for the different mining areas and the associated processing facilities and infrastructure, including on-site lodges.
Teck commits to implement the following mitigation measures regarding choice of fly-in/fly-out (FIFO) (see the response to JRP IR 5.14(a), Table 5.14a-6):
A FIFO lodge-based approach to construction and operations.
Ongoing monitoring of the operations FIFO model and revisiting the approach should local circumstances change.
Teck’s monitoring will take into consideration input received via its workers, contractors and ongoing local stakeholder and Indigenous engagement process. This would likely include feedback with respect to the social and economic effects of the FIFO model on individual workers, their families and communities.
Commitment to include Fort Chipewyan in a FIFO program.
Engage with potential employees living in Fort Chipewyan to discuss shift schedules and other travel and lodging logistics that influence their choice to work at the Project versus other opportunities.
Discuss with local communities the design of FIFO shifts that best benefit its employees and families while remaining logistically and financially feasible.
Remain open to engaging in broader, regional initiatives, for example through the OSCA and its study of the use of aerodromes in the region.
Change to employment, business and training opportunity needs
None. Teck commits to implement the following mitigation measures regarding employment, business and training opportunity needs (see the response to JRP IR 5.14(a), Table 5.14a-5):
Specific contractual commitments to Indigenous communities on employment, business and training opportunities will be made within Participation Agreements negotiated between Teck and the Indigenous community.
Prioritize recruiting residents from the region first, Alberta second, followed by the rest of Canada, then North America and then overseas countries.
Draw on various sources of labour in Canada that are traditionally under-represented in the labour market, including Indigenous people, immigrants and women.
Put in place a policy to hire local businesses and contractors that are competitive and able to meet the company’s needs is already in place.
Teck will consult with Indigenous communities regarding procurement and employment initiatives such as:
o Establishing mechanisms to enhance employment prospects of local residents, including preferential consideration.
o Using procurement processes that regard local ownership and prevalence of workers residing locally as positive criteria in goods and services vendor selection competitions.
o Establishing monitoring programs that measure local involvement, gather feedback and work with interested parties on how to improve results.
Implement Teck’s relevant charters, codes and policies, including its Indigenous Peoples Policy, when working with Indigenous peoples in seeking to develop lasting mutual benefits that respect Indigenous community’s values – including hiring, training and retention of Indigenous employees.
Utilize what Teck’s has learned to date from local Indigenous communities with which it is engaged for the Project to overcome oil sands specific challenges to Indigenous employment and procurement.
Consider work experience in lieu of a high school graduation for Indigenous peoples.
Work with the Fort McMurray Chamber of Commerce, the Northeastern Alberta Aboriginal Business Association (NAABA) and others to maximize contracting and employment opportunities in the region.
Offer a choice of worker turnaround cycles and opportunity to earn premium pay through overtime.
Continue to work with the Indigenous communities in the area and specifically with the communities of Fort McKay and Fort Chipewyan to develop Indigenous employment and business development program(s) guided by a commitment to: maximize opportunities for local Indigenous businesses to supply services and products in support of Project construction and operations; hire qualified Indigenous people from the communities surrounding the Project and support education, training and investment initiatives in local Indigenous communities, where appropriate.
Teck’s Indigenous community employment and business development program(s) will engage with Indigenous communities on establishing employment and procurement policies and procedures, as well as adaptive management mechanisms specific to Indigenous community employment and procurement.
Teck’s Indigenous community employment and business development program(s), as well as community-specific Participation Agreements will take into consideration input provided by local Indigenous communities, and will be guided by a commitment to: develop substantial opportunities for local Indigenous businesses to supply services and products in support of Project construction and operations; hire qualified Indigenous people from the communities surrounding the Project and support education, training and investment initiatives in local Indigenous communities, where appropriate.
Continuously monitor Teck’s local employment and procurement policies and programs, along with reporting the results of this monitoring as part of ongoing community consultation.
Teck has yet to determine the exact reporting and monitoring mechanisms for its local procurement and employment policies, but will engage with Indigenous communities on mechanisms and expects they will likely be similar to mechanisms used by Teck’s other operations. These might include:
o Total employment, attraction and retention rates, average salary levels and other general human resource data. Where possible, the data will be disaggregated at the local community level.
o Procurement activity, including examination of goods and services sourced from providers in local communities, value and length of contracts, types of goods and services provided and employment and enterprise effects associated with procurement.
o Additional potential mechanisms are identified in Teck’s draft socio-economic monitoring plan in response to JRP IR 5.15(a).
Continue supporting local labour force skills development, and work with communities, government and other industrial proponents on programs that assist community members overcome labour market barriers.
Frontier Oil Sands Mine Project Appendix 10.12
Table 10.12-2: Potential Adverse Environmental Effect and Mitigation Table – Athabasca Chipewyan First Nation (continued)
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Change to culture None. Teck commits to implement the following mitigation measures regarding changes to culture (see the response to JRP IR 5.14(a), Tables 5-14a-6 and 5.14a-7):
Continue to expand Teck’s knowledge of, and engagement with, local stakeholders and Indigenous communities near the Project to confirm ongoing and growing participation in Project-related benefits, as well as the design of appropriate and effective mitigation measures to reduce any adverse effect. These efforts are envisioned to include capacity building support within Participation Agreements for Indigenous communities.
Provide cultural diversity awareness training to employees and contractors, focusing on respect for traditional land users as well as respect for Indigenous world views, customs and values.
Consider supportive workplace practices as Teck develops workplace policies and seek local Indigenous community input into cultural awareness programming to be provided at the Project site.
Carry out a review of Teck’s standard bereavement policy, including a review of policies from other fly in/fly out operations in Alberta, as operation specific policies are developed during future planning phases.
Continuing to provide cultural awareness training for all Project staff and contractors.
Considering key Indigenous access routes and access preferences in the Project’s draft Access Management Plan (AMP).
Considering cultural keystone species in the wildlife management and mitigation plan, FHCL and biodiversity management plan.
Incorporating and using Indigenous place names where applicable.
Supporting community-led projects to document Indigenous place names in their respective traditional territories.
Contributing to language retention programs and other programs that support retaining Indigenous culture, knowledge and practice (e.g., culture camps for youth).
Discuss with local communities the design of fly in/fly out shifts that best benefit its employees and families while remaining logistically and financially feasible.
Access
Change to access near the Project disturbance area
None. Teck has developed a draft access management plan (AMP) for the Project to facilitate access to or through Teck’s mineral surface lease to the extent possible while maintaining worker and public safety (see the response to JRP 4.5, Appendix 4.5). Teck has proposed next steps to Indigenous groups that would provide the opportunity for land users and community members to provide direct input into developing access mitigation measures. This input will refine the draft AMP.
Teck commits to implement the following mitigation measures to reduce potential effects on changes to access near the Project disturbance area (see Volume 3, Appendix 17H, Section 17H.8.2 of the Project Update) and the response to JRP IR 10.9):
All individuals wanting to gain access to or through lands being actively developed, which is generally Teck’s mineral surface lease (MSL), will be required to submit an access request.
Traditional land users will be granted temporary access to and through the PDA according to the policy and processes set out in the AMP.
Traditional land users will not have to meet worker site access requirements but will be escorted by someone who has permanent site access (i.e., a worker).
Access through, and to portions of the PDA not being actively developed will not require an access request form be submitted. Individuals will be required to contact the site’s security office and provide adequate notice about when they plan to be in the area, who will be present, and the intended activities and general location(s) as they relate to Teck leases. All individuals passing through the PDA will have to check in at the security office and will be escorted by a Teck worker. Teck understands that Aboriginal communities desire that the advance notice period.
Throughout the life of the mine, access to locations in the PDA by Aboriginal community members will be based on mine advance. For safety reasons, harvesting and use of firearms would not be permitted in areas being actively mined or within and around facilities associated with the mine.
The River Road will be maintained through operations and will provide access to the Fish Habitat Compensation Lake, aerodrome, and areas north of the PDA.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Traditional Land Use
Change in availability of resources (wildlife, fish and vegetation), culturally important sites or areas for traditional activities and use of lands
None. Teck commits to implement the following mitigation measures to reduce changes in availability of resources (wildlife, fish and vegetation), culturally important sites or areas for traditional activities and use of lands (assessed in Volume 3, Section 17.6 of the Project Update) (see the response to JRP IR 4.6, Table 4.6-1):
Grant traditional land users temporary access to and through the PDA according to the policy and processes set out in the draft access management plan.
Implement measures to mitigate Project-related effects on wildlife through the wildlife monitoring and mitigation plan.
Engage Indigenous communities in the development of a biodiversity management plan.
Implement measures to mitigate Project-related effects on fish and fish habitat through the detailed fisheries offsetting plan.
Implement measures to reduce Project-related effects on vegetation through the conservation closure and reclamation plan and the reclamation monitoring plan.
Historical resources sites in the PDA that Alberta Culture and Tourism (ACT) determines to have moderate to high heritage value will meet the requirements of ACT and aim to meet the desires of Indigenous communities.
Teck commits to implement the following mitigation measures to reduce effects on the land use experience for traditional land users (see the response to JRP IR 4.6, Table 4.6-1):
Establish Participation Agreements with Indigenous communities.
Invite traditional users to harvest traditional plants before disturbance.
Support the planning and implementation of an excursion for Indigenous communities within the terrestrial local study area prior to Project-related disturbance to describe Indigenous values, access and to recommend mitigation to avoid or limit effects on Indigenous access values.
Provide cultural diversity awareness training to employees and contractors focusing on respect for Indigenous land users, traplines, cabins, trails and equipment, as well as respect for Indigenous world views, customs and values.
Compensate Indigenous trappers following industry-community standards and the Alberta Trappers Compensation Program.
Project personnel will be prohibited from fishing, hunting and trapping within the PDA during work rotations, which is when Teck’s policies’ can be enforced.
Project personnel will be prohibited from using personal recreation vehicles within the PDA.
Investigate with potentially affected Indigenous communities through the Reclamation Working Group the concept of incorporating cultural values into reclamation planning.
Supporting documentation of community-specific cultural heritage.
Teck has developed a Draft Traditional Land Use Mitigation, Monitoring and Adaptive Management Plan (see the response to JRP IR 4.6, Appendix 4.6). Teck will continue to seek input and engage with Indigenous groups, as well as regulators where appropriate, as part of finalizing this plan. Once finalized, Teck will continue to pursue collaborative engagement processes with Indigenous groups as outlined in the plan. Through these collaborative engagement processes Teck will aim to minimize and mitigate potential Project effects on traditional land use. Once finalized, the plan will include a communication management section, which will outline how findings of the program will be communicated to interested parties.
Frontier Oil Sands Mine Project Appendix 10.12
Table 10.12-2: Potential Adverse Environmental Effect and Mitigation Table – Athabasca Chipewyan First Nation (continued)
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Potential Adverse Effects Mitigation Proposed by Athabasca Chipewyan
First Nation in TLU Study Mitigation Teck Commits to Implement
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Notes:
NOx = oxides of nitrogen; SO2 = sulphur dioxide; PM2.5 = particulate matter
Frontier Oil Sands Mine Project Appendix 10.12
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2 Fort Chipewyan Métis Local 125
A summary of established or asserted Aboriginal rights, current use of lands and resources for traditional
purposes and cultural and physical heritage features as described by Fort Chipewyan Métis Local 125
(Métis Local 125) is presented in Table 10.12-3.
Table 10.12-3: Fort Chipewyan Métis Local 125 Rights, Land Uses and Cultural and Physical Heritage Features
Established or Asserted Aboriginal Rights, Current Use of Lands and Resources for Traditional Purposes
Cultural and Physical Heritage Feature
Carry out traditional livelihoods and practice Aboriginal rights
Hunting
Fishing
Trapping
Gathering
Use of lands for hunting, trapping and gathering
Navigate waters
Traditional knowledge and language
Providing
Gathering, visiting and sharing
Cultural/historical/spiritual values
Wellbeing
Transmission of cultural and religious practices
Potential adverse Project effects on Métis Local 125’s established or asserted Aboriginal rights, current
use of lands and resources for traditional purposes or cultural and physical heritage are presented in
Table 10.12-4, along with mitigation proposed by Métis Local 125 in their TLU study (Woven Paths 2015)
and CIA (Integral Ecology Group 2015), and mitigation that Teck has committed to implement to reduce
these potential effects.
The mitigation proposed by Métis Local 125 in their TLU study and CIA may not be reflected, as
articulated by Métis Local 125, in the mitigation measures outlined in Table 10.12-4, for one or more of
the following reasons:
The mitigation measure proposed by Métis Local 125 is directly or indirectly reflected in one or
more mitigation measures outlined by Teck.
The mitigation measure proposed by Métis Local 125 is beyond the scope or control of what a
single proponent can mitigate.
The mitigation measure proposed by Métis Local 125 is within the scope of ongoing
environmental stewardship planning and implementation activities that Teck and Métis Local 125
will undertake as part of implementing a Participation Agreement (discussed below).
In 2016 Teck and Métis Local 125 entered into a Participation Agreement for the Project. The Agreement
sets out a framework for items such as traditional land use and environmental stewardship related to the
Project. The Agreement will be implemented through a joint Cooperative Implementation Committee,
which, among other activities, will engage in environmental stewardship planning and implementation for
the Project. Teck’s mitigation plans for the Project will be further discussed with Métis Local 125 as part of
joint Participation Agreement implementation efforts.
Frontier Oil Sands Mine Project Appendix 10.12
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Table 10.12-4: Potential Adverse Environmental Effect and Mitigation Table – Fort Chipewyan Métis Local 125
Potential Adverse Effects Mitigation Proposed by Fort Chipewyan Métis
Local 125 in TLU Study and CIA Mitigation Teck Commits to Implement
Hydrology and Water Quality
Changes in flows, water levels and open water areas
None. The Athabasca River will satisfy the Project’s makeup water requirements, and an off-stream storage pond (OSSP) will supply the Project with water during periods when river water withdrawal is restricted (see the response to Joint Review Panel (JRP) Information Request (IR) 10.26, Appendix 10.26, Section 7.1).
Teck commits to implement the following mitigation measures to reduce changes in flows and water levels in receiving waterbodies (see the response to JRP IR 10.25, Appendix 10.25, Table 10.25-1):
Reduce changes to flows in Ronald Lake by using a flow splitter on the Redclay Creek diversion during operations.
Reduce changes to flows in Big Creek by using a flow splitter on the Big Creek diversion during operations.
Distribute muskeg drainage operations through the mine life, thereby avoiding a large increase in flows in the receiving waters.
Reduce effects of closed-circuit operations on flows and water levels in receiving waters by diverting natural watercourses that will not be disturbed by the mining operations around the mining area to receiving watercourses.
Reduce river-water withdrawal requirements from the Athabasca River by maximizing closed-circuit recycling of surface and groundwater where practical, and by storing sufficient amounts of water in an off-stream storage pond in the event of extended withdrawal restrictions from the Athabasca River.
Progressively construct and develop diversion systems, which helps limit the change in open-water areas during construction and operation by providing new drainage channels to replace the loss of natural watercourses and waterbodies.
Reduce changes to flows and water levels in receiving waters by developing a closure drainage layout that will limit changes in drainage areas contributing flows to the receiving watercourses relative to predevelopment conditions.
Design watercourses, waterbodies and wetlands during reclamation to attenuate floods.
Teck is committed to continue to consult meaningfully with, and engage, all potentially affected Indigenous groups at both a Project-specific and regional level to reduce and mitigate potential Project and cumulative effects on hydrology and surface water quality, including continuing discussions regarding hydrology and surface water quality concerns and is prepared to consider additional mitigation measures to address these concerns (see the response to JRP IR 10.25, Appendix 10.25).
Teck has developed a Draft Hydrology and Water Quality Mitigation, Monitoring and Adaptive Management Plan (see the response to JRP IR 10.25, Appendix 10.25). Once finalized, the plan will include a communication management section, which will outline how findings of the program will be communicated to interested parties.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Changes in sediment yields, concentrations and channel regimes (geomorphology)
None. Teck commits to implement the following mitigation measures to limit release of Total Suspended Solids (TSS) (see the response to JRP IR 10.25, Appendix 10.25, Table 10.25-1):
Follow relevant regulatory guidelines, standards and best management practices during construction and operation to reduce the risk of increased sediment loadings to receiving watercourses.
Construct and operate sedimentation ponds to settle TSS where necessary.
Control sediment generation in diversion channels through revegetation of streambanks, overbank areas and berms as soon as possible after construction and by the use of channel armour (riprap), where required.
Direct muskeg and overburden drainage waters to polishing ponds equipped with oil-separation capability.
Reduce sediment yields from reclaimed surfaces by developing appropriate final topography and soil moisture conditions.
Resuspension of sediments from the bottom of polishing ponds, wetlands and pit lakes will be reduced through appropriate hydraulic design.
Reduce gullying and channel erosion by developing robust and sustainable reclamation drainage systems with built-in self-healing capability and robustness similar to natural drainage systems.
Teck commits to implement the following mitigation measures to reduce changes in flood flows and geomorphology downstream of the Project (see the response to JRP IR 10.25, Appendix 10.25, Table 10.25-1):
Limit changes in flood flows in receiving watercourses relative to predevelopment conditions. Mitigation measures listed for the “reduce changes in flows and water levels” above are relevant for mitigating flood flows.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Direct water emissions:
Muskeg drainage and overburden dewatering flows
Drainage from operating and reclaimed mine site
Basal water sands depressurization
Process-affected seepages from backfilled mine pits and tailings disposal areas
Detailed plans to reduce the risk of surface and groundwater contamination from tailings ponds and replacement reservoirs must be communicated with Métis Local 125 in plain language and either at open and accessible public meetings in the community or with a community advisory group (Woven Paths 2015, p. 91).
Teck commits to implement the following mitigation measures to limit the release of ions, nutrients, metals, polycyclic aromatic hydrocarbons (PAHs) and other parameters during operations and closure and protect sediment quality in downstream watercourses and waterbodies (see the response to JRP IR 10.25, Appendix 10.25, Table 10.25-1):
Recycle process-affected waters and runoff within the Project disturbance area (PDA) in a closed-circuit system during operations.
Using a perimeter ditch and groundwater wells to capture and pump back seepages and runoff from the external tailings areas (ETAs) back into the tailings areas during operations.
Design the closure drainage system to capture seepage and runoff from ETAs, external disposal areas (EDAs) and the Frontier Project plant site and directing it to wetlands, pit lakes or constructed reclamation lakes during the mine closure management phase.
Use wetlands, constructed reclamation lakes and pit lakes during and after the decommissioning and closure phases to provide biological remediation and settling of particulate materials in reclamation waters before discharge.
Respond to spills using best management practices. Project activities will follow safety protocols designed to limit accidents and reduce effects if an accident should occur.
Teck commits to the following mitigation measures to manage depressurization water during preproduction (see Volume 1, Section 7.6.5 and 7.8.4 of the Project Update):
Teck plans to manage depressurization water during preproduction by storing approximately half of it in a storage pond at surface and reinjecting the remaining half into the BWS aquifer.
Teck is committed to continue to consult meaningfully with, and engage, all potentially affected Indigenous groups at both a Project-specific and regional level to reduce and mitigate potential Project and cumulative effects on hydrology and surface water quality, including continuing discussions regarding hydrology and surface water quality concerns and is prepared to consider additional mitigation measures to address these concerns (see the response to JRP IR 10.25, Appendix 10.25).
Teck has developed a Draft Hydrology and Water Quality Mitigation, Monitoring and Adaptive Management Plan (see the response to JRP IR 10.25, Appendix 10.25). Once finalized, the plan will include a communication management section, which will outline how findings of the program will be communicated to interested parties.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Pit lake releases Detailed plans to reduce the risk of surface and Teck will leverage the knowledge gained through its other reclamation efforts, along with research through regional initiatives such as Canada’s Oil Sands Innovation Alliance (COSIA), to develop healthy, functional
Frontier Oil Sands Mine Project Appendix 10.12
Table 10.12-4: Potential Adverse Environmental Effect and Mitigation Table – Fort Chipewyan Métis Local 125 (continued)
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Potential Adverse Effects Mitigation Proposed by Fort Chipewyan Métis
Local 125 in TLU Study and CIA Mitigation Teck Commits to Implement
groundwater contamination from tailings ponds and replacement reservoirs must be communicated with Métis Local 125 in plain language and either at open and accessible public meetings in the community or with a community advisory group (Woven Paths 2015, p. 91).
ecosystems in the Project pit lakes (see the response to JRP IR 2.3).
Teck also commits to implement the following mitigation measures when designing closure drainage and pit lakes for hydrological sustainability and to promote effective passive treatment of process-affected waters and to support a viable aquatic ecosystem prior to release and to sequester tailings and other mine waste in the most appropriate location at mine closure (see the response to JRP IR 10.25, Appendix 10.25, Table 10.25-1):
Exclude tailings from pit lakes.
Do not release water from pit lakes until acceptable quality is achieved.
Maintain the water balance of the pit lakes with sufficient inflows to compensate for evaporative losses.
Manage the rate of Athabasca River water input to pit lakes as appropriate to confirm water quality filling targets are met and to comply with Athabasca river low flow restrictions.
Include wetlands reclamation lakes for treatment purposes in reclamation drainages to the pit lakes.
Teck is committed to continue to consult meaningfully with, and engage, all potentially affected Indigenous groups at both a Project-specific and regional level to reduce and mitigate potential Project and cumulative effects on hydrology and surface water quality, including continuing discussions regarding hydrology and surface water quality concerns and is prepared to consider additional mitigation measures to address these concerns (see the response to JRP IR 10.25, Appendix 10.25).
Teck has developed a Draft Hydrology and Water Quality Mitigation, Monitoring and Adaptive Management Plan (see the response to JRP IR 10.25, Appendix 10.25). Once finalized, the plan will include a communication management section, which will outline how findings of the program will be communicated to interested parties.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Changes in quality of groundwater and surface water downgradient of EDAs
Detailed plans to reduce the risk of surface and groundwater contamination from tailings ponds and replacement reservoirs must be communicated with Métis Local 125 in plain language and either at open and accessible public meetings in the community or with a community advisory group (Woven Paths 2015, p. 91).
Teck commits to implement the following mitigation measures to maintain surface water quality in consideration of surface flows into and out of the Project area and groundwater discharge (see the response to JRP IR 10.25, Appendix 10.25, Table 10.25-1):
Groundwater and surface waters draining EDAs will be captured if monitoring data indicate that the drainage waters are unsuitable for release.
Teck is committed to continue to consult meaningfully with, and engage, all potentially affected Indigenous groups at both a Project-specific and regional level to reduce and mitigate potential Project and cumulative effects on hydrology and surface water quality, including continuing discussions regarding hydrology and surface water quality concerns and is prepared to consider additional mitigation measures to address these concerns (see the response to JRP IR 10.25, Appendix 10.25).
Teck has developed a Draft Hydrology and Water Quality Mitigation, Monitoring and Adaptive Management Plan (see the response to JRP IR 10.25, Appendix 10.25). Once finalized, the plan will include a communication management section, which will outline how findings of the program will be communicated to interested parties.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Air Quality and Odour
NOX emissions None. Teck commits to implement the following mitigation measures to reduce NOX emissions from combustion sources (see the response to JRP IR 3.18, Table 3.18-1):
Use natural gas as a fuel for the cogeneration plant and boilers and heaters.
Dry low NOX technology to reduce NOX emissions and increase cogeneration plant efficiency.
Boiler and heater technology that will meet provincial and federal government emission requirements.
Purchase Tier IV compliant haul trucks when they become available.
Optimize mine planning to reduce haul distances.
Develop and implement an anti-idling program for the mine fleet.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
SO2 emissions None. Teck commits to implement the following mitigation measures to reduce SO2 emissions from combustion sources (see the response to JRP IR 3.18, Table 3.18-1):
Use natural gas as a fuel for the cogeneration plant and boilers and heaters.
Use ultra-low sulphur diesel for the mine fleet.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
PM2.5 and dust emissions None. Teck commits to implement the following mitigation measures to reduce PM2.5 emissions from combustion sources (see the response to JRP IR 3.18, Table 3.18-1):
Use natural gas as a fuel for the cogeneration plant and boilers and heaters.
Boiler and heater technology that will meet provincial and national government emission requirements.
Purchase Tier IV compliant haul trucks when they become available.
Optimize mine planning to reduce haul distances.
Develop and implement an anti-idling program for the mine fleet.
Teck commits to implement the following mitigation measures to reduce fugitive dust emissions (see the response to JRP IR 3.18, Table 3.18-1):
Dust mitigation measures to be applied to onsite roads during construction include appropriate selection of road materials, limiting vehicle speeds, surface watering, progressive reclamation, temporary vegetation of disturbed land and retain natural vegetation as windbreaks.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Hydrocarbon and reduced sulphur emissions and secondary organic aerosol precursor emissions
None. Teck commits to implement the following mitigation measures to reduce fugitive plant emissions (see the response to JRP IR 3.18, Table 3.18-1):
Use floating roof tanks where appropriate and a vapour recovery system to condense and recover vapours from storage tanks and process areas.
Use dual solvent vapour recovery units to provide full redundancy.
Conduct a leak detection and repair (LDAR) program to identify leaking components and to prioritize associated repairs.
Teck commits to implement the following mitigation measures to reduce fugitive mine face emissions (see the response to JRP IR 3.18, Table 3.18-1):
Frontier Oil Sands Mine Project Appendix 10.12
Table 10.12-4: Potential Adverse Environmental Effect and Mitigation Table – Fort Chipewyan Métis Local 125 (continued)
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Mitigation not currently known.
Teck commits to implement the following mitigation measures to reduce fugitive tailings area emissions (see the response to JRP IR 3.18, Table 3.18-1):
Tailing solvent recovery unit to maintain losses to less than four volumes of solvent to 1,000 volumes of bitumen produced.
Teck commits to implement the following mitigation measures to reduce hydrocarbon and reduced sulphur emissions from combustion sources (see the response to JRP IR 3.18, Table 3.18-1):
Use natural gas as a fuel for the cogeneration plant and boilers and heaters.
Purchase Tier IV compliant haul trucks when they become available.
Optimize mine planning to reduce haul distances.
Develop and implement an anti-idling program for the mine fleet.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Odour None Teck has developed a draft Odour Management and Response Plan (see the response to JRP IR 3.13, Appendix 3.13). The draft Plan. The Plan’s goals are mitigation, monitoring, participation in regional complaint process, and correlation of complaints to Project activities to determine response actions. The Plan will be finalized following consultation with Indigenous communities, regulators and stakeholders.
At any time during Project operation, nearby residences will be able to contact Teck if they are concerned that Project operations are causing odours. The contact will be documented, investigative action will be initiated to determine the potential source, and the caller will be notified. If a source can be identified, a review will be undertaken to implement corrective action to reduce the potential for future occurrences (ERCB Round 1 SIR 113a; Appendix 3.13).
Acoustics
Change in sound levels None. Teck has made an overall commitment to managing and promptly addressing all noise-related concerns (see Volume 3, Section 3.4.9.2, Project Update) and will develop a Noise Management Plan (see Volume 3, Section 3.4.9.1, Project Update).
Teck also commits to implement the following mitigation measures to reduce changes in sound levels (see Volume 3, Appendix 17H, Section 17H.5 of the Project Update and the response to JRP IR 1.3, Table 1.4-1):
Vehicles will be maintained in good working condition (e.g., mufflers will be maintained) and speed limits will be enforced.
Emergency alarms will be tested during daytime, where reasonably practical.
Acoustic performance of building wall construction will meet a minimum sound transmission class (STC) rating of 29, based on published data in the North American Insulation Manufacturers Association for a pre-engineered structure.
For outdoor equipment, the manufacturer incorporates mitigation in the equipment design to achieve the published sound power level.
Noise effects will be mitigated using various measures, including but not limited to the following:
o haul trucks exhaust silencer
o haul truck speed
o trip frequency (number of trips per daytime and nighttime period)
o route location or alignment
Ventilation openings (i.e., air intake and exhaust openings) will be fitted with appropriate acoustic silencers, louvers, or plenums, where applicable, to reduce outdoor sound transmission from indoor equipment.
Buildings housing indoor noise-generating equipment will be appropriately sealed to reduce noise.
Where practical, flanking path and penetrations from plumbing, heating ducts and electrical wire in the buildings will be properly insulated and covered to reduce noise.
Appropriate acoustical lagging will be installed to provide additional attenuation to the steel casing, where practical.
Vibration isolation pads, resilient mounts on equipment, resilient pipe support systems, and dampers will be installed where appropriate.
Teck will incorporate best management practices to reduce Project-related noise into Daily Operational Procedures, Long-Term Operational Procedures, design for low-noise facilities, and performance measurement as described in SPOG (2012) Best Practices Document, where appropriate (ERCB Round 1 SIR 116; Volume 3, Section 3.4.9.1 of the Project Update), including:
Daily Operational Procedures
Keeping compressor station doors and windows closed
Using belt dressing
Inspecting and repairing mufflers
Running fans slower at night (variable frequency drive [VFD])
Using vent silencers on buildings
Using soundproofing (insulation and lagging)
Troubleshooting transient noise
Minimizing flaring and venting
Considering gravel pack around compressor building skids
Developing noise check in daily reading sheets
Long-Term Operational Procedures
Responding quickly to noise concerns
Establishing baseline noise levels (in plant, at fence-line, or both) and resurvey to determine trends
Conducting regular assessment of noise control opportunities
Using best practical technology for noise control
Frontier Oil Sands Mine Project Appendix 10.12
Table 10.12-4: Potential Adverse Environmental Effect and Mitigation Table – Fort Chipewyan Métis Local 125 (continued)
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Maintaining communication links with noise sensitive receptors and communities
Being aware of noise from contractors (e.g., service rigs) and developing processes to meet best practice expectations
Scheduling work to create the least amount of noise effects on noise sensitive receptors and keeping those affected informed
Design for Low Noise Facilities
Considering low noise electric drives versus engine driven compressors
Designing cooler fans for low tip velocity
Orienting noise sources away from residents
Using acoustical pipe lagging
Installing VFDs on coolers
Performance Measurement
Conducting measurements and establishing baseline data
Using best practices as part of the company’s operating procedures
Visual
Change to visual environment None. Teck commits to implement the following mitigation measures to reduce changes to visual effects (see Volume 1, Section 8.3.6, Volume 3, Section 16.4.6, Volume 3, Section 18.10.4.2, Volume 3, Section 18.11.5.4 and Volume 3, Appendix 17H, Section 17H.7 of the Project Update):
Maintaining vegetated buffers between the Project and the Athabasca River as well as along Project transportation corridors to the extent feasible where safety concerns are not an issue.
Using construction materials that reduce contrast, limit visual attraction to Project features, and blending built structures into the natural surrounding environment.
Using construction materials, where practicable, that minimize light reflection, potentially reducing viewing distances of Project features
Reclamation techniques will be used that integrate closure plans with the surrounding landscape.
Teck will seek to develop closure plans that:
o Include integration and contouring of slopes that mimic natural topography.
o Focus on establishing a variety of vegetation communities.
o Avoid unnatural-looking breaks at development boundaries.
Planting a narrow band of white spruce along the edge of the river water intake (RWI) cofferdam and plant dogwood on the cofferdam, except in areas where tall vegetation would impede any maintenance or present safety concerns.
Completing reclamation in the RWI area to minimize erosion and slope instability.
Using lighting that minimizes light pollution.
At closure, infrastructure will be removed and the Project will be reclaimed using vegetation types similar, though not identical to existing conditions, creating a continuous vegetated landscape.
A lighting plan will be developed during future stages of engineering to avoid over-illumination. Lighting design will be part of future stages of engineering, and Teck will consult with interested Indigenous communities about lighting considerations.
Finish the Athabasca River Bridge with low-glare materials and plant vegetation buffers near the bridge. Teck also commits to clear minimal vegetation and to vegetate cleared areas.
Retain treed buffers around or near watercourses.
Fish and Fish Habitat
Change in productive
fish habitat
None. Fish habitat of equivalent or higher productivity than that affected by the Project will be created through offsetting measures where prevention of adverse habitat alteration or loss (i.e., reduced habitat productivity or loss of productive habitat area) is not feasible (see the draft Detailed Fisheries Offsetting Plan, the response to JRP IR 2.1, Appendix 2.1).
Teck also commits to implement the following mitigation measures to avoid or reduce changes in fish habitat quantity or quality (see the response to JRP IR 2.1, Table 5):
To avoid or reduce sedimentation:
Temporary and permanent erosion and sediment control measures for construction activities and disturbed areas.
Stabilization and revegetation of disturbed areas.
Isolation of instream work areas where they are required.
Best management practices and regulatory guidelines for construction activities in and near watercourses/waterbodies for erosion and sediment control.
Polishing ponds or other measures to reduce suspended sediment concentrations in discharge waters to avoid increases in sedimentation in the receiving environment.
Appropriate design of constructed channels and ponds to reduce internal erosion and generation of suspended sediments.
Appropriate design and construction of reclaimed landscape to reduce sediment yield.
To avoid or reduce changes to water quality:
Passing muskeg drainage and overburden water through polishing ponds and drainage ditches to reduce changes in water temperatures and dissolved oxygen concentrations.
Recycling of process affected waters during operations.
Capture and recycling of ETA seepage and run off water during operations, and use of a passive seepage control system at closure.
Use of wetlands, pit lakes and constructed reclamation lakes in the closure drainage system to provide biological remediation before release to the environment.
Removal of organic material from fish habitat compensation lake (FHCL) area prior to flooding.
To avoid or reduce changes to habitat area:
Diversion of watercourses around the PDA to return natural upslope water back to the diverted watercourse to preserve flows and avoid elimination of downstream habitats.
Provision of a flow splitter on the diversion channel that will collect water from both upper Redclay Creek and Unnamed Creek 17 to appropriately apportion the flows in lower Redclay Creek and Unnamed Creek 17 to avoid flow changes in the Ronald Lake watershed.
Operation of the RWI and Off Stream Storage Pond (OSSP) in compliance with the Lower Athabasca River Surface Water Quantity Management Framework.
Frontier Oil Sands Mine Project Appendix 10.12
Table 10.12-4: Potential Adverse Environmental Effect and Mitigation Table – Fort Chipewyan Métis Local 125 (continued)
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Design of the closure drainage channels and pit lakes to provide habitats capable of supporting aquatic ecosystems.
Best management practices and regulatory guidelines to ensure construction and operation of the RWI, Athabasca River bridge and watercourse crossings associated with access roads do not interfere with fish passage and access to available habitats.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Change in fish abundance None. Teck commits to implement the following mitigation measures to avoid or reduce changes in fish abundance (see the response to JRP IR 2.1, Table 5):
Fish rescue operations to capture and relocate fish prior to habitat dewatering.
Screening of the RWI in compliance with regulatory guidelines to mitigate fish entrainment or impingement.
Best management practices and regulatory guidelines for scheduling construction activities in and near waterbodies/watercourse to avoid sensitive time periods in adjacent or downstream fish-bearing watercourses.
Education of Project personnel on sustainable fishing practices to support a Teck applied prohibition on their fishing in watercourses or waterbodies in the PDA to mitigate potential increases in recreational fishing pressure.
Access Management Plan for the PDA to limit access to fish bearing habitats to mitigate increased fishing pressure.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Change in fish and fish habitat diversity
None. Teck commits to implement the following mitigation measures to avoid or reduce changes in fish and fish habitat diversity (see the response to JRP IR 2.1, Table 5):
Several of the measures intended to avoid or mitigate effects to fish habitat and fish abundance also apply to fish and fish habitat diversity, in cases where they preserve fish and productive fish habitats or create new habitats, including:
o Diversions designed to preserve flows and avoid elimination of downstream habitats.
o Closure drainage channels and pit lakes designed to provide habitats capable of supporting aquatic ecosystems.
o Fish rescue operations.
o Screening of the RWI.
o Education and prohibition of Project personnel from fishing in the PDA.
o Access Management for the PDA to limit access to fish bearing habitats.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Wildlife
Change in wildlife habitat availability
Establish a restoration Project for wildlife and vegetation habitat (Woven Paths 2015, p. 92).
Teck commits to implement the following mitigation measures to reduce direct habitat loss (see the response to JRP IR 7.14, Table 7.14-1):
Limit the size of the east side access road right-of-way (ROW) and temporary workspace to the extent practical.
Limit the Athabasca River bridge footprint in riparian areas.
Carry out progressive reclamation to reclaim disturbed wildlife habitat as portions of the mine footprint become available.
Develop a weed management plan.
Teck commits to implement the following mitigation measures to reduce indirect habitat loss (see the response to JRP IR 7.14, Table 7.14-1):
Implement strategies to reduce noise and light effects, including design considerations (e.g., Frontier Project plant site engineering and aerodrome operation within regulatory and safety constraints).
Limiting employee and contractor access to identified areas of high-quality habitat adjacent to Project footprint.
Teck commits to developing a Biodiversity Management Plan (BMP) with the underlying goal of optimizing reclamation during operations to reduce offsetting of residual environmental effects (see the response to JRP IR 7.15).
Teck has developed a Draft Wildlife Mitigation, Monitoring and Adaptive Management Plan (WMMP; see the response to JRP IR 7.14, Appendix 7.14). Teck has proposed steps to Indigenous groups that would provide the opportunity for land users and community members to provide direct input into developing wildlife mitigation measures. Input will refine this draft WMMP. Once finalized, the plan will include a communication management section, which will outline how findings of the program will be communicated to interested parties.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Change in wildlife landscape connectivity
Establish a restoration Project for wildlife and vegetation habitat (Woven Paths 2015, p. 92).
Teck commits to implement the following mitigation measures to reduce change to landscape connectivity (see the response to JRP IR 7.14, Table 7.14-1):
Carry out progressive reclamation to restore habitat for movement as portions of the mine footprint become available.
To maintain connectivity between Birch Mountains and Athabasca River:
o Coordinate development activities with Canadian Natural Resources Limited (CNRL) who acquired the Pierre River Mine oil sands leases formerly held by Shell Canada Limited should CNRL reapply for and develop the Pierre River Mine project.
o Develop an integrated land management strategy for the Project in consultation with industry, the province, Indigenous communities, and stakeholders.
Provide wildlife passage under both sides of the Athabasca River bridge and river water intake bridge to Dalkin Island to allow north–south wildlife movement along river banks using crossing design considerations (e.g., bridge height and length) outlined in Clevenger and Huijser (2011) and GOA (2011).
Set up educational signage to limit human use of wildlife underpasses.
Evaluate wing fencing along the approach to crossing passages (at least 2.4 m high for large mammals as per GOA 2011) as part of the crossing structure design.
Provide appropriate walking substrate along the wildlife underpass.
Create vegetated buffers adjacent to wildlife underpasses to increase movement opportunities for a variety of species.
Provide coarse woody debris (e.g., stumps) along the wildlife underpass to provide cover and increase use by furbearers and other small mammals.
Teck has developed a Draft WMMP (see the response to JRP IR 7.14, Appendix 7.14). Teck has proposed steps to Indigenous groups that would provide the opportunity for land users and community members to provide direct input into developing wildlife mitigation measures. Input will refine this draft WMMP. Once finalized, the plan will include a communication management section, which will outline how findings of the program will be communicated to interested parties.
Frontier Oil Sands Mine Project Appendix 10.12
Table 10.12-4: Potential Adverse Environmental Effect and Mitigation Table – Fort Chipewyan Métis Local 125 (continued)
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Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Change in wildlife mortality risk Establish a restoration Project for wildlife and vegetation habitat (Woven Paths 2015, p. 92).
Teck commits to implement the following mitigation measures to reduce wildlife mortality risk resulting from vehicle–wildlife collisions (see the response to JRP IR 7.14, Table 7.14-1):
Implement fly-in/fly-out policy for workers to reduce vehicular traffic volume.
Erect wildlife cautionary signage on access roads.
Foster environmental awareness with speed restrictions on access roads report Project-related wildlife fatalities.
Provide vegetation maintenance at roadsides (vegetation will be trimmed regularly to discourage roadside foraging and prevent visual obstruction of wildlife).
Develop seed mixes for roadside reclamation from less palatable species to reduce wildlife attraction to road edges.
Design the road to maximize line of sight.
Remove road kill as soon as practical.
Teck commits to implement the following mitigation measures to reduce wildlife mortality risk resulting from wildlife interactions with equipment (see the response to JRP IR 7.14, Table 7.14-1):
Implement preconstruction surveys for active wildlife habitat features (e.g., nests, breeding wetlands) before starting early works.
Avoid vegetation clearing during the recommended May 1 to August 10 migratory bird-breeding period for the boreal ecozone per Environment Canada guidelines; note that in species at risk habitat, a more conservative breeding window of April 1 to August 31 might apply (Gregoire 2014, pers. comm.); complete nest surveys if clearing activities occur during the breeding window.
Conduct owl nest search if clearing is scheduled within the non-migratory breeding bird window, March 1 to April 15 (based on Enhanced Approval Process guidelines for barred owl, GOA 2013).
Reduce on disturbance of amphibian breeding and overwintering habitat (where possible).
Teck commits to implement the following mitigation measures to reduce wildlife mortality risk resulting from interactions with Infrastructure (see the response to JRP IR 7.14, Table 7.14-1):
Create fuel and chemical spill contingency and response plans.
Confirm adequate spill protection for all fuel storage facilities.
Monitor and maintain waste disposal sites, wastewater storage areas and runoff control structures to prevent surface water impacts.
During overburden dewatering, intermittently backslope the sides of drainage ditches to allow for wildlife crossings and to reduce the potential for entrapment.
Use visible markers, such as aviation spheres and spiral vibration dampeners to make transmission lines near waterfowl staging and potential stopover areas more visible to birds, and where possible, design transmission lines to match the height of surrounding trees to reduce wire strikes by birds.
Teck commits to implement the following mitigation measures to reduce wildlife mortality risk resulting from wildlife–human conflicts (see the response to JRP IR 7.14, Table 7.14-1):
Implement a food waste-management strategy to prevent attraction of nuisance wildlife.
Confirm wildlife is not harassed or fed (to prevent habituation).
Provide wildlife awareness training to Project staff and contractors to reduce disturbance and negative human/bear interactions.
Provide all field staff with bear-aware training courses, personal protective equipment (e.g., bear spray, bear bangers, air horns) and training on proper use of equipment.
Develop a nuisance wildlife mitigation and monitoring plan in cooperation with the regulators.
Teck commits to implement the following mitigation measures to reduce wildlife mortality risk resulting from increased hunter access (see the response to JRP IR 7.14, Table 7.14-1):
Implement deactivation plans for roads no longer in use.
Prohibit construction and operations personnel and contractors from hunting and trapping while working.
Disallow personal recreational vehicle use onsite.
Prohibit firearms on Project lands or at Project facilities.
Consider requesting a Directors Order to limit public access to the west side of the Athabasca River along Project roads.
Teck has developed a Draft WMMP (see the response to JRP IR 7.14, Appendix 7.14). Teck has proposed steps to Indigenous groups that would provide the opportunity for land users and community members to provide direct input into developing wildlife mitigation measures. Input will refine this draft WMMP. Once finalized, the plan will include a communication management section, which will outline how findings of the program will be communicated to interested parties.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Waterfowl
Change in bird mortality risk None. Teck commits to implement the following mitigation measures to reduce migratory water bird mortality risk resulting from the use of ponds (see the response to JRP IR 7.10, Table 7.10-1):
Develop detailed construction and operational procedures and mitigation measures to reduce wildlife mortality during tailings area start-up.
Design the sides of wastewater ponds to reduce attractiveness to birds (e.g., using gravel for sides).
Clear trees and above-ground vegetation including shrubs, herbs and the ground layer prior to placement of tailings into tailings disposal areas.
Remove peat from tailings area prior to flooding.
Develop detailed construction and operational procedures and mitigation measures to reduce wildlife mortality during tailings area start-up.
Reduce attractiveness of tailings areas for birds by keeping the inner walls of the tailings dyke free of vegetation.
Keep slopes of tailings areas as steep as possible to reduce “black beach” areas.
Implement procedure for removing any peat mats that float to the surface of the tailings area.
Implement procedure for controlling floating bitumen mats.
Manage the use and operation of anthropogenic lighting around wastewater ponds and tailings areas.
Bird deterrent systems will be used to discourage birds from landing on wastewater ponds and tailings areas.
Teck commits to implement the following mitigation measure to reduce the potential for birds to land in ponds containing process-affected water (see the response to ESRD/CEAA Round 3 SIR 64):
Frontier Oil Sands Mine Project Appendix 10.12
Table 10.12-4: Potential Adverse Environmental Effect and Mitigation Table – Fort Chipewyan Métis Local 125 (continued)
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Bird deterrent systems will be installed on all ponds associated with the Project that have process-affected water that could be detrimental to birds.
Teck commits to implement the following mitigation measures to maximize recovery efficiency should birds use ponds (see the response to JRP IR 7.10, Table 7.10-1):
Develop procedure for handling of any bird recovered from wastewater ponds or tailings areas.
Procedure will be in compliance with directions received from the local Alberta Fish and Wildlife office and/or the Alberta Environment and Parks (AEP) wildlife biologist.
Procedure will also be in compliance with directions from Environment and Climate Change Canada with respect to whooping cranes.
Teck commits to implement the following mitigation measures to reduce the potential for bird mortality risk resulting from interaction with transmission and distribution lines (see the response to JRP IR 7.10, Table 7.10-1):
Designing transmission and distribution lines, where possible, to match the height of surrounding trees to reduce wire strikes by birds.
Marking of transmission and distribution lines in areas near waterfowl staging and potential stopover areas.
Teck has developed a Draft Waterfowl Protection Plan (see the response to JRP IR 7.10, Appendix 7.10). Teck will continue to pursue collaborative engagement processes, as outlined in the WMMP for the Project as the primary mechanism in which it will engage with potentially affected Indigenous groups regarding the Waterfowl Protection Plan. Once finalized, the plan will include a communication management section, which will outline how findings of the program will be communicated to interested parties.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Bison
Change in bison habitat availability
Establish a restoration Project for wildlife and vegetation habitat (Woven Paths 2015, p. 92).
Teck commits to implement the following mitigation measures to reduce direct habitat loss (see the response to JRP IR 7.5, Table 7.5-1):
Limit the size of the east side access road right-of-way (ROW) and temporary workspace to the extent practical.
Limit the Athabasca Rive bridge footprint in riparian areas.
Carry out progressive reclamation to reclaim disturbed wildlife habitat as portions of the mine footprint become available.
Develop a weed management plan.
Teck commits to implement the following mitigation measures to reduce indirect habitat loss (see the response to JRP IR 7.5, Table 7.5-1):
Implement strategies to reduce noise and light effects, including design considerations (e.g., Frontier Project plant site engineering and aerodrome operation within regulatory and safety constraints).
Limiting employee and contractor access to identified areas of high-quality habitat adjacent to Project footprint.
Teck has developed a Draft Ronald Lake Bison Mitigation, Monitoring and Adaptive Management Plan (see the response to JRP IR 7.5, Appendix 7.5). Teck has proposed steps to Indigenous groups that would provide the opportunity for land users and community members to provide direct input into developing wildlife mitigation measures, including those specific to bison. Once finalized, the plan will include a communication management section, which will outline how findings of the program will be communicated to interested parties.
Teck will also work with the responsible authority to explore possible mitigations for which Teck does not have the authority to implement independently.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Change in bison landscape connectivity
Establish a restoration Project for wildlife and vegetation habitat (Woven Paths 2015, p. 92).
Teck commits to implement the following mitigation measures to reduce change to landscape connectivity (see the response to JRP IR 7.5, Table 7.5-1):
Carry out progressive reclamation to restore vegetated corridors as portions of the mine footprint become available.
To maintain connectivity between Birch Mountains and Athabasca River:
o Coordinate development activities with Canadian Natural Resources Limited (CNRL) who acquired the Pierre River Mine oil sands leases formerly held by Shell Canada Limited should CNRL reapply for and develop the Pierre River Mine project.
o Develop an integrated land management strategy for the Project in consultation with industry, Indigenous stakeholders and the Province.
Provide wildlife passage under both sides of the Athabasca River bridge and river water intake bridge to Dalkin Island to allow north–south wildlife movement along river banks using crossing design considerations (e.g., bridge height and length) outlined in Clevenger and Huijser (2011) and GOA (2011):
o Set up educational signage to limit human use of wildlife underpasses.
o Evaluate wing fencing along the approach to crossing passages (at least 2.4 m high for large mammals as per GOA 2011) as part of the crossing structure design.
o Provide appropriate walking substrate along the wildlife underpass.
o Create vegetated buffers adjacent to wildlife underpasses to increase movement opportunities for a variety of species.
Teck has developed a Draft Ronald Lake Bison Mitigation, Monitoring and Adaptive Management Plan (see the response to JRP IR 7.5, Appendix 7.5). Teck has proposed steps to Indigenous groups that would provide the opportunity for land users and community members to provide direct input into developing wildlife mitigation measures, including those specific to bison. Once finalized, the plan will include a communication management section, which will outline how findings of the program will be communicated to interested parties.
Teck will also work with the responsible authority to explore possible mitigations for which Teck does not have the authority to implement independently.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Change in bison mortality risk Establish a restoration Project for wildlife and vegetation habitat (Woven Paths 2015, p. 92).
Teck commits to implement the following mitigation measures to reduce bison mortality risk resulting from vehicle–bison collisions (see the response to JRP IR 7.5, Table 7.5-1):
Implement fly-in/fly-out policy for workers to reduce vehicular traffic volume.
Erect wildlife cautionary signage on access roads.
Foster environmental awareness with speed restrictions on access roads, report Project-related wildlife fatalities.
Provide vegetation maintenance at roadsides (vegetation will be trimmed regularly to discourage roadside foraging and prevent visual obstruction of wildlife).
Develop seed mixes for roadside reclamation from less palatable species to reduce wildlife attraction to road edges.
Design the road to maximize line of sight.
Teck commits to implement the following mitigation measures to reduce bison mortality risk resulting from bison-human interactions - interactions with infrastructure (see the response to JRP IR 7.5, Table 7.5-1):
Frontier Oil Sands Mine Project Appendix 10.12
Table 10.12-4: Potential Adverse Environmental Effect and Mitigation Table – Fort Chipewyan Métis Local 125 (continued)
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Create fuel and chemical spill contingency and response plans.
Confirm adequate spill protection for all fuel storage facilities.
Monitor and maintain waste disposal sites, wastewater storage areas and runoff control structures to prevent contamination of surface waters.
During overburden dewatering, intermittently backslope the sides of drainage ditches to allow for wildlife crossings and to reduce the potential for entrapment.
Teck commits to implement the following mitigation measures to reduce bison mortality risk resulting from hunter access (see the response to JRP IR 7.5, Table 7.5-1):
Construct predator access blocks to deter predator use (i.e., reduce line of sight) on linear features in the PDA that may leave core bison areas susceptible to predation.
Deactivate roads in the PDA no longer in use.
Implement employee / contractor policies to prohibit hunting within the Project area.
Reduce linear features in the closure landscape.
Reduce width of linear features in the closure landscape.
Teck commits to implement the following mitigation measures to reduce bison mortality risk resulting from disease transmission to the Ronald Lake bison herd (see the response to JRP IR 7.5, Table 7.5-1):
Implement progressive reclamation in the PDA to create suitable Ronald Lake bison habitat and reduce the potential of shifting habitat use northward.
Mitigations associated with reducing hunter and predator access.
Mitigations associated with reducing wildlife human conflict.
Mitigations associated with reducing indirect habitat loss.
Teck has developed a Draft Ronald Lake Bison Mitigation, Monitoring and Adaptive Management Plan (see the response to JRP IR 7.5, Appendix 7.5). Teck has proposed steps to Indigenous groups that would provide the opportunity for land users and community members to provide direct input into developing wildlife mitigation measures, including those specific to bison. Once finalized, the plan will include a communication management section, which will outline how findings of the program will be communicated to interested parties.
Teck will also work with the responsible authority to explore possible mitigations for which Teck does not have the authority to implement independently.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Vegetation
Change in vegetation Establish a restoration Project for wildlife and vegetation habitat (Woven Paths 2015, p. 92).
Involve and consult Métis Local 125 directly in reclamation planning and monitoring for any oil sands projects that proceed with development (Integral Ecology Group 2015, p. v).
Develop and maintain an active Métis Local 125 consultation and engagement program to collect and incorporate Métis Local 125 knowledge and input on reclamation objectives into reclamation plans, as well update the community on project development and reclamation (Integral Ecology Group 2015, p. 92).
Support research on reclamation techniques to successfully restore the traditional land use capability of peat-forming wetlands, which are of particular importance to Métis Local 125 community (Integral Ecology Group 2015, p. 92).
Teck is committed to continue working with potentially affected Indigenous groups to refine the closure, conservation and reclamation (CC&R) plan through the life of the Project and to incorporate input from Indigenous groups on reclamation monitoring and thresholds and document the establishment of traditional use vegetation in the reclaimed landscape. Teck plans to co-create Reclamation Working Group(s) with potentially affected Indigenous groups to seek input to the Project’s reclamation plan and measures and targets to determine its success. It anticipates that species of traditional importance will be identified by Reclamation Working Group(s) and incorporated into reclamation planning as feasible. In addition, collaborative participation is planned in reclamation research both from a Project and regional perspective. Results of this research will be incorporated into future Project plans (see the response to JRP IR 6.9, Section 4.2).
Teck also commits to implement the following mitigation measures to reduce change in vegetation (see Volume 3, Appendix 17H, Section 17H.4 of the Project Update; response to JRP IRs 6.8 and 6.10):
Reclamation of the closure landscape will focus on generating a sustainable landscape that is designed to maximize diversity through the generation of landforms that include:
o topographic diversity and associated diversity in moisture regimes
o aspect diversity
o substrate diversity including both fine- and coarse- grained landforms
o mesotopography
Removal of existing linear disturbances that are currently fragmenting the landscape.
Mitigation to reduce effects on community diversity will focus on research results and strategies as summarized in:
o Guidelines for Reclamation to Forest Vegetation in the Athabasca Oil Sands Region (2nd Edition) (ESRD 2010)
o Guideline for Wetland Establishment on Reclaimed Oil Sands Leases (3rd Edition) (CEMA 2014)
o Oil Sands Marshes: A Knowledge Transfer (Charette et al. 2012)
o Best Management Practices for Conservation of Reclamation Materials in the Mineable Oil Sands Region of Alberta (MacKenzie 2011)
o Restoration and Reclamation of Boreal Ecosystems: Attaining Sustainable Development (Vitt and Bhatti 2012)
o Riparian Classification and Reclamation Guide, Revised Edition (Mihajlovich 2012)
Include peatlands in detailed CC&R planning should research results and recommendations prove to be feasible and appropriate.
Work with the governments of Alberta and Canada and look to their guidance on the development of a Conservation Agreement.
Plant additional species on the reclamation landscape, including those with traditional value, to supplement those recommended in provincial reclamation guidelines.
Mitigation for rare plant species will be achieved through avoidance whenever possible. In areas where avoidance is not possible, alternate mitigation strategies will be developed to promote conservation of these species and associated genetic diversity.
A weed management plan will be implemented throughout the life of the Project including during reclamation and at closure.
Develop and implement a program to salvage and relocate known occurrences of rare (vascular) plant species to areas outside of the Project area in consultation with Indigenous communities.
Incorporate species of traditional important as identified through the Reclamation Working Group(s) into reclamation planning, as feasible.
Engage Indigenous communities in preparing plans to harvest and collect seeds, and will invite community members to harvest and collect seeds of rare and culturally important species before disturbance, for use in reproducing the species and revegetation of the Project area.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures related to reclamation and evaluate monitoring results to determine if adaptations are warranted.
Historical Resources
Changes to historical resources None. Teck commits to implement the following mitigation measures regarding changes to historical resources within the Project disturbance area (see Volume 3, Appendix 17H, Section 17H.9 of the Project Update):
Frontier Oil Sands Mine Project Appendix 10.12
Table 10.12-4: Potential Adverse Environmental Effect and Mitigation Table – Fort Chipewyan Métis Local 125 (continued)
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within the Project disturbance area
Historical resources sites in the PDA that Alberta Culture and Tourism (ACT) determines to have moderate to high heritage value will likely have requirements for further study. These might include some or all of the following:
o Additional shovel testing to identify site boundaries, areas of highest artifact density, activity areas and areas with unique or specialized artifacts.
o Archaeological excavation at sites with high interpretive potential.
o Mapping and documentation at specific sites.
Teck will phase the required supplemental historic resources impact assessment (HRIA) studies to ensure completion of all necessary studies in the PDA in advance of vegetation clearing in each development area.
Teck will also work collaboratively with local First Nation and Aboriginal communities on mitigation studies, in an effort to address local concerns and interests in relation to historical resources in the area.
Socio-economics
Change to housing needs Métis Local 125 members would like to see improvements in housing, healthcare, water delivery and treatment, and support for local industry, they want to be consulted for their input on how such improvements would be implemented (Integral Ecology Group 2015, p. 91).
Teck commits to implement the following mitigation measures regarding housing needs (see the response to JRP IR 5.14(a), Table 5.15a-1):
Provide on-site, lodge-based accommodations during construction and operations to reduce the Project’s effect on the resident population and associated effects on social infrastructure and housing in the region.
Offer lodge amenities and services – including individual rooms and shared spaces, the quality of the food services and free-time activities – that are competitive with other lodge accommodations in the region.
Change to social infrastructure needs
Establish a Water Delivery Method Program (Woven Paths 2015, p. 92)
Subsidized food freight costs – fresh produce once a week at cost and cover freight (Woven Paths 2015, p. 92).
Bulk food-case lot business venture (Woven Paths 2015, p. 93).
Soup kitchen program (Woven Paths 2015, p. 93).
Grocery/meal delivery service for the elders and infirm (Woven Paths 2015, p. 93).
Youth greenhouse garden program (Woven Paths 2015, p. 93).
Métis Local 125 members would like to see improvements in housing, healthcare, water delivery and treatment, and support for local industry, they want to be consulted for their input on how such improvements would be implemented (Integral Ecology Group 2015, p. 91).
Develop or improve the systems and programs that support health and well-being (Integral Ecology Group 2015, p. v).
Teck commits to implement the following mitigation measures regarding social infrastructure needs (see the response to JRP IR 5.14(a), Table 5.15a-2):
Maintain explicit and enforced lodge, workplace and flight policies with regards to the use of alcohol, drugs and illegal activities.
Provide onsite security services, including controlled gates, check-in procedures, perimeter security fencing and lodge-based security officers on duty 24 hours.
Offer in-house security services to assist the Royal Canadian Mounted Police (RCMP) within, and sometimes outside, the Project lease boundaries (e.g., securing accident scenes and assisting with highway closures).
Develop and implement an emergency response plan which includes the required personnel, procedures and equipment resources (e.g., vehicles, fire response, medical response and rescue).
Develop required mitigation measures for areas adjacent to the Project area based on the FireSmart Wildfire Assessment System and implement in the emergency response plan.
Enter into mutual aid agreements with the Regional Municipality of Wood Buffalo (RMWB) and other oil sands companies that include:
o responding to motor vehicle accidents on Highway #63
o responding to forest fire threats to Fort McKay
o responding to regional spills
Participate in the management of regional emergencies at the RMWB’s Regional Emergency Operations Centre.
Make available onsite health services, including an on-site medical facility staffed by qualified health professionals providing 24-hour on-site primary, emergency and occupational health services.
Consider financial and in-kind contributions to the Northern Lights Health Foundation, where appropriate, to support the efforts of Alberta Health Services to meet the needs of Wood Buffalo residents. Recognizing some of the health concerns in the region Teck is prepared to make health promotion and disease prevention initiatives a focus of their community investment policy.
Provide helicopter or fixed-wing aircraft access via the on-site aerodrome for injured workers requiring rapid evacuation for off-site medical care.
Discuss with other industrial proponents near the Project options for coordinating on-site health facilities and resources.
Assess and support school events and education initiatives identified by rural schools in the study area, as appropriate.
Provide employees with access to the company’s confidential Employee and Family Assistance Plan, which provides support for families and individuals who might experience difficulty dealing with personal, family or work-life issues that can affect one’s health and well-being.
Consider support for community level initiatives including social groups providing assistance to those in need.
Continue providing direct support to community initiatives through its social investment programs.
Offer shift schedules that provide workers with sufficient time off to enjoy leisure activities in their home communities.
Make available onsite recreational opportunities and facilities.
Change to transportation needs None. Teck commits to implement the following mitigation measures regarding transportation needs (see the response to JRP IR 5.14(a), Table 5.14a-3):
Construct and operate an aerodrome near the Project site.
Use on-site as well as regional lodge accommodations during both construction and operations to reduce worker commutes.
Use bus service for transporting construction and operations workers.
Limit private vehicles brought to the Project site.
Schedule truck traffic, including oversized loads, to off-peak hours.
Use an on-site concrete batch plant; and attempt to source aggregates from pits near to site.
Enforce lodge, workplace and flight policies with regards to the use of alcohol, drugs and illegal activities.
Work with the local RCMP to confirm communication on local effects.
Support the efforts of RMWB and Oil Sands Community Alliance (OSCA) to work with the provincial government to progress improvements to highway infrastructure in a timely way.
Keep responsible regional and provincial planners informed of the Project’s development plans and their timing.
Consult and cooperate with other operators regarding shift scheduling with a view to reduce overlap in commuter traffic.
Provide funding to assist in the maintenance and safety of applicable segments of Highway #63 from Fort McKay to Fort Chipewyan that are affected by the Project.
Change to municipal infrastructure needs
Alternative energy pilot project/study (Woven Paths 2015, p. 93).
Métis Local 125 members would like to see
Teck commits to implement the following mitigation measures regarding municipal infrastructure (see the response to JRP IR 5.14(a), Table 5.14a-4):
Provide water and sewer services for the different mining areas and the associated processing facilities and infrastructure, including on-site lodges.
Teck commits to implement the following mitigation measures regarding choice of fly-in/fly-out (FIFO) (see the response to JRP IR 5.14(a), Table 5.14a-6):
Frontier Oil Sands Mine Project Appendix 10.12
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improvements in housing, healthcare, water delivery and treatment, and support for local industry, they want to be consulted for their input on how such improvements would be implemented (Integral Ecology Group 2015, p. 91).
A FIFO lodge-based approach to construction and operations.
Ongoing monitoring of the operations FIFO model and revisiting the approach should local circumstances change.
Teck’s monitoring will take into consideration input received via its workers, contractors and ongoing local stakeholder and Indigenous engagement process. This would likely include feedback with respect to the social and economic effects of the FIFO model on individual workers, their families and communities.
Commitment to include Fort Chipewyan in a FIFO program.
Engage with potential employees living in Fort Chipewyan to discuss shift schedules and other travel and lodging logistics that influence their choice to work at the Project versus other opportunities.
Discuss with local communities the design of FIFO shifts that best benefit its employees and families while remaining logistically and financially feasible.
Remain open to engaging in broader, regional initiatives, for example through the OSCA and its study of the use of aerodromes in the region.
Change to employment, business and training opportunity needs
Removal of mixed economy opportunities and replaced with economic opportunities. Must be provided with preferential opportunities for employment, procurement and training in order to maximize project benefits for the community (Woven Paths 2015, p. 93)
Alternative energy pilot project/study (Woven Paths 2015, p. 93).
Develop and implement employment services and job training programs for youth and other community members (Integral Ecology Group, p. v).
Teck commits to implement the following mitigation measures regarding employment, business and training opportunity needs (see the response to JRP IR 5.14(a), Table 5.14a-5):
Specific contractual commitments to Indigenous communities on employment, business and training opportunities will be made within Participation Agreements negotiated between Teck and the Indigenous community.
Prioritize recruiting residents from the region first, Alberta second, followed by the rest of Canada, then North America and then overseas countries.
Draw on various sources of labour in Canada that are traditionally under-represented in the labour market, including Indigenous people, immigrants and women.
Put in place a policy to hire local businesses and contractors that are competitive and able to meet the company’s needs is already in place.
Teck will consult with Indigenous communities regarding procurement and employment initiatives such as:
o Establishing mechanisms to enhance employment prospects of local residents, including preferential consideration.
o Using procurement processes that regard local ownership and prevalence of workers residing locally as positive criteria in goods and services vendor selection competitions.
o Establishing monitoring programs that measure local involvement, gather feedback and work with interested parties on how to improve results.
Implement Teck’s relevant charters, codes and policies, including its Indigenous Peoples Policy, when working with Indigenous peoples in seeking to develop lasting mutual benefits that respect Indigenous community’s values – including hiring, training and retention of Indigenous employees.
Utilize what Teck’s has learned to date from local Indigenous communities with which it is engaged for the Project to overcome oil sands specific challenges to Indigenous employment and procurement.
Consider work experience in lieu of a high school graduation for Indigenous peoples.
Work with the Fort McMurray Chamber of Commerce, the Northeastern Alberta Aboriginal Business Association (NAABA) and others to maximize contracting and employment opportunities in the region.
Offer a choice of worker turnaround cycles and opportunity to earn premium pay through overtime.
Continue to work with the Indigenous communities in the area and specifically with the communities of Fort McKay and Fort Chipewyan to develop Indigenous employment and business development program(s) guided by a commitment to: maximize opportunities for local Indigenous businesses to supply services and products in support of Project construction and operations; hire qualified Indigenous people from the communities surrounding the Project and support education, training and investment initiatives in local Indigenous communities, where appropriate.
Teck’s Indigenous community employment and business development program(s) will engage with Indigenous communities on establishing employment and procurement policies and procedures, as well as adaptive management mechanisms specific to Indigenous community employment and procurement.
Teck’s Indigenous community employment and business development program(s), as well as community-specific Participation Agreements will take into consideration input provided by local Indigenous communities, and will be guided by a commitment to: develop substantial opportunities for local Indigenous businesses to supply services and products in support of Project construction and operations; hire qualified Indigenous people from the communities surrounding the Project and support education, training and investment initiatives in local Indigenous communities, where appropriate.
Continuously monitor Teck’s local employment and procurement policies and programs, along with reporting the results of this monitoring as part of ongoing community consultation.
Teck has yet to determine the exact reporting and monitoring mechanisms for its local procurement and employment policies, but will engage with Indigenous communities on mechanisms and expects they will likely be similar to mechanisms used by Teck’s other operations. These might include:
o Total employment, attraction and retention rates, average salary levels and other general human resource data. Where possible, the data will be disaggregated at the local community level.
o Procurement activity, including examination of goods and services sourced from providers in local communities, value and length of contracts, types of goods and services provided and employment and enterprise effects associated with procurement.
o Additional potential mechanisms are identified in Teck’s draft socio-economic monitoring plan in response to JRP IR 5.15(a).
Continue supporting local labour force skills development, and work with communities, government and other industrial proponents on programs that assist community members overcome labour market barriers.
Change to culture The locations of places of spiritual, historical and cultural importance, particularly those identified by Métis members of the Hermansen family, ought to be recognized, marked and avoided by project construction where possible. Where not possible, removal plan options should be discussed with the Hermansen family, secondarily with Métis Local 125, in the event structures or objects wish to be salvaged, or ceremonially respected (Woven Paths 2015, p. 92).
Recognition of Métis history, use and place names in the area should be formally preserved in infrastructure, buildings and company related social programs / initiatives as a way to inform employees and the public of what was valued in the Project area before (Woven Paths 2015, p. 92).
Teck commits to implement the following mitigation measures regarding changes to culture (see the response to JRP IR 5.14(a), Tables 5-14a-6 and 5.14a-7):
Continue to expand Teck’s knowledge of, and engagement with, local stakeholders and Indigenous communities near the Project to confirm ongoing and growing participation in Project-related benefits, as well as the design of appropriate and effective mitigation measures to reduce any adverse effect. These efforts are envisioned to include capacity building support within Participation Agreements for Indigenous communities.
Provide cultural diversity awareness training to employees and contractors, focusing on respect for traditional land users as well as respect for Indigenous world views, customs and values.
Consider supportive workplace practices as Teck develops workplace policies and seek local Indigenous community input into cultural awareness programming to be provided at the Project site.
Carry out a review of Teck’s standard bereavement policy, including a review of policies from other fly in/fly out operations in Alberta, as operation specific policies are developed during future planning phases.
Continuing to provide cultural awareness training for all Project staff and contractors.
Considering key Indigenous access routes and access preferences in the Project’s draft Access Management Plan (AMP).
Considering cultural keystone species in the wildlife management and mitigation plan, FHCL and biodiversity management plan.
Incorporating and using Indigenous place names where applicable.
Supporting community-led projects to document Indigenous place names in their respective traditional territories.
Contributing to language retention programs and other programs that support retaining Indigenous culture, knowledge and practice (e.g., culture camps for youth).
Discuss with local communities the design of fly in/fly out shifts that best benefit its employees and families while remaining logistically and financially feasible.
Frontier Oil Sands Mine Project Appendix 10.12
Table 10.12-4: Potential Adverse Environmental Effect and Mitigation Table – Fort Chipewyan Métis Local 125 (continued)
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Potential Adverse Effects Mitigation Proposed by Fort Chipewyan Métis
Local 125 in TLU Study and CIA Mitigation Teck Commits to Implement
Regular Aboriginal Awareness Training on site for all departments and new employees, and relevant contractors (Woven Paths 2015, p. 92).
Increased competitive access for land & recreational use, cultural practices and knowledge transmission: cabins and campsites built for Métis culture camps / family use (Woven Paths 2015, p. 93).
Cultural / Spiritual-heritage, health & wellness and spiritual maintenance programs: centre for community cultural gatherings, cultural programs, office space and health care program subsidy (Woven Paths 2015, p. 93).
Develop and implement programs to support knowledge and language retention (Integral Ecology Group 2015, p. v).
Continue to document cultural heritage and development of cultural indicators to monitor, maintain and strengthen Métis Local 125 cultural integrity into the future (Integral Ecology Group 2015, p .v).
Conduct additional research into cumulative effects and land-use planning to support a long-term vision to minimize adverse effects and strengthen cultural integrity (Integral Ecology Group 2015, p .v).
Support for a schedule of interviews and/or additional focus groups and possibly a community-based monitoring program to generate a complementary synthesis of qualitative and quantitative measures for a given set of cultural attributes or practices (Integral Ecology Group 2015, p. 94).
Access
Change to access near the Project disturbance area
Access management planning must be designed to enhance Métis Local 125 access to areas on the west side of the Athabasca River, while restricting worker’s off hours access to the local study area (LSA). Métis Local 125 access should be prioritized over non-Aboriginal harvesters competing for land use and ecologically damaging recreational activities in the LSA. Access corridors through the LSA and development areas should be maintained where safety permits (Woven Paths 2015, p. 91).
Teck has developed a draft access management plan (AMP) for the Project to facilitate access to or through Teck’s mineral surface lease to the extent possible while maintaining worker and public safety (see the response to JRP 4.5, Appendix 4.5). Teck has proposed next steps to Indigenous groups that would provide the opportunity for land users and community members to provide direct input into developing access mitigation measures. This input will refine the draft AMP.
Teck commits to implement the following mitigation measures to reduce potential effects on changes to access near the Project disturbance area (see Volume 3, Appendix 17H, Section 17H.8.2 of the Project Update) and the response to JRP IR 10.9):
All individuals wanting to gain access to or through lands being actively developed, which is generally Teck’s mineral surface lease (MSL), will be required to submit an access request.
Traditional land users will be granted temporary access to and through the PDA according to the policy and processes set out in the AMP.
Traditional land users will not have to meet worker site access requirements but will be escorted by someone who has permanent site access (i.e., a worker).
Access through, and to portions of the PDA not being actively developed will not require an access request form be submitted. Individuals will be required to contact the site’s security office and provide adequate notice about when they plan to be in the area, who will be present, and the intended activities and general location(s) as they relate to Teck leases. All individuals passing through the PDA will have to check in at the security office and will be escorted by a Teck worker. Teck understands that Aboriginal communities desire that the advance notice period.
Throughout the life of the mine, access to locations in the PDA by Aboriginal community members will be based on mine advance. For safety reasons, harvesting and use of firearms would not be permitted in areas being actively mined or within and around facilities associated with the mine.
The River Road will be maintained through operations and will provide access to the Fish Habitat Compensation Lake, aerodrome, and areas north of the PDA.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Traditional Land Use
Change in availability of resources (wildlife, fish and vegetation), culturally important sites or areas for traditional activities and use of lands
Compensatory and mitigative discussion with the trapline holder will be conducted separately (Woven Paths 2015, p. 91).
Teck should participate in regional environmental monitoring initiatives and regional multi-stakeholder advisory groups alongside Aboriginal communities in recognition of their
Teck commits to implement the following mitigation measures to reduce changes in availability of resources (wildlife, fish and vegetation), culturally important sites or areas for traditional activities and use of lands (assessed in Volume 3, Section 17.6 of the Project Update) (see the response to JRP IR 4.6, Table 4.6-1):
Grant traditional land users temporary access to and through the PDA according to the policy and processes set out in the draft access management plan.
Implement measures to mitigate Project-related effects on wildlife through the wildlife monitoring and mitigation plan.
Engage Indigenous communities in the development of a biodiversity management plan.
Implement measures to mitigate Project-related effects on fish and fish habitat through the detailed fisheries offsetting plan.
Implement measures to reduce Project-related effects on vegetation through the conservation closure and reclamation plan and the reclamation monitoring plan.
Frontier Oil Sands Mine Project Appendix 10.12
Table 10.12-4: Potential Adverse Environmental Effect and Mitigation Table – Fort Chipewyan Métis Local 125 (continued)
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Potential Adverse Effects Mitigation Proposed by Fort Chipewyan Métis
Local 125 in TLU Study and CIA Mitigation Teck Commits to Implement
rights and interests, including the right to a clean and safe environment, an affordable local economy, and healthy land base for sustainable traditional harvesting (Woven Paths 2015, p. 91).
Subsidized hunting program – every Métis house to receive wild meat (Woven Paths 2015, p. 92).
Increased competitive access for land & recreational use, cultural practices and knowledge transmission: cabins and campsites built for Métis culture camps / family use (Woven Paths 2015, p. 93).
Historical resources sites in the PDA that Alberta Culture and Tourism (ACT) determines to have moderate to high heritage value will meet the requirements of ACT and aim to meet the desires of Indigenous communities.
Teck commits to implement the following mitigation measures to reduce effects on the land use experience for traditional land users (see the response to JRP IR 4.6, Table 4.6-1):
Establish Participation Agreements with Indigenous communities.
Invite traditional users to harvest traditional plants before disturbance.
Support the planning and implementation of an excursion for Indigenous communities within the terrestrial local study area prior to Project-related disturbance to describe Indigenous values, access and to recommend mitigation to avoid or limit effects on Indigenous access values.
Provide cultural diversity awareness training to employees and contractors focusing on respect for Indigenous land users, traplines, cabins, trails and equipment, as well as respect for Indigenous world views, customs and values.
Compensate Indigenous trappers following industry-community standards and the Alberta Trappers Compensation Program.
Project personnel will be prohibited from fishing, hunting and trapping within the PDA during work rotations, which is when Teck’s policies’ can be enforced.
Project personnel will be prohibited from using personal recreation vehicles within the PDA.
Investigate with potentially affected Indigenous communities through the Reclamation Working Group the concept of incorporating cultural values into reclamation planning.
Supporting documentation of community-specific cultural heritage.
Teck has developed a Draft Traditional Land Use Mitigation, Monitoring and Adaptive Management Plan (see the response to JRP IR 4.6, Appendix 4.6). Teck will continue to seek input and engage with Indigenous groups, as well as regulators where appropriate, as part of finalizing this plan. Once finalized, Teck will continue to pursue collaborative engagement processes with Indigenous groups as outlined in the plan. Through these collaborative engagement processes Teck will aim to minimize and mitigate potential Project effects on traditional land use. Once finalized, the plan will include a communication management section, which will outline how findings of the program will be communicated to interested parties.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Notes:
NOx = oxides of nitrogen; SO2 = sulphur dioxide; PM2.5 = particulate matter.
Frontier Oil Sands Mine Project Appendix 10.12
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3 Fort McKay First Nation
A summary of established or asserted Aboriginal and treaty rights, current use of lands and resources for
traditional purposes and cultural and physical heritage features as described by Fort McKay First Nation
(FMFN) is presented in Table 10.12-5.
Table 10.12-5: Fort McKay First Nation Rights, Land Uses and Cultural and Physical Heritage Features
Established or Asserted Aboriginal and Treaty Rights, Current Use of Lands and Resources for Traditional
Purposes Cultural and Physical Heritage Feature
Hunting
Hunting food in all seasons
Fishing
Trapping
Plant harvesting
Commercial harvest for RFMA holders
Pursuit of way of life
Use, enjoyment and control of lands
Livelihood from traditional lands
Sufficient lands and resources and access to them of a quality and nature sufficient to support meaningful experience
Site-specific cultural features and cultural practices
Physical cultural sites
Cultural practices
Cultural landscapes
Cultural values
Wellbeing
Potential adverse Project effects on FMFN’s established or asserted Aboriginal and treaty rights, current
use of lands and resources for traditional purposes or cultural and physical heritage are presented in
Table 10.12-6, along with mitigation proposed by FMFN in their TLU study (Fort McKay and Integral
Ecology Group 2011) and CIA (Integral Ecology Group 2016), and mitigation that Teck has committed to
implement to reduce these potential effects.
The mitigation proposed by FMFN in their TLU study and CIA may not be reflected, as articulated by
FMFN, in the mitigation measures outlined in Table 10.12-6, for one or more of the following reasons:
The mitigation measure proposed by FMFN is directly or indirectly reflected in one or more
mitigation measures outlined by Teck.
The mitigation measure proposed by FMFN is beyond the scope or control of a what a single
proponent can mitigate.
The mitigation measure proposed by FMFN is within the scope of ongoing activities that Teck and
FMFN will undertake as part of implementing a Participation Agreement (discussed below).
In 2016 Teck and FMFN entered into a Participation Agreement for the Project. Teck’s mitigation plans for
the Project will be further discussed with FMFN as part of joint Participation Agreement implementation
efforts.
Frontier Oil Sands Mine Project Appendix 10.12
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Table 10.12-6: Potential Adverse Environmental Effect and Mitigation Table – Fort McKay First Nation
Potential Adverse Effects Mitigation Proposed by Fort McKay First Nation in TLU
Study and CIA Mitigation Teck Commits to Implement
Hydrology and Water Quality
Changes in flows, water levels and open water areas
None. The Athabasca River will satisfy the Project’s makeup water requirements, and an off-stream storage pond (OSSP) will supply the Project with water during periods when river water withdrawal is restricted (see the response to Joint Review Panel (JRP) Information Request (IR) 10.26, Appendix 10.26, Section 7.1).
Teck commits to implement the following mitigation measures to reduce changes in flows and water levels in receiving waterbodies (see the response to JRP IR 10.25, Appendix 10.25, Table 10.25-1):
Reduce changes to flows in Ronald Lake by using a flow splitter on the Redclay Creek diversion during operations.
Reduce changes to flows in Big Creek by using a flow splitter on the Big Creek diversion during operations.
Distribute muskeg drainage operations through the mine life, thereby avoiding a large increase in flows in the receiving waters.
Reduce effects of closed-circuit operations on flows and water levels in receiving waters by diverting natural watercourses that will not be disturbed by the mining operations around the mining area to receiving watercourses.
Reduce river-water withdrawal requirements from the Athabasca River by maximizing closed-circuit recycling of surface and groundwater where practical, and by storing sufficient amounts of water in an off-stream storage pond in the event of extended withdrawal restrictions from the Athabasca River.
Progressively construct and develop diversion systems, which helps limit the change in open-water areas during construction and operation by providing new drainage channels to replace the loss of natural watercourses and waterbodies.
Reduce changes to flows and water levels in receiving waters by developing a closure drainage layout that will limit changes in drainage areas contributing flows to the receiving watercourses relative to predevelopment conditions.
Design watercourses, waterbodies and wetlands during reclamation to attenuate floods.
Teck is committed to continue to consult meaningfully with, and engage, all potentially affected Indigenous groups at both a Project-specific and regional level to reduce and mitigate potential Project and cumulative effects on hydrology and surface water quality, including continuing discussions regarding hydrology and surface water quality concerns and is prepared to consider additional mitigation measures to address these concerns (see the response to JRP IR 10.25, Appendix 10.25).
Teck has developed a Draft Hydrology and Water Quality Mitigation, Monitoring and Adaptive Management Plan (see the response to JRP IR 10.25, Appendix 10.25). Once finalized, the plan will include a communication management section, which will outline how findings of the program will be communicated to interested parties.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Changes in sediment yields, concentrations and channel regimes (geomorphology)
None. Teck commits to implement the following mitigation measures to limit release of Total Suspended Solids (TSS) (see the response to JRP IR 10.25, Appendix 10.25, Table 10.25-1):
Follow relevant regulatory guidelines, standards and best management practices during construction and operation to reduce the risk of increased sediment loadings to receiving watercourses.
Construct and operate sedimentation ponds to settle TSS where necessary.
Control sediment generation in diversion channels through revegetation of streambanks, overbank areas and berms as soon as possible after construction and by the use of channel armour (riprap), where required.
Direct muskeg and overburden drainage waters to polishing ponds equipped with oil-separation capability.
Reduce sediment yields from reclaimed surfaces by developing appropriate final topography and soil moisture conditions.
Resuspension of sediments from the bottom of polishing ponds, wetlands and pit lakes will be reduced through appropriate hydraulic design.
Reduce gullying and channel erosion by developing robust and sustainable reclamation drainage systems with built-in self-healing capability and robustness similar to natural drainage systems.
Teck commits to implement the following mitigation measures to reduce changes in flood flows and geomorphology downstream of the Project (see the response to JRP IR 10.25, Appendix 10.25, Table 10.25-1):
Limit changes in flood flows in receiving watercourses relative to predevelopment conditions. Mitigation measures listed for the “reduce changes in flows and water levels” above are relevant for mitigating flood flows.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Direct water emissions:
Muskeg drainage and overburden dewatering flows
Drainage from operating and reclaimed mine site
Basal water sands depressurization
Process-affected seepages from backfilled mine pits and tailings disposal areas
None. Teck commits to implement the following mitigation measures to limit the release of ions, nutrients, metals, polycyclic aromatic hydrocarbons (PAHs) and other parameters during operations and closure and protect sediment quality in downstream watercourses and waterbodies (see the response to JRP IR 10.25, Appendix 10.25, Table 10.25-1):
Recycle process-affected waters and runoff within the Project disturbance area (PDA) in a closed-circuit system during operations.
Using a perimeter ditch and groundwater wells to capture and pump back seepages and runoff from the external tailings areas (ETAs) back into the tailings areas during operations.
Design the closure drainage system to capture seepage and runoff from ETAs, external disposal areas (EDAs) and the Frontier Project plant site and directing it to wetlands, pit lakes or constructed reclamation lakes during the mine closure management phase.
Use wetlands, constructed reclamation lakes and pit lakes during and after the decommissioning and closure phases to provide biological remediation and settling of particulate materials in reclamation waters before discharge.
Respond to spills using best management practices. Project activities will follow safety protocols designed to limit accidents and reduce effects if an accident should occur.
Teck commits to the following mitigation measures to manage depressurization water during preproduction (see Volume 1, Section 7.6.5 and 7.8.4 of the Project Update):
Teck plans to manage depressurization water during preproduction by storing approximately half of it in a storage pond at surface and reinjecting the remaining half into the BWS aquifer.
Teck is committed to continue to consult meaningfully with, and engage, all potentially affected Indigenous groups at both a Project-specific and regional level to reduce and mitigate potential Project and cumulative effects on hydrology and surface water quality, including continuing discussions regarding hydrology and surface water quality concerns and is prepared to consider additional mitigation measures to address these concerns (see the response to JRP IR 10.25, Appendix 10.25).
Teck has developed a Draft Hydrology and Water Quality Mitigation, Monitoring and Adaptive Management Plan (see the response to JRP IR 10.25, Appendix 10.25). Once finalized, the plan will include a communication management section, which will outline how findings of the program will be communicated to interested parties.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Frontier Oil Sands Mine Project Appendix 10.12
Table 10.12-6: Potential Adverse Environmental Effect and Mitigation Table – Fort McKay First Nation (continued)
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Potential Adverse Effects Mitigation Proposed by Fort McKay First Nation in TLU
Study and CIA Mitigation Teck Commits to Implement
Pit lake releases None. Teck will leverage the knowledge gained through its other reclamation efforts, along with research through regional initiatives such as Canada’s Oil Sands Innovation Alliance (COSIA), to develop healthy, functional ecosystems in the Project pit lakes (see the response to JRP IR 2.3).
Teck also commits to implement the following mitigation measures when designing closure drainage and pit lakes for hydrological sustainability and to promote effective passive treatment of process-affected waters and to support a viable aquatic ecosystem prior to release and to sequester tailings and other mine waste in the most appropriate location at mine closure (see the response to JRP IR 10.25, Appendix 10.25, Table 10.25-1):
Exclude tailings from pit lakes.
Do not release water from pit lakes until acceptable quality is achieved.
Maintain the water balance of the pit lakes with sufficient inflows to compensate for evaporative losses.
Manage the rate of Athabasca River water input to pit lakes as appropriate to confirm water quality filling targets are met and to comply with Athabasca river low flow restrictions.
Include wetlands reclamation lakes for treatment purposes in reclamation drainages to the pit lakes.
Teck is committed to continue to consult meaningfully with, and engage, all potentially affected Indigenous groups at both a Project-specific and regional level to reduce and mitigate potential Project and cumulative effects on hydrology and surface water quality, including continuing discussions regarding hydrology and surface water quality concerns and is prepared to consider additional mitigation measures to address these concerns (see the response to JRP IR 10.25, Appendix 10.25).
Teck has developed a Draft Hydrology and Water Quality Mitigation, Monitoring and Adaptive Management Plan (see the response to JRP IR 10.25, Appendix 10.25). Once finalized, the plan will include a communication management section, which will outline how findings of the program will be communicated to interested parties.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Changes in quality of groundwater and surface water downgradient of EDAs
None. Teck commits to implement the following mitigation measures to maintain surface water quality in consideration of surface flows into and out of the Project area and groundwater discharge (see the response to JRP IR 10.25, Appendix 10.25, Table 10.25-1):
Groundwater and surface waters draining EDAs will be captured if monitoring data indicate that the drainage waters are unsuitable for release.
Teck is committed to continue to consult meaningfully with, and engage, all potentially affected Indigenous groups at both a Project-specific and regional level to reduce and mitigate potential Project and cumulative effects on hydrology and surface water quality, including continuing discussions regarding hydrology and surface water quality concerns and is prepared to consider additional mitigation measures to address these concerns (see the response to JRP IR 10.25, Appendix 10.25).
Teck has developed a Draft Hydrology and Water Quality Mitigation, Monitoring and Adaptive Management Plan (see the response to JRP IR 10.25, Appendix 10.25). Once finalized, the plan will include a communication management section, which will outline how findings of the program will be communicated to interested parties.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Air Quality and Odour
NOX emissions None. Teck commits to implement the following mitigation measures to reduce NOX emissions from combustion sources (see the response to JRP IR 3.18, Table 3.18-1):
Use natural gas as a fuel for the cogeneration plant and boilers and heaters.
Dry low NOX technology to reduce NOX emissions and increase cogeneration plant efficiency.
Boiler and heater technology that will meet provincial and federal government emission requirements.
Purchase Tier IV compliant haul trucks when they become available.
Optimize mine planning to reduce haul distances.
Develop and implement an anti-idling program for the mine fleet.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
SO2 emissions None. Teck commits to implement the following mitigation measures to reduce SO2 emissions from combustion sources (see the response to JRP IR 3.18, Table 3.18-1):
Use natural gas as a fuel for the cogeneration plant and boilers and heaters.
Use ultra-low sulphur diesel for the mine fleet.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
PM2.5 and dust emissions None. Teck commits to implement the following mitigation measures to reduce PM2.5 emissions from combustion sources (see the response to JRP IR 3.18, Table 3.18-1):
Use natural gas as a fuel for the cogeneration plant and boilers and heaters.
Boiler and heater technology that will meet provincial and national government emission requirements.
Purchase Tier IV compliant haul trucks when they become available.
Optimize mine planning to reduce haul distances.
Develop and implement an anti-idling program for the mine fleet.
Teck commits to implement the following mitigation measures to reduce fugitive dust emissions (see the response to JRP IR 3.18, Table 3.18-1):
Dust mitigation measures to be applied to onsite roads during construction include appropriate selection of road materials, limiting vehicle speeds, surface watering, progressive reclamation, temporary vegetation of disturbed land and retain natural vegetation as windbreaks.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Hydrocarbon and reduced sulphur emissions and secondary organic aerosol precursor emissions
None. Teck commits to implement the following mitigation measures to reduce fugitive plant emissions (see the response to JRP IR 3.18, Table 3.18-1):
Use floating roof tanks where appropriate and a vapour recovery system to condense and recover vapours from storage tanks and process areas.
Frontier Oil Sands Mine Project Appendix 10.12
Table 10.12-6: Potential Adverse Environmental Effect and Mitigation Table – Fort McKay First Nation (continued)
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Potential Adverse Effects Mitigation Proposed by Fort McKay First Nation in TLU
Study and CIA Mitigation Teck Commits to Implement
Use dual solvent vapour recovery units to provide full redundancy.
Conduct a leak detection and repair (LDAR) program to identify leaking components and to prioritize associated repairs.
Teck commits to implement the following mitigation measures to reduce fugitive mine face emissions (see the response to JRP IR 3.18, Table 3.18-1):
Mitigation not currently known.
Teck commits to implement the following mitigation measures to reduce fugitive tailings area emissions (see the response to JRP IR 3.18, Table 3.18-1):
Tailing solvent recovery unit to maintain losses to less than four volumes of solvent to 1,000 volumes of bitumen produced.
Teck commits to implement the following mitigation measures to reduce hydrocarbon and reduced sulphur emissions from combustion sources (see the response to JRP IR 3.18, Table 3.18-1):
Use natural gas as a fuel for the cogeneration plant and boilers and heaters.
Purchase Tier IV compliant haul trucks when they become available.
Optimize mine planning to reduce haul distances.
Develop and implement an anti-idling program for the mine fleet.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Odour None Teck has developed a draft Odour Management and Response Plan (see the response to JRP IR 3.13, Appendix 3.13). The draft Plan. The Plan’s goals are mitigation, monitoring, participation in regional complaint process, and correlation of complaints to Project activities to determine response actions. The Plan will be finalized following consultation with Indigenous communities, regulators and stakeholders.
At any time during Project operation, nearby residences will be able to contact Teck if they are concerned that Project operations are causing odours. The contact will be documented, investigative action will be initiated to determine the potential source, and the caller will be notified. If a source can be identified, a review will be undertaken to implement corrective action to reduce the potential for future occurrences (ERCB Round 1 SIR 113a; Appendix 3.13).
Acoustics
Change in sound levels
None. Teck has made an overall commitment to managing and promptly addressing all noise-related concerns (see Volume 3, Section 3.4.9.2, Project Update) and will develop a Noise Management Plan (see Volume 3, Section 3.4.9.1, Project Update).
Teck also commits to implement the following mitigation measures to reduce changes in sound levels (see Volume 3, Appendix 17H, Section 17H.5 of the Project Update and the response to JRP IR 1.3, Table 1.4-1):
Vehicles will be maintained in good working condition (e.g., mufflers will be maintained) and speed limits will be enforced.
Emergency alarms will be tested during daytime, where reasonably practical.
Acoustic performance of building wall construction will meet a minimum sound transmission class (STC) rating of 29, based on published data in the North American Insulation Manufacturers Association for a pre-engineered structure.
For outdoor equipment, the manufacturer incorporates mitigation in the equipment design to achieve the published sound power level.
Noise effects will be mitigated using various measures, including but not limited to the following:
o haul trucks exhaust silencer
o haul truck speed
o trip frequency (number of trips per daytime and nighttime period)
o route location or alignment
Ventilation openings (i.e., air intake and exhaust openings) will be fitted with appropriate acoustic silencers, louvers, or plenums, where applicable, to reduce outdoor sound transmission from indoor equipment.
Buildings housing indoor noise-generating equipment will be appropriately sealed to reduce noise.
Where practical, flanking path and penetrations from plumbing, heating ducts and electrical wire in the buildings will be properly insulated and covered to reduce noise.
Appropriate acoustical lagging will be installed to provide additional attenuation to the steel casing, where practical.
Vibration isolation pads, resilient mounts on equipment, resilient pipe support systems, and dampers will be installed where appropriate.
Teck will incorporate best management practices to reduce Project-related noise into Daily Operational Procedures, Long-Term Operational Procedures, design for low-noise facilities, and performance measurement as described in SPOG (2012) Best Practices Document, where appropriate (ERCB Round 1 SIR 116; Volume 3, Section 3.4.9.1 of the Project Update), including:
Daily Operational Procedures
Keeping compressor station doors and windows closed
Using belt dressing
Inspecting and repairing mufflers
Running fans slower at night (variable frequency drive [VFD])
Using vent silencers on buildings
Using soundproofing (insulation and lagging)
Troubleshooting transient noise
Minimizing flaring and venting
Considering gravel pack around compressor building skids
Developing noise check in daily reading sheets
Long-Term Operational Procedures
Frontier Oil Sands Mine Project Appendix 10.12
Table 10.12-6: Potential Adverse Environmental Effect and Mitigation Table – Fort McKay First Nation (continued)
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Potential Adverse Effects Mitigation Proposed by Fort McKay First Nation in TLU
Study and CIA Mitigation Teck Commits to Implement
Responding quickly to noise concerns
Establishing baseline noise levels (in plant, at fence-line, or both) and resurvey to determine trends
Conducting regular assessment of noise control opportunities
Using best practical technology for noise control
Maintaining communication links with noise sensitive receptors and communities
Being aware of noise from contractors (e.g., service rigs) and developing processes to meet best practice expectations
Scheduling work to create the least amount of noise effects on noise sensitive receptors and keeping those affected informed
Design for Low Noise Facilities
Considering low noise electric drives versus engine driven compressors
Designing cooler fans for low tip velocity
Orienting noise sources away from residents
Using acoustical pipe lagging
Installing VFDs on coolers
Performance Measurement
Conducting measurements and establishing baseline data
Using best practices as part of the company’s operating procedures
Visual
Change to visual environment None. Teck commits to implement the following mitigation measures to reduce changes to visual effects (see Volume 1, Section 8.3.6, Volume 3, Section 16.4.6, Volume 3, Section 18.10.4.2, Volume 3, Section 18.11.5.4 and Volume 3, Appendix 17H, Section 17H.7 of the Project Update):
Maintaining vegetated buffers between the Project and the Athabasca River as well as along Project transportation corridors to the extent feasible where safety concerns are not an issue.
Using construction materials that reduce contrast, limit visual attraction to Project features, and blending built structures into the natural surrounding environment.
Using construction materials, where practicable, that minimize light reflection, potentially reducing viewing distances of Project features
Reclamation techniques will be used that integrate closure plans with the surrounding landscape.
Teck will seek to develop closure plans that:
o Include integration and contouring of slopes that mimic natural topography.
o Focus on establishing a variety of vegetation communities.
o Avoid unnatural-looking breaks at development boundaries.
Planting a narrow band of white spruce along the edge of the river water intake (RWI) cofferdam and plant dogwood on the cofferdam, except in areas where tall vegetation would impede any maintenance or present safety concerns.
Completing reclamation in the RWI area to minimize erosion and slope instability.
Using lighting that minimizes light pollution.
At closure, infrastructure will be removed and the Project will be reclaimed using vegetation types similar, though not identical to existing conditions, creating a continuous vegetated landscape.
A lighting plan will be developed during future stages of engineering to avoid over-illumination. Lighting design will be part of future stages of engineering, and Teck will consult with interested Indigenous communities about lighting considerations.
Finish the Athabasca River Bridge with low-glare materials and plant vegetation buffers near the bridge. Teck also commits to clear minimal vegetation and to vegetate cleared areas.
Retain treed buffers around or near watercourses.
Fish and Fish Habitat
Change in productive fish habitat
None. Fish habitat of equivalent or higher productivity than that affected by the Project will be created through offsetting measures where prevention of adverse habitat alteration or loss (i.e., reduced habitat productivity or loss of productive habitat area) is not feasible (see the draft Detailed Fisheries Offsetting Plan, the response to JRP IR 2.1, Appendix 2.1).
Teck also commits to implement the following mitigation measures to avoid or reduce changes in fish habitat quantity or quality (see the response to JRP IR 2.1, Table 5):
To avoid or reduce sedimentation:
o Temporary and permanent erosion and sediment control measures for construction activities and disturbed areas.
o Stabilization and revegetation of disturbed areas.
o Isolation of instream work areas where they are required.
o Best management practices and regulatory guidelines for construction activities in and near watercourses/waterbodies for erosion and sediment control.
o Polishing ponds or other measures to reduce suspended sediment concentrations in discharge waters to avoid increases in sedimentation in the receiving environment.
o Appropriate design of constructed channels and ponds to reduce internal erosion and generation of suspended sediments.
o Appropriate design and construction of reclaimed landscape to reduce sediment yield.
To avoid or reduce changes to water quality:
o Passing muskeg drainage and overburden water through polishing ponds and drainage ditches to reduce changes in water temperatures and dissolved oxygen concentrations.
o Recycling of process affected waters during operations.
o Capture and recycling of ETA seepage and run off water during operations, and use of a passive seepage control system at closure.
o Use of wetlands, pit lakes and constructed reclamation lakes in the closure drainage system to provide biological remediation before release to the environment.
Frontier Oil Sands Mine Project Appendix 10.12
Table 10.12-6: Potential Adverse Environmental Effect and Mitigation Table – Fort McKay First Nation (continued)
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Potential Adverse Effects Mitigation Proposed by Fort McKay First Nation in TLU
Study and CIA Mitigation Teck Commits to Implement
o Removal of organic material from fish habitat compensation lake (FHCL) area prior to flooding.
To avoid or reduce changes to habitat area:
o Diversion of watercourses around the PDA to return natural upslope water back to the diverted watercourse to preserve flows and avoid elimination of downstream habitats.
o Provision of a flow splitter on the diversion channel that will collect water from both upper Redclay Creek and Unnamed Creek 17 to appropriately apportion the flows in lower Redclay Creek and Unnamed Creek 17 to avoid flow changes in the Ronald Lake watershed.
o Operation of the RWI and Off Stream Storage Pond (OSSP) in compliance with the Lower Athabasca River Surface Water Quantity Management Framework.
o Design of the closure drainage channels and pit lakes to provide habitats capable of supporting aquatic ecosystems.
o Best management practices and regulatory guidelines to ensure construction and operation of the RWI, Athabasca River bridge and watercourse crossings associated with access roads do not interfere with fish passage and access to available habitats.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Change in fish abundance None. Teck commits to implement the following mitigation measures to avoid or reduce changes in fish abundance (see the response to JRP IR 2.1, Table 5):
Fish rescue operations to capture and relocate fish prior to habitat dewatering.
Screening of the RWI in compliance with regulatory guidelines to mitigate fish entrainment or impingement.
Best management practices and regulatory guidelines for scheduling construction activities in and near waterbodies/watercourse to avoid sensitive time periods in adjacent or downstream fish-bearing watercourses.
Education of Project personnel on sustainable fishing practices to support a Teck applied prohibition on their fishing in watercourses or waterbodies in the PDA to mitigate potential increases in recreational fishing pressure.
Access Management Plan for the PDA to limit access to fish bearing habitats to mitigate increased fishing pressure.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Change in fish and fish habitat diversity
None. Teck commits to implement the following mitigation measures to avoid or reduce changes in fish and fish habitat diversity (see the response to JRP IR 2.1, Table 5):
Several of the measures intended to avoid or mitigate effects to fish habitat and fish abundance also apply to fish and fish habitat diversity, in cases where they preserve fish and productive fish habitats or create new habitats, including:
o Diversions designed to preserve flows and avoid elimination of downstream habitats.
o Closure drainage channels and pit lakes designed to provide habitats capable of supporting aquatic ecosystems.
o Fish rescue operations.
o Screening of the RWI.
o Education and prohibition of Project personnel from fishing in the PDA.
o Access Management for the PDA to limit access to fish bearing habitats.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Wildlife
Change in wildlife habitat availability Reclamation initiatives (Integral Ecology Group 2016, Section 8.5)
Teck commits to implement the following mitigation measures to reduce direct habitat loss (see the response to JRP IR 7.14, Table 7.14-1):
Limit the size of the east side access road right-of-way (ROW) and temporary workspace to the extent practical.
Limit the Athabasca River bridge footprint in riparian areas.
Carry out progressive reclamation to reclaim disturbed wildlife habitat as portions of the mine footprint become available.
Develop a weed management plan.
Teck commits to implement the following mitigation measures to reduce indirect habitat loss (see the response to JRP IR 7.14, Table 7.14-1):
Implement strategies to reduce noise and light effects, including design considerations (e.g., Frontier Project plant site engineering and aerodrome operation within regulatory and safety constraints).
Limiting employee and contractor access to identified areas of high-quality habitat adjacent to Project footprint.
Teck commits to developing a Biodiversity Management Plan (BMP) with the underlying goal of optimizing reclamation during operations to reduce offsetting of residual environmental effects (see the response to JRP IR 7.15).
Teck has developed a Draft Wildlife Mitigation, Monitoring and Adaptive Management Plan (WMMP; see the response to JRP IR 7.14, Appendix 7.14). Teck has proposed steps to Indigenous groups that would provide the opportunity for land users and community members to provide direct input into developing wildlife mitigation measures. Input will refine this draft WMMP. Once finalized, the plan will include a communication management section, which will outline how findings of the program will be communicated to interested parties.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Change in wildlife landscape connectivity Reclamation initiatives (Integral Ecology Group 2016, Section 8.5)
Teck commits to implement the following mitigation measures to reduce change to landscape connectivity (see the response to JRP IR 7.14, Table 7.14-1):
Carry out progressive reclamation to restore habitat for movement as portions of the mine footprint become available.
To maintain connectivity between Birch Mountains and Athabasca River:
o Coordinate development activities with Canadian Natural Resources Limited (CNRL) who acquired the Pierre River Mine oil sands leases formerly held by Shell Canada Limited should CNRL reapply for and develop the Pierre River Mine project.
o Develop an integrated land management strategy for the Project in consultation with industry, the province, Indigenous communities, and stakeholders.
Provide wildlife passage under both sides of the Athabasca River bridge and river water intake bridge to Dalkin Island to allow north–south wildlife movement along river banks using crossing design considerations (e.g., bridge height and length) outlined in Clevenger and Huijser (2011) and GOA (2011).
Set up educational signage to limit human use of wildlife underpasses.
Frontier Oil Sands Mine Project Appendix 10.12
Table 10.12-6: Potential Adverse Environmental Effect and Mitigation Table – Fort McKay First Nation (continued)
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Potential Adverse Effects Mitigation Proposed by Fort McKay First Nation in TLU
Study and CIA Mitigation Teck Commits to Implement
Evaluate wing fencing along the approach to crossing passages (at least 2.4 m high for large mammals as per GOA 2011) as part of the crossing structure design.
Provide appropriate walking substrate along the wildlife underpass.
Create vegetated buffers adjacent to wildlife underpasses to increase movement opportunities for a variety of species.
Provide coarse woody debris (e.g., stumps) along the wildlife underpass to provide cover and increase use by furbearers and other small mammals.
Teck has developed a Draft WMMP (see the response to JRP IR 7.14, Appendix 7.14). Teck has proposed steps to Indigenous groups that would provide the opportunity for land users and community members to provide direct input into developing wildlife mitigation measures. Input will refine this draft WMMP. Once finalized, the plan will include a communication management section, which will outline how findings of the program will be communicated to interested parties.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Change in wildlife mortality risk
None.
Teck commits to implement the following mitigation measures to reduce wildlife mortality risk resulting from vehicle–wildlife collisions (see the response to JRP IR 7.14, Table 7.14-1):
Implement fly-in/fly-out policy for workers to reduce vehicular traffic volume.
Erect wildlife cautionary signage on access roads.
Foster environmental awareness with speed restrictions on access roads report Project-related wildlife fatalities.
Provide vegetation maintenance at roadsides (vegetation will be trimmed regularly to discourage roadside foraging and prevent visual obstruction of wildlife).
Develop seed mixes for roadside reclamation from less palatable species to reduce wildlife attraction to road edges.
Design the road to maximize line of sight.
Remove road kill as soon as practical.
Teck commits to implement the following mitigation measures to reduce wildlife mortality risk resulting from wildlife interactions with equipment (see the response to JRP IR 7.14, Table 7.14-1):
Implement preconstruction surveys for active wildlife habitat features (e.g., nests, breeding wetlands) before starting early works.
Avoid vegetation clearing during the recommended May 1 to August 10 migratory bird-breeding period for the boreal ecozone per Environment Canada guidelines; note that in species at risk habitat, a more conservative breeding window of April 1 to August 31 might apply (Gregoire 2014, pers. comm.); complete nest surveys if clearing activities occur during the breeding window.
Conduct owl nest search if clearing is scheduled within the non-migratory breeding bird window, March 1 to April 15 (based on Enhanced Approval Process guidelines for barred owl, GOA 2013).
Reduce on disturbance of amphibian breeding and overwintering habitat (where possible).
Teck commits to implement the following mitigation measures to reduce wildlife mortality risk resulting from interactions with Infrastructure (see the response to JRP IR 7.14, Table 7.14-1):
Create fuel and chemical spill contingency and response plans.
Confirm adequate spill protection for all fuel storage facilities.
Monitor and maintain waste disposal sites, wastewater storage areas and runoff control structures to prevent surface water impacts.
During overburden dewatering, intermittently backslope the sides of drainage ditches to allow for wildlife crossings and to reduce the potential for entrapment.
Use visible markers, such as aviation spheres and spiral vibration dampeners to make transmission lines near waterfowl staging and potential stopover areas more visible to birds, and where possible, design transmission lines to match the height of surrounding trees to reduce wire strikes by birds.
Teck commits to implement the following mitigation measures to reduce wildlife mortality risk resulting from wildlife–human conflicts (see the response to JRP IR 7.14, Table 7.14-1):
Implement a food waste-management strategy to prevent attraction of nuisance wildlife.
Confirm wildlife is not harassed or fed (to prevent habituation).
Provide wildlife awareness training to Project staff and contractors to reduce disturbance and negative human/bear interactions.
Provide all field staff with bear-aware training courses, personal protective equipment (e.g., bear spray, bear bangers, air horns) and training on proper use of equipment.
Develop a nuisance wildlife mitigation and monitoring plan in cooperation with the regulators.
Teck commits to implement the following mitigation measures to reduce wildlife mortality risk resulting from increased hunter access (see the response to JRP IR 7.14, Table 7.14-1):
Implement deactivation plans for roads no longer in use.
Prohibit construction and operations personnel and contractors from hunting and trapping while working.
Disallow personal recreational vehicle use onsite.
Prohibit firearms on Project lands or at Project facilities.
Consider requesting a Directors Order to limit public access to the west side of the Athabasca River along Project roads.
Teck has developed a Draft WMMP (see the response to JRP IR 7.14, Appendix 7.14). Teck has proposed steps to Indigenous groups that would provide the opportunity for land users and community members to provide direct input into developing wildlife mitigation measures. Input will refine this draft WMMP. Once finalized, the plan will include a communication management section, which will outline how findings of the program will be communicated to interested parties.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Frontier Oil Sands Mine Project Appendix 10.12
Table 10.12-6: Potential Adverse Environmental Effect and Mitigation Table – Fort McKay First Nation (continued)
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Potential Adverse Effects Mitigation Proposed by Fort McKay First Nation in TLU
Study and CIA Mitigation Teck Commits to Implement
Waterfowl
Change in bird mortality risk
None.
Teck commits to implement the following mitigation measures to reduce migratory water bird mortality risk resulting from the use of ponds (see the response to JRP IR 7.10, Table 7.10-1):
Develop detailed construction and operational procedures and mitigation measures to reduce wildlife mortality during tailings area start-up.
Design the sides of wastewater ponds to reduce attractiveness to birds (e.g., using gravel for sides).
Clear trees and above-ground vegetation including shrubs, herbs and the ground layer prior to placement of tailings into tailings disposal areas.
Remove peat from tailings area prior to flooding.
Develop detailed construction and operational procedures and mitigation measures to reduce wildlife mortality during tailings area start-up.
Reduce attractiveness of tailings areas for birds by keeping the inner walls of the tailings dyke free of vegetation.
Keep slopes of tailings areas as steep as possible to reduce “black beach” areas.
Implement procedure for removing any peat mats that float to the surface of the tailings area.
Implement procedure for controlling floating bitumen mats.
Manage the use and operation of anthropogenic lighting around wastewater ponds and tailings areas.
Bird deterrent systems will be used to discourage birds from landing on wastewater ponds and tailings areas.
Teck commits to implement the following mitigation measure to reduce the potential for birds to land in ponds containing process-affected water (see the response to ESRD/CEAA Round 3 SIR 64):
Bird deterrent systems will be installed on all ponds associated with the Project that have process-affected water that could be detrimental to birds.
Teck commits to implement the following mitigation measures to maximize recovery efficiency should birds use ponds (see the response to JRP IR 7.10, Table 7.10-1):
Develop procedure for handling of any bird recovered from wastewater ponds or tailings areas.
Procedure will be in compliance with directions received from the local Alberta Fish and Wildlife office and/or the Alberta Environment and Parks (AEP) wildlife biologist.
Procedure will also be in compliance with directions from Environment and Climate Change Canada with respect to whooping cranes.
Teck commits to implement the following mitigation measures to reduce the potential for bird mortality risk resulting from interaction with transmission and distribution lines (see the response to JRP IR 7.10, Table 7.10-1):
Designing transmission and distribution lines, where possible, to match the height of surrounding trees to reduce wire strikes by birds.
Marking of transmission and distribution lines in areas near waterfowl staging and potential stopover areas.
Teck has developed a Draft Waterfowl Protection Plan (see the response to JRP IR 7.10, Appendix 7.10). Teck will continue to pursue collaborative engagement processes, as outlined in the WMMP for the Project as the primary mechanism in which it will engage with potentially affected Indigenous groups regarding the Waterfowl Protection Plan. Once finalized, the plan will include a communication management section, which will outline how findings of the program will be communicated to interested parties.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Bison
Change in bison habitat availability Reclamation initiatives (Integral Ecology Group 2016, Section 8.5)
Teck commits to implement the following mitigation measures to reduce direct habitat loss (see the response to JRP IR 7.5, Table 7.5-1):
Limit the size of the east side access road right-of-way (ROW) and temporary workspace to the extent practical.
Limit the Athabasca Rive bridge footprint in riparian areas.
Carry out progressive reclamation to reclaim disturbed wildlife habitat as portions of the mine footprint become available.
Develop a weed management plan.
Teck commits to implement the following mitigation measures to reduce indirect habitat loss (see the response to JRP IR 7.5, Table 7.5-1):
Implement strategies to reduce noise and light effects, including design considerations (e.g., Frontier Project plant site engineering and aerodrome operation within regulatory and safety constraints).
Limiting employee and contractor access to identified areas of high-quality habitat adjacent to Project footprint.
Teck has developed a Draft Ronald Lake Bison Mitigation, Monitoring and Adaptive Management Plan (see the response to JRP IR 7.5, Appendix 7.5). Teck has proposed steps to Indigenous groups that would provide the opportunity for land users and community members to provide direct input into developing wildlife mitigation measures, including those specific to bison. Once finalized, the plan will include a communication management section, which will outline how findings of the program will be communicated to interested parties.
Teck will also work with the responsible authority to explore possible mitigations for which Teck does not have the authority to implement independently.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Change in bison landscape connectivity Reclamation initiatives (Integral Ecology Group 2016, Section 8.5)
Teck commits to implement the following mitigation measures to reduce change to landscape connectivity (see the response to JRP IR 7.5, Table 7.5-1):
Carry out progressive reclamation to restore vegetated corridors as portions of the mine footprint become available.
To maintain connectivity between Birch Mountains and Athabasca River:
o Coordinate development activities with Canadian Natural Resources Limited (CNRL) who acquired the Pierre River Mine oil sands leases formerly held by Shell Canada Limited should CNRL reapply for and develop the Pierre River Mine project.
o Develop an integrated land management strategy for the Project in consultation with industry, Indigenous stakeholders and the Province.
Provide wildlife passage under both sides of the Athabasca River bridge and river water intake bridge to Dalkin Island to allow north–south wildlife movement along river banks using crossing design considerations (e.g., bridge height and length) outlined in Clevenger and Huijser (2011) and GOA (2011):
o Set up educational signage to limit human use of wildlife underpasses.
o Evaluate wing fencing along the approach to crossing passages (at least 2.4 m high for large mammals as per GOA 2011) as part of the crossing structure design.
Frontier Oil Sands Mine Project Appendix 10.12
Table 10.12-6: Potential Adverse Environmental Effect and Mitigation Table – Fort McKay First Nation (continued)
Teck Resources Limited Page 36
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Potential Adverse Effects Mitigation Proposed by Fort McKay First Nation in TLU
Study and CIA Mitigation Teck Commits to Implement
o Provide appropriate walking substrate along the wildlife underpass.
o Create vegetated buffers adjacent to wildlife underpasses to increase movement opportunities for a variety of species.
Teck has developed a Draft Ronald Lake Bison Mitigation, Monitoring and Adaptive Management Plan (see the response to JRP IR 7.5, Appendix 7.5). Teck has proposed steps to Indigenous groups that would provide the opportunity for land users and community members to provide direct input into developing wildlife mitigation measures, including those specific to bison. Once finalized, the plan will include a communication management section, which will outline how findings of the program will be communicated to interested parties.
Teck will also work with the responsible authority to explore possible mitigations for which Teck does not have the authority to implement independently.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Change in bison mortality risk
None.
Teck commits to implement the following mitigation measures to reduce bison mortality risk resulting from vehicle–bison collisions (see the response to JRP IR 7.5, Table 7.5-1):
Implement fly-in/fly-out policy for workers to reduce vehicular traffic volume.
Erect wildlife cautionary signage on access roads.
Foster environmental awareness with speed restrictions on access roads, report Project-related wildlife fatalities.
Provide vegetation maintenance at roadsides (vegetation will be trimmed regularly to discourage roadside foraging and prevent visual obstruction of wildlife).
Develop seed mixes for roadside reclamation from less palatable species to reduce wildlife attraction to road edges.
Design the road to maximize line of sight.
Teck commits to implement the following mitigation measures to reduce bison mortality risk resulting from bison-human interactions - interactions with infrastructure (see the response to JRP IR 7.5, Table 7.5-1):
Create fuel and chemical spill contingency and response plans.
Confirm adequate spill protection for all fuel storage facilities.
Monitor and maintain waste disposal sites, wastewater storage areas and runoff control structures to prevent contamination of surface waters.
During overburden dewatering, intermittently backslope the sides of drainage ditches to allow for wildlife crossings and to reduce the potential for entrapment.
Teck commits to implement the following mitigation measures to reduce bison mortality risk resulting from hunter access (see the response to JRP IR 7.5, Table 7.5-1):
Construct predator access blocks to deter predator use (i.e., reduce line of sight) on linear features in the PDA that may leave core bison areas susceptible to predation.
Deactivate roads in the PDA no longer in use.
Implement employee / contractor policies to prohibit hunting within the Project area.
Reduce linear features in the closure landscape.
Reduce width of linear features in the closure landscape.
Teck commits to implement the following mitigation measures to reduce bison mortality risk resulting from disease transmission to the Ronald Lake bison herd (see the response to JRP IR 7.5, Table 7.5-1):
Implement progressive reclamation in the PDA to create suitable Ronald Lake bison habitat and reduce the potential of shifting habitat use northward.
Mitigations associated with reducing hunter and predator access.
Mitigations associated with reducing wildlife human conflict.
Mitigations associated with reducing indirect habitat loss.
Teck has developed a Draft Ronald Lake Bison Mitigation, Monitoring and Adaptive Management Plan (see the response to JRP IR 7.5, Appendix 7.5). Teck has proposed steps to Indigenous groups that would provide the opportunity for land users and community members to provide direct input into developing wildlife mitigation measures, including those specific to bison. Once finalized, the plan will include a communication management section, which will outline how findings of the program will be communicated to interested parties.
Teck will also work with the responsible authority to explore possible mitigations for which Teck does not have the authority to implement independently.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Vegetation
Change in vegetation
Reclamation initiatives (Integral Ecology Group 2016, Section 8.5)
Teck is committed to continue working with potentially affected Indigenous groups to refine the closure, conservation and reclamation (CC&R) plan through the life of the Project and to incorporate input from Indigenous groups on reclamation monitoring and thresholds and document the establishment of traditional use vegetation in the reclaimed landscape. Teck plans to co-create Reclamation Working Group(s) with potentially affected Indigenous groups to seek input to the Project’s reclamation plan and measures and targets to determine its success. It anticipates that species of traditional importance will be identified by Reclamation Working Group(s) and incorporated into reclamation planning as feasible. In addition, collaborative participation is planned in reclamation research both from a Project and regional perspective. Results of this research will be incorporated into future Project plans (see the response to JRP IR 6.9, Section 4.2).
Teck also commits to implement the following mitigation measures to reduce change in vegetation (see Volume 3, Appendix 17H, Section 17H.4 of the Project Update; response to JRP IRs 6.8 and 6.10):
Reclamation of the closure landscape will focus on generating a sustainable landscape that is designed to maximize diversity through the generation of landforms that include:
o topographic diversity and associated diversity in moisture regimes
o aspect diversity
o substrate diversity including both fine- and coarse- grained landforms
o mesotopography
Removal of existing linear disturbances that are currently fragmenting the landscape.
Mitigation to reduce effects on community diversity will focus on research results and strategies as summarized in:
o Guidelines for Reclamation to Forest Vegetation in the Athabasca Oil Sands Region (2nd Edition) (ESRD 2010)
Frontier Oil Sands Mine Project Appendix 10.12
Table 10.12-6: Potential Adverse Environmental Effect and Mitigation Table – Fort McKay First Nation (continued)
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Potential Adverse Effects Mitigation Proposed by Fort McKay First Nation in TLU
Study and CIA Mitigation Teck Commits to Implement
o Guideline for Wetland Establishment on Reclaimed Oil Sands Leases (3rd Edition) (CEMA 2014)
o Oil Sands Marshes: A Knowledge Transfer (Charette et al. 2012)
o Best Management Practices for Conservation of Reclamation Materials in the Mineable Oil Sands Region of Alberta (MacKenzie 2011)
o Restoration and Reclamation of Boreal Ecosystems: Attaining Sustainable Development (Vitt and Bhatti 2012)
o Riparian Classification and Reclamation Guide, Revised Edition (Mihajlovich 2012)
Include peatlands in detailed CC&R planning should research results and recommendations prove to be feasible and appropriate.
Work with the governments of Alberta and Canada and look to their guidance on the development of a Conservation Agreement.
Plant additional species on the reclamation landscape, including those with traditional value, to supplement those recommended in provincial reclamation guidelines.
Mitigation for rare plant species will be achieved through avoidance whenever possible. In areas where avoidance is not possible, alternate mitigation strategies will be developed to promote conservation of these species and associated genetic diversity.
A weed management plan will be implemented throughout the life of the Project including during reclamation and at closure.
Develop and implement a program to salvage and relocate known occurrences of rare (vascular) plant species to areas outside of the Project area in consultation with Indigenous communities.
Incorporate species of traditional important as identified through the Reclamation Working Group(s) into reclamation planning, as feasible.
Engage Indigenous communities in preparing plans to harvest and collect seeds, and will invite community members to harvest and collect seeds of rare and culturally important species before disturbance, for use in reproducing the species and revegetation of the Project area.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures related to reclamation and evaluate monitoring results to determine if adaptations are warranted.
Historical Resources
Changes to historical resources within the Project disturbance area
None. Teck commits to implement the following mitigation measures regarding changes to historical resources within the Project disturbance area (see Volume 3, Appendix 17H, Section 17H.9 of the Project Update):
Historical resources sites in the PDA that Alberta Culture and Tourism (ACT) determines to have moderate to high heritage value will likely have requirements for further study. These might include some or all of the following:
o Additional shovel testing to identify site boundaries, areas of highest artifact density, activity areas and areas with unique or specialized artifacts.
o Archaeological excavation at sites with high interpretive potential.
o Mapping and documentation at specific sites.
Teck will phase the required supplemental historic resources impact assessment (HRIA) studies to ensure completion of all necessary studies in the PDA in advance of vegetation clearing in each development area.
Teck will also work collaboratively with local First Nation and Aboriginal communities on mitigation studies, in an effort to address local concerns and interests in relation to historical resources in the area.
Socio-economics
Change to housing needs None. Teck commits to implement the following mitigation measures regarding housing needs (see the response to JRP IR 5.14(a), Table 5.15a-1):
Provide on-site, lodge-based accommodations during construction and operations to reduce the Project’s effect on the resident population and associated effects on social infrastructure and housing in the region.
Offer lodge amenities and services – including individual rooms and shared spaces, the quality of the food services and free-time activities – that are competitive with other lodge accommodations in the region.
Change to social infrastructure needs
Cultural strategy (Integral Ecology Group 2016, Section 8.1)
Teck commits to implement the following mitigation measures regarding social infrastructure needs (see the response to JRP IR 5.14(a), Table 5.15a-2):
Maintain explicit and enforced lodge, workplace and flight policies with regards to the use of alcohol, drugs and illegal activities.
Provide onsite security services, including controlled gates, check-in procedures, perimeter security fencing and lodge-based security officers on duty 24 hours.
Offer in-house security services to assist the Royal Canadian Mounted Police (RCMP) within, and sometimes outside, the Project lease boundaries (e.g., securing accident scenes and assisting with highway closures).
Develop and implement an emergency response plan which includes the required personnel, procedures and equipment resources (e.g., vehicles, fire response, medical response and rescue).
Develop required mitigation measures for areas adjacent to the Project area based on the FireSmart Wildfire Assessment System and implement in the emergency response plan.
Enter into mutual aid agreements with the Regional Municipality of Wood Buffalo (RMWB) and other oil sands companies that include:
o responding to motor vehicle accidents on Highway #63
o responding to forest fire threats to Fort McKay
o responding to regional spills
Participate in the management of regional emergencies at the RMWB’s Regional Emergency Operations Centre.
Make available onsite health services, including an on-site medical facility staffed by qualified health professionals providing 24-hour on-site primary, emergency and occupational health services.
Consider financial and in-kind contributions to the Northern Lights Health Foundation, where appropriate, to support the efforts of Alberta Health Services to meet the needs of Wood Buffalo residents. Recognizing some of the health concerns in the region Teck is prepared to make health promotion and disease prevention initiatives a focus of their community investment policy.
Provide helicopter or fixed-wing aircraft access via the on-site aerodrome for injured workers requiring rapid evacuation for off-site medical care.
Discuss with other industrial proponents near the Project options for coordinating on-site health facilities and resources.
Assess and support school events and education initiatives identified by rural schools in the study area, as appropriate.
Provide employees with access to the company’s confidential Employee and Family Assistance Plan, which provides support for families and individuals who might experience difficulty dealing with personal, family or work-life issues that can affect one’s health and well-being.
Consider support for community level initiatives including social groups providing assistance to those in need.
Continue providing direct support to community initiatives through its social investment programs.
Offer shift schedules that provide workers with sufficient time off to enjoy leisure activities in their home communities.
Make available onsite recreational opportunities and facilities.
Frontier Oil Sands Mine Project Appendix 10.12
Table 10.12-6: Potential Adverse Environmental Effect and Mitigation Table – Fort McKay First Nation (continued)
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Potential Adverse Effects Mitigation Proposed by Fort McKay First Nation in TLU
Study and CIA Mitigation Teck Commits to Implement
Change to transportation needs
None. Teck commits to implement the following mitigation measures regarding transportation needs (see the response to JRP IR 5.14(a), Table 5.14a-3):
Construct and operate an aerodrome near the Project site.
Use on-site as well as regional lodge accommodations during both construction and operations to reduce worker commutes.
Use bus service for transporting construction and operations workers.
Limit private vehicles brought to the Project site.
Schedule truck traffic, including oversized loads, to off-peak hours.
Use an on-site concrete batch plant; and attempt to source aggregates from pits near to site.
Enforce lodge, workplace and flight policies with regards to the use of alcohol, drugs and illegal activities.
Work with the local RCMP to confirm communication on local effects.
Support the efforts of RMWB and Oil Sands Community Alliance (OSCA) to work with the provincial government to progress improvements to highway infrastructure in a timely way.
Keep responsible regional and provincial planners informed of the Project’s development plans and their timing.
Consult and cooperate with other operators regarding shift scheduling with a view to reduce overlap in commuter traffic.
Provide funding to assist in the maintenance and safety of applicable segments of Highway #63 from Fort McKay to Fort Chipewyan that are affected by the Project.
Change to municipal infrastructure needs None. Teck commits to implement the following mitigation measures regarding municipal infrastructure (see the response to JRP IR 5.14(a), Table 5.14a-4):
Provide water and sewer services for the different mining areas and the associated processing facilities and infrastructure, including on-site lodges.
Teck commits to implement the following mitigation measures regarding choice of fly-in/fly-out (FIFO) (see the response to JRP IR 5.14(a), Table 5.14a-6):
A FIFO lodge-based approach to construction and operations.
Ongoing monitoring of the operations FIFO model and revisiting the approach should local circumstances change.
Teck’s monitoring will take into consideration input received via its workers, contractors and ongoing local stakeholder and Indigenous engagement process. This would likely include feedback with respect to the social and economic effects of the FIFO model on individual workers, their families and communities.
Commitment to include Fort Chipewyan in a FIFO program.
Engage with potential employees living in Fort Chipewyan to discuss shift schedules and other travel and lodging logistics that influence their choice to work at the Project versus other opportunities.
Discuss with local communities the design of FIFO shifts that best benefit its employees and families while remaining logistically and financially feasible.
Remain open to engaging in broader, regional initiatives, for example through the OSCA and its study of the use of aerodromes in the region.
Change to employment, business and training opportunity needs
None. Teck commits to implement the following mitigation measures regarding employment, business and training opportunity needs (see the response to JRP IR 5.14(a), Table 5.14a-5):
Specific contractual commitments to Indigenous communities on employment, business and training opportunities will be made within Participation Agreements negotiated between Teck and the Indigenous community.
Prioritize recruiting residents from the region first, Alberta second, followed by the rest of Canada, then North America and then overseas countries.
Draw on various sources of labour in Canada that are traditionally under-represented in the labour market, including Indigenous people, immigrants and women.
Put in place a policy to hire local businesses and contractors that are competitive and able to meet the company’s needs is already in place.
Teck will consult with Indigenous communities regarding procurement and employment initiatives such as:
o Establishing mechanisms to enhance employment prospects of local residents, including preferential consideration.
o Using procurement processes that regard local ownership and prevalence of workers residing locally as positive criteria in goods and services vendor selection competitions.
o Establishing monitoring programs that measure local involvement, gather feedback and work with interested parties on how to improve results.
Implement Teck’s relevant charters, codes and policies, including its Indigenous Peoples Policy, when working with Indigenous peoples in seeking to develop lasting mutual benefits that respect Indigenous community’s values – including hiring, training and retention of Indigenous employees.
Utilize what Teck’s has learned to date from local Indigenous communities with which it is engaged for the Project to overcome oil sands specific challenges to Indigenous employment and procurement.
Consider work experience in lieu of a high school graduation for Indigenous peoples.
Work with the Fort McMurray Chamber of Commerce, the Northeastern Alberta Aboriginal Business Association (NAABA) and others to maximize contracting and employment opportunities in the region.
Offer a choice of worker turnaround cycles and opportunity to earn premium pay through overtime.
Continue to work with the Indigenous communities in the area and specifically with the communities of Fort McKay and Fort Chipewyan to develop Indigenous employment and business development program(s) guided by a commitment to: maximize opportunities for local Indigenous businesses to supply services and products in support of Project construction and operations; hire qualified Indigenous people from the communities surrounding the Project and support education, training and investment initiatives in local Indigenous communities, where appropriate.
Teck’s Indigenous community employment and business development program(s) will engage with Indigenous communities on establishing employment and procurement policies and procedures, as well as adaptive management mechanisms specific to Indigenous community employment and procurement.
Teck’s Indigenous community employment and business development program(s), as well as community-specific Participation Agreements will take into consideration input provided by local Indigenous communities, and will be guided by a commitment to: develop substantial opportunities for local Indigenous businesses to supply services and products in support of Project construction and operations; hire qualified Indigenous people from the communities surrounding the Project and support education, training and investment initiatives in local Indigenous communities, where appropriate.
Continuously monitor Teck’s local employment and procurement policies and programs, along with reporting the results of this monitoring as part of ongoing community consultation.
Teck has yet to determine the exact reporting and monitoring mechanisms for its local procurement and employment policies, but will engage with Indigenous communities on mechanisms and expects they will likely be similar to mechanisms used by Teck’s other operations. These might include:
o Total employment, attraction and retention rates, average salary levels and other general human resource data. Where possible, the data will be disaggregated at the local community level.
o Procurement activity, including examination of goods and services sourced from providers in local communities, value and length of contracts, types of goods and services provided and employment and enterprise effects associated with procurement.
Frontier Oil Sands Mine Project Appendix 10.12
Table 10.12-6: Potential Adverse Environmental Effect and Mitigation Table – Fort McKay First Nation (continued)
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Potential Adverse Effects Mitigation Proposed by Fort McKay First Nation in TLU
Study and CIA Mitigation Teck Commits to Implement
o Additional potential mechanisms are identified in Teck’s draft socio-economic monitoring plan in response to JRP IR 5.15(a).
Continue supporting local labour force skills development, and work with communities, government and other industrial proponents on programs that assist community members overcome labour market barriers.
Change to culture
Cultural strategy (Integral Ecology Group 2016, Section 8.1)
Continued monitoring of culture (Integral Ecology Group 2016, Section 8.2)
Language retention initiatives (Integral
Ecology Group 2016, Section 8.3)
Teck commits to implement the following mitigation measures regarding changes to culture (see the response to JRP IR 5.14(a), Tables 5-14a-6 and 5.14a-7):
Continue to expand Teck’s knowledge of, and engagement with, local stakeholders and Indigenous communities near the Project to confirm ongoing and growing participation in Project-related benefits, as well as the design of appropriate and effective mitigation measures to reduce any adverse effect. These efforts are envisioned to include capacity building support within Participation Agreements for Indigenous communities.
Provide cultural diversity awareness training to employees and contractors, focusing on respect for traditional land users as well as respect for Indigenous world views, customs and values.
Consider supportive workplace practices as Teck develops workplace policies and seek local Indigenous community input into cultural awareness programming to be provided at the Project site.
Carry out a review of Teck’s standard bereavement policy, including a review of policies from other fly in/fly out operations in Alberta, as operation specific policies are developed during future planning phases.
Continuing to provide cultural awareness training for all Project staff and contractors.
Considering key Indigenous access routes and access preferences in the Project’s draft Access Management Plan (AMP).
Considering cultural keystone species in the wildlife management and mitigation plan, FHCL and biodiversity management plan.
Incorporating and using Indigenous place names where applicable.
Supporting community-led projects to document Indigenous place names in their respective traditional territories.
Contributing to language retention programs and other programs that support retaining Indigenous culture, knowledge and practice (e.g., culture camps for youth).
Discuss with local communities the design of fly in/fly out shifts that best benefit its employees and families while remaining logistically and financially feasible.
Access
Change to access near the Project disturbance area
None. Teck has developed a draft access management plan (AMP) for the Project to facilitate access to or through Teck’s mineral surface lease to the extent possible while maintaining worker and public safety (see the response to JRP 4.5, Appendix 4.5). Teck has proposed next steps to Indigenous groups that would provide the opportunity for land users and community members to provide direct input into developing access mitigation measures. This input will refine the draft AMP.
Teck commits to implement the following mitigation measures to reduce potential effects on changes to access near the Project disturbance area (see Volume 3, Appendix 17H, Section 17H.8.2 of the Project Update) and the response to JRP IR 10.9):
All individuals wanting to gain access to or through lands being actively developed, which is generally Teck’s mineral surface lease (MSL), will be required to submit an access request.
Traditional land users will be granted temporary access to and through the PDA according to the policy and processes set out in the AMP.
Traditional land users will not have to meet worker site access requirements but will be escorted by someone who has permanent site access (i.e., a worker).
Access through, and to portions of the PDA not being actively developed will not require an access request form be submitted. Individuals will be required to contact the site’s security office and provide adequate notice about when they plan to be in the area, who will be present, and the intended activities and general location(s) as they relate to Teck leases. All individuals passing through the PDA will have to check in at the security office and will be escorted by a Teck worker. Teck understands that Aboriginal communities desire that the advance notice period.
Throughout the life of the mine, access to locations in the PDA by Aboriginal community members will be based on mine advance. For safety reasons, harvesting and use of firearms would not be permitted in areas being actively mined or within and around facilities associated with the mine.
The River Road will be maintained through operations and will provide access to the Fish Habitat Compensation Lake, aerodrome, and areas north of the PDA.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Traditional Land Use
Change in availability of resources (wildlife, fish and vegetation), culturally important sites or areas for traditional activities and use of lands
Cultural strategy (Integral Ecology Group 2016, Section 8.1)
Continued monitoring of culture (Integral Ecology Group 2016, Section 8.2)
Language retention initiatives (Integral
Ecology Group 2016, Section 8.3)
Teck commits to implement the following mitigation measures to reduce changes in availability of resources (wildlife, fish and vegetation), culturally important sites or areas for traditional activities and use of lands (assessed in Volume 3, Section 17.6 of the Project Update) (see the response to JRP IR 4.6, Table 4.6-1):
Grant traditional land users temporary access to and through the PDA according to the policy and processes set out in the draft access management plan.
Implement measures to mitigate Project-related effects on wildlife through the wildlife monitoring and mitigation plan.
Engage Indigenous communities in the development of a biodiversity management plan.
Implement measures to mitigate Project-related effects on fish and fish habitat through the detailed fisheries offsetting plan.
Implement measures to reduce Project-related effects on vegetation through the conservation closure and reclamation plan and the reclamation monitoring plan.
Historical resources sites in the PDA that Alberta Culture and Tourism (ACT) determines to have moderate to high heritage value will meet the requirements of ACT and aim to meet the desires of Indigenous communities.
Teck commits to implement the following mitigation measures to reduce effects on the land use experience for traditional land users (see the response to JRP IR 4.6, Table 4.6-1):
Establish Participation Agreements with Indigenous communities.
Invite traditional users to harvest traditional plants before disturbance.
Support the planning and implementation of an excursion for Indigenous communities within the terrestrial local study area prior to Project-related disturbance to describe Indigenous values, access and to recommend mitigation to avoid or limit effects on Indigenous access values.
Provide cultural diversity awareness training to employees and contractors focusing on respect for Indigenous land users, traplines, cabins, trails and equipment, as well as respect for Indigenous world views, customs and values.
Compensate Indigenous trappers following industry-community standards and the Alberta Trappers Compensation Program.
Project personnel will be prohibited from fishing, hunting and trapping within the PDA during work rotations, which is when Teck’s policies’ can be enforced.
Project personnel will be prohibited from using personal recreation vehicles within the PDA.
Investigate with potentially affected Indigenous communities through the Reclamation Working Group the concept of incorporating cultural values into reclamation planning.
Frontier Oil Sands Mine Project Appendix 10.12
Table 10.12-6: Potential Adverse Environmental Effect and Mitigation Table – Fort McKay First Nation (continued)
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Potential Adverse Effects Mitigation Proposed by Fort McKay First Nation in TLU
Study and CIA Mitigation Teck Commits to Implement
Supporting documentation of community-specific cultural heritage.
Teck has developed a Draft Traditional Land Use Mitigation, Monitoring and Adaptive Management Plan (see the response to JRP IR 4.6, Appendix 4.6). Teck will continue to seek input and engage with Indigenous groups, as well as regulators where appropriate, as part of finalizing this plan. Once finalized, Teck will continue to pursue collaborative engagement processes with Indigenous groups as outlined in the plan. Through these collaborative engagement processes Teck will aim to minimize and mitigate potential Project effects on traditional land use. Once finalized, the plan will include a communication management section, which will outline how findings of the program will be communicated to interested parties.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Notes:
NOx = oxides of nitrogen; SO2 = sulphur dioxide; PM2.5 = particulate matter
Frontier Oil Sands Mine Project Appendix 10.12
Teck Resources Limited Page 41
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4 Fort McKay Métis
A summary of established or asserted Aboriginal rights, current use of lands and resources for traditional
purposes and cultural and physical heritage features as described by Fort McKay Métis is presented in
Table 10.12-7.
Table 10.12-7: Fort McKay Métis Rights, Land Uses and Cultural and Physical Heritage Features
Established or Asserted Aboriginal Rights, Current Use of Lands and Resources for Traditional Purposes
Cultural and Physical Heritage Feature
Hunting
Hunting food in all seasons
Fishing
Trapping
Plant harvesting
Commercial harvest for RFMA holders
Pursue way of life
Use, enjoyment and control of lands
Livelihood from traditional lands
Sufficient lands and access to them of a quality and nature sufficient to support meaningful experience
Site-specific cultural practices and features
Hunting
Fishing
Trapping
Services for Métis
Commerce work
Getting together
Storytelling
Spiritual activities
Gathering
Potential adverse Project effects on Fort McKay Métis’ established or asserted Aboriginal rights, current
use of lands and resources for traditional purposes or cultural and physical heritage are presented in
Table 10.12-8, along with mitigation proposed by Fort McKay Métis in their Traditional Land Use study
(Fort McKay and Integral Ecology Group 2011) and CIA (Human Environment Group 2016), and
mitigation that Teck has committed to implement to reduce these potential effects.
The mitigation proposed by Fort McKay Métis in their TLU study and CIA may not be reflected, as
articulated by Fort McKay Métis, in the mitigation measures outlined in Table 10.12-8, for one or more of
the following reasons:
The mitigation measure proposed by Fort McKay Métis is directly or indirectly reflected in one or
more mitigation measures outlined by Teck.
The mitigation measure proposed by Fort McKay Métis is beyond the scope of what a single
proponent can mitigate.
The mitigation measure proposed by Fort McKay Métis is within the scope of ongoing
environmental stewardship planning and implementation activities that Teck and Fort McKay
Métis will undertake as part of implementing a Participation Agreement (discussed below).
In 2016 Teck and Fort McKay Métis entered into a Participation Agreement for the Project, pursuant to
which Fort McKay Métis and Teck have jointly committed to significant ongoing efforts on critical areas of
importance to Fort McKay Métis and its members throughout planning, construction, operation and
reclamation of the Project. The joint efforts of Fort McKay Métis and Teck include ongoing mitigation,
monitoring and management of Project impacts to the environment and Fort McKay Métis traditional use
and rights, identification of contracting and employment opportunities, and provision of direct financial
benefits to Fort McKay Métis.
Frontier Oil Sands Mine Project Appendix 10.12
Teck Resources Limited Page 42
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Table 10.12-8: Potential Adverse Environmental Effect and Mitigation Table – Fort McKay Métis
Potential Adverse Effects Mitigation Proposed by Fort McKay Métis in
TLU Study and CIA Mitigation Teck Commits to Implement
Hydrology and Water Quality
Changes in flows, water levels and open water areas
Diverted streams not be used in the off-stream storage pond in the Unnamed Creek 2 valley (HEG 2016, Section 16.3.1, Numbers 39 and 42)
Only Athabasca River water be used for water supply (HEG 2016, Section 16.3.1, Number 40)
The Athabasca River will satisfy the Project’s makeup water requirements, and an off-stream storage pond (OSSP) will supply the Project with water during periods when river water withdrawal is restricted (see the response to Joint Review Panel (JRP) Information Request (IR) 10.26, Appendix 10.26, Section 7.1).
Teck commits to implement the following mitigation measures to reduce changes in flows and water levels in receiving waterbodies (see the response to JRP IR 10.25, Appendix 10.25, Table 10.25-1):
Reduce changes to flows in Ronald Lake by using a flow splitter on the Redclay Creek diversion during operations.
Reduce changes to flows in Big Creek by using a flow splitter on the Big Creek diversion during operations.
Distribute muskeg drainage operations through the mine life, thereby avoiding a large increase in flows in the receiving waters.
Reduce effects of closed-circuit operations on flows and water levels in receiving waters by diverting natural watercourses that will not be disturbed by the mining operations around the mining area to receiving watercourses.
Reduce river-water withdrawal requirements from the Athabasca River by maximizing closed-circuit recycling of surface and groundwater where practical, and by storing sufficient amounts of water in an off-stream storage pond in the event of extended withdrawal restrictions from the Athabasca River.
Progressively construct and develop diversion systems, which helps limit the change in open-water areas during construction and operation by providing new drainage channels to replace the loss of natural watercourses and waterbodies.
Reduce changes to flows and water levels in receiving waters by developing a closure drainage layout that will limit changes in drainage areas contributing flows to the receiving watercourses relative to predevelopment conditions.
Design watercourses, waterbodies and wetlands during reclamation to attenuate floods.
Teck is committed to continue to consult meaningfully with, and engage, all potentially affected Indigenous groups at both a Project-specific and regional level to reduce and mitigate potential Project and cumulative effects on hydrology and surface water quality, including continuing discussions regarding hydrology and surface water quality concerns and is prepared to consider additional mitigation measures to address these concerns (see the response to JRP IR 10.25, Appendix 10.25).
Teck has developed a Draft Hydrology and Water Quality Mitigation, Monitoring and Adaptive Management Plan (see the response to JRP IR 10.25, Appendix 10.25). Once finalized, the plan will include a communication management section, which will outline how findings of the program will be communicated to interested parties.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Changes in sediment yields, concentrations and channel regimes (geomorphology)
None. Teck commits to implement the following mitigation measures to limit release of Total Suspended Solids (TSS) (see the response to JRP IR 10.25, Appendix 10.25, Table 10.25-1):
Follow relevant regulatory guidelines, standards and best management practices during construction and operation to reduce the risk of increased sediment loadings to receiving watercourses.
Construct and operate sedimentation ponds to settle TSS where necessary.
Control sediment generation in diversion channels through revegetation of streambanks, overbank areas and berms as soon as possible after construction and by the use of channel armour (riprap), where required.
Direct muskeg and overburden drainage waters to polishing ponds equipped with oil-separation capability.
Reduce sediment yields from reclaimed surfaces by developing appropriate final topography and soil moisture conditions.
Resuspension of sediments from the bottom of polishing ponds, wetlands and pit lakes will be reduced through appropriate hydraulic design.
Reduce gullying and channel erosion by developing robust and sustainable reclamation drainage systems with built-in self-healing capability and robustness similar to natural drainage systems.
Teck commits to implement the following mitigation measures to reduce changes in flood flows and geomorphology downstream of the Project (see the response to JRP IR 10.25, Appendix 10.25, Table 10.25-1):
Limit changes in flood flows in receiving watercourses relative to predevelopment conditions. Mitigation measures listed for the “reduce changes in flows and water levels” above are relevant for mitigating flood flows.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Direct water emissions:
Muskeg drainage and overburden dewatering flows
Drainage from operating and reclaimed mine site
Basal water sands depressurization
Process-affected seepages from backfilled mine pits and tailings disposal areas
None. Teck commits to implement the following mitigation measures to limit the release of ions, nutrients, metals, polycyclic aromatic hydrocarbons (PAHs) and other parameters during operations and closure and protect sediment quality in downstream watercourses and waterbodies (see the response to JRP IR 10.25, Appendix 10.25, Table 10.25-1):
Recycle process-affected waters and runoff within the Project disturbance area (PDA) in a closed-circuit system during operations.
Using a perimeter ditch and groundwater wells to capture and pump back seepages and runoff from the external tailings areas (ETAs) back into the tailings areas during operations.
Design the closure drainage system to capture seepage and runoff from ETAs, external disposal areas (EDAs) and the Frontier Project plant site and directing it to wetlands, pit lakes or constructed reclamation lakes during the mine closure management phase.
Use wetlands, constructed reclamation lakes and pit lakes during and after the decommissioning and closure phases to provide biological remediation and settling of particulate materials in reclamation waters before discharge.
Respond to spills using best management practices. Project activities will follow safety protocols designed to limit accidents and reduce effects if an accident should occur.
Teck commits to the following mitigation measures to manage depressurization water during preproduction (see Volume 1, Section 7.6.5 and 7.8.4 of the Project Update):
Teck plans to manage depressurization water during preproduction by storing approximately half of it in a storage pond at surface and reinjecting the remaining half into the BWS aquifer.
Teck is committed to continue to consult meaningfully with, and engage, all potentially affected Indigenous groups at both a Project-specific and regional level to reduce and mitigate potential Project and cumulative effects on hydrology and surface water quality, including continuing discussions regarding hydrology and surface water quality concerns and is prepared to consider additional mitigation measures to address these concerns (see the response to JRP IR 10.25, Appendix 10.25).
Teck has developed a Draft Hydrology and Water Quality Mitigation, Monitoring and Adaptive Management Plan (see the response to JRP IR 10.25, Appendix 10.25). Once finalized, the plan will include a communication management section, which will outline how findings of the program will be communicated to interested parties.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Pit lake releases Participation in pit lake research (HEG 2016, Section 16.3.1, Number 23)
Teck will leverage the knowledge gained through its other reclamation efforts, along with research through regional initiatives such as Canada’s Oil Sands Innovation Alliance (COSIA), to develop healthy, functional ecosystems in the Project pit lakes (see the response to JRP IR 2.3).
Frontier Oil Sands Mine Project Appendix 10.12
Table 10.12-8: Potential Adverse Environmental Effect and Mitigation Table – Fort McKay Métis (continued)
Teck Resources Limited Page 43
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Potential Adverse Effects Mitigation Proposed by Fort McKay Métis in
TLU Study and CIA Mitigation Teck Commits to Implement
Teck also commits to implement the following mitigation measures when designing closure drainage and pit lakes for hydrological sustainability and to promote effective passive treatment of process-affected waters and to support a viable aquatic ecosystem prior to release and to sequester tailings and other mine waste in the most appropriate location at mine closure (see the response to JRP IR 10.25, Appendix 10.25, Table 10.25-1):
Exclude tailings from pit lakes.
Do not release water from pit lakes until acceptable quality is achieved.
Maintain the water balance of the pit lakes with sufficient inflows to compensate for evaporative losses.
Manage the rate of Athabasca River water input to pit lakes as appropriate to confirm water quality filling targets are met and to comply with Athabasca river low flow restrictions.
Include wetlands reclamation lakes for treatment purposes in reclamation drainages to the pit lakes.
Teck is committed to continue to consult meaningfully with, and engage, all potentially affected Indigenous groups at both a Project-specific and regional level to reduce and mitigate potential Project and cumulative effects on hydrology and surface water quality, including continuing discussions regarding hydrology and surface water quality concerns and is prepared to consider additional mitigation measures to address these concerns (see the response to JRP IR 10.25, Appendix 10.25).
Teck has developed a Draft Hydrology and Water Quality Mitigation, Monitoring and Adaptive Management Plan (see the response to JRP IR 10.25, Appendix 10.25). Once finalized, the plan will include a communication management section, which will outline how findings of the program will be communicated to interested parties.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Changes in quality of groundwater and surface water downgradient of EDAs
Explore option to install interceptor trench earlier (HEG 2016, Section 16.3.1, Number 35)
Contingency plans if seepage mitigation plans do not perform as anticipated (HEG 2016, Section 16.3.1)
Teck commits to implement the following mitigation measures to maintain surface water quality in consideration of surface flows into and out of the Project area and groundwater discharge (see the response to JRP IR 10.25, Appendix 10.25, Table 10.25-1):
Groundwater and surface waters draining EDAs will be captured if monitoring data indicate that the drainage waters are unsuitable for release.
Teck is committed to continue to consult meaningfully with, and engage, all potentially affected Indigenous groups at both a Project-specific and regional level to reduce and mitigate potential Project and cumulative effects on hydrology and surface water quality, including continuing discussions regarding hydrology and surface water quality concerns and is prepared to consider additional mitigation measures to address these concerns (see the response to JRP IR 10.25, Appendix 10.25).
Teck has developed a Draft Hydrology and Water Quality Mitigation, Monitoring and Adaptive Management Plan (see the response to JRP IR 10.25, Appendix 10.25). Once finalized, the plan will include a communication management section, which will outline how findings of the program will be communicated to interested parties.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Air Quality and Odour
NOX emissions None. Teck commits to implement the following mitigation measures to reduce NOX emissions from combustion sources (see the response to JRP IR 3.18, Table 3.18-1):
Use natural gas as a fuel for the cogeneration plant and boilers and heaters.
Dry low NOX technology to reduce NOX emissions and increase cogeneration plant efficiency.
Boiler and heater technology that will meet provincial and federal government emission requirements.
Purchase Tier IV compliant haul trucks when they become available.
Optimize mine planning to reduce haul distances.
Develop and implement an anti-idling program for the mine fleet.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
SO2 emissions None. Teck commits to implement the following mitigation measures to reduce SO2 emissions from combustion sources (see the response to JRP IR 3.18, Table 3.18-1):
Use natural gas as a fuel for the cogeneration plant and boilers and heaters.
Use ultra-low sulphur diesel for the mine fleet.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
PM2.5 and dust emissions None. Teck commits to implement the following mitigation measures to reduce PM2.5 emissions from combustion sources (see the response to JRP IR 3.18, Table 3.18-1):
Use natural gas as a fuel for the cogeneration plant and boilers and heaters.
Boiler and heater technology that will meet provincial and national government emission requirements.
Purchase Tier IV compliant haul trucks when they become available.
Optimize mine planning to reduce haul distances.
Develop and implement an anti-idling program for the mine fleet.
Teck commits to implement the following mitigation measures to reduce fugitive dust emissions (see the response to JRP IR 3.18, Table 3.18-1):
Dust mitigation measures to be applied to onsite roads during construction include appropriate selection of road materials, limiting vehicle speeds, surface watering, progressive reclamation, temporary vegetation of disturbed land and retain natural vegetation as windbreaks.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Hydrocarbon and reduced sulphur emissions and secondary organic aerosol precursor emissions
None. Teck commits to implement the following mitigation measures to reduce fugitive plant emissions (see the response to JRP IR 3.18, Table 3.18-1):
Use floating roof tanks where appropriate and a vapour recovery system to condense and recover vapours from storage tanks and process areas.
Use dual solvent vapour recovery units to provide full redundancy.
Conduct a leak detection and repair (LDAR) program to identify leaking components and to prioritize associated repairs.
Teck commits to implement the following mitigation measures to reduce fugitive mine face emissions (see the response to JRP IR 3.18, Table 3.18-1):
Mitigation not currently known.
Frontier Oil Sands Mine Project Appendix 10.12
Table 10.12-8: Potential Adverse Environmental Effect and Mitigation Table – Fort McKay Métis (continued)
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Potential Adverse Effects Mitigation Proposed by Fort McKay Métis in
TLU Study and CIA Mitigation Teck Commits to Implement
Teck commits to implement the following mitigation measures to reduce fugitive tailings area emissions (see the response to JRP IR 3.18, Table 3.18-1):
Tailing solvent recovery unit to maintain losses to less than four volumes of solvent to 1,000 volumes of bitumen produced.
Teck commits to implement the following mitigation measures to reduce hydrocarbon and reduced sulphur emissions from combustion sources (see the response to JRP IR 3.18, Table 3.18-1):
Use natural gas as a fuel for the cogeneration plant and boilers and heaters.
Purchase Tier IV compliant haul trucks when they become available.
Optimize mine planning to reduce haul distances.
Develop and implement an anti-idling program for the mine fleet.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted
Odour None. Teck has developed a draft Odour Management and Response Plan (see the response to JRP IR 3.13, Appendix 3.13). The draft Plan. The Plan’s goals are mitigation, monitoring, participation in regional complaint process, and correlation of complaints to Project activities to determine response actions. The Plan will be finalized following consultation with Indigenous communities, regulators and stakeholders.
At any time during Project operation, nearby residences will be able to contact Teck if they are concerned that Project operations are causing odours. The contact will be documented, investigative action will be initiated to determine the potential source, and the caller will be notified. If a source can be identified, a review will be undertaken to implement corrective action to reduce the potential for future occurrences (ERCB Round 1 SIR 113a; Appendix 3.13).
Acoustics
Change in sound levels
Mitigate noise even if compliance with Directive 038 is achieved (HEG 2016, Section 16.3.1, Number 28)
Teck has made an overall commitment to managing and promptly addressing all noise-related concerns (see Volume 3, Section 3.4.9.2, Project Update) and will develop a Noise Management Plan (see Volume 3, Section 3.4.9.1, Project Update).
Teck also commits to implement the following mitigation measures to reduce changes in sound levels (see Volume 3, Appendix 17H, Section 17H.5 of the Project Update and the response to JRP IR 1.3, Table 1.4-1):
Vehicles will be maintained in good working condition (e.g., mufflers will be maintained) and speed limits will be enforced.
Emergency alarms will be tested during daytime, where reasonably practical.
Acoustic performance of building wall construction will meet a minimum sound transmission class (STC) rating of 29, based on published data in the North American Insulation Manufacturers Association for a pre-engineered structure.
For outdoor equipment, the manufacturer incorporates mitigation in the equipment design to achieve the published sound power level.
Noise effects will be mitigated using various measures, including but not limited to the following:
o haul trucks exhaust silencer
o haul truck speed
o trip frequency (number of trips per daytime and nighttime period)
o route location or alignment
Ventilation openings (i.e., air intake and exhaust openings) will be fitted with appropriate acoustic silencers, louvers, or plenums, where applicable, to reduce outdoor sound transmission from indoor equipment.
Buildings housing indoor noise-generating equipment will be appropriately sealed to reduce noise.
Where practical, flanking path and penetrations from plumbing, heating ducts and electrical wire in the buildings will be properly insulated and covered to reduce noise.
Appropriate acoustical lagging will be installed to provide additional attenuation to the steel casing, where practical.
Vibration isolation pads, resilient mounts on equipment, resilient pipe support systems, and dampers will be installed where appropriate.
Teck will incorporate best management practices to reduce Project-related noise into Daily Operational Procedures, Long-Term Operational Procedures, design for low-noise facilities, and performance measurement as described in SPOG (2012) Best Practices Document, where appropriate (ERCB Round 1 SIR 116; Volume 3, Section 3.4.9.1 of the Project Update), including:
Daily Operational Procedures
Keeping compressor station doors and windows closed
Using belt dressing
Inspecting and repairing mufflers
Running fans slower at night (variable frequency drive [VFD])
Using vent silencers on buildings
Using soundproofing (insulation and lagging)
Troubleshooting transient noise
Minimizing flaring and venting
Considering gravel pack around compressor building skids
Developing noise check in daily reading sheets
Long-Term Operational Procedures
Responding quickly to noise concerns
Establishing baseline noise levels (in plant, at fence-line, or both) and resurvey to determine trends
Conducting regular assessment of noise control opportunities
Using best practical technology for noise control
Maintaining communication links with noise sensitive receptors and communities
Being aware of noise from contractors (e.g., service rigs) and developing processes to meet best practice expectations
Scheduling work to create the least amount of noise effects on noise sensitive receptors and keeping those affected informed
Frontier Oil Sands Mine Project Appendix 10.12
Table 10.12-8: Potential Adverse Environmental Effect and Mitigation Table – Fort McKay Métis (continued)
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Design for Low Noise Facilities
Considering low noise electric drives versus engine driven compressors
Designing cooler fans for low tip velocity
Orienting noise sources away from residents
Using acoustical pipe lagging
Installing VFDs on coolers
Performance Measurement
Conducting measurements and establishing baseline data
Using best practices as part of the company’s operating procedures
Visual
Change to visual environment None. Teck commits to implement the following mitigation measures to reduce changes to visual effects (see Volume 1, Section 8.3.6, Volume 3, Section 16.4.6, Volume 3, Section 18.10.4.2, Volume 3, Section 18.11.5.4 and Volume 3, Appendix 17H, Section 17H.7 of the Project Update):
Maintaining vegetated buffers between the Project and the Athabasca River as well as along Project transportation corridors to the extent feasible where safety concerns are not an issue.
Using construction materials that reduce contrast, limit visual attraction to Project features, and blending built structures into the natural surrounding environment.
Using construction materials, where practicable, that minimize light reflection, potentially reducing viewing distances of Project features
Reclamation techniques will be used that integrate closure plans with the surrounding landscape.
Teck will seek to develop closure plans that:
o Include integration and contouring of slopes that mimic natural topography.
o Focus on establishing a variety of vegetation communities.
o Avoid unnatural-looking breaks at development boundaries.
Planting a narrow band of white spruce along the edge of the river water intake (RWI) cofferdam and plant dogwood on the cofferdam, except in areas where tall vegetation would impede any maintenance or present safety concerns.
Completing reclamation in the RWI area to minimize erosion and slope instability.
Using lighting that minimizes light pollution.
At closure, infrastructure will be removed and the Project will be reclaimed using vegetation types similar, though not identical to existing conditions, creating a continuous vegetated landscape.
A lighting plan will be developed during future stages of engineering to avoid over-illumination. Lighting design will be part of future stages of engineering, and Teck will consult with interested Indigenous communities about lighting considerations.
Finish the Athabasca River Bridge with low-glare materials and plant vegetation buffers near the bridge. Teck also commits to clear minimal vegetation and to vegetate cleared areas.
Retain treed buffers around or near watercourses.
Fish and Fish Habitat
Change in productive fish habitat
Maintain habitats to a functioning capacity for healthy growth of fish (HEG 2016, Section 16.3.1, Number 57)
Fish habitat of equivalent or higher productivity than that affected by the Project will be created through offsetting measures where prevention of adverse habitat alteration or loss (i.e., reduced habitat productivity or loss of productive habitat area) is not feasible (see the draft Detailed Fisheries Offsetting Plan, the response to JRP IR 2.1, Appendix 2.1).
Teck also commits to implement the following mitigation measures to avoid or reduce changes in fish habitat quantity or quality (see the response to JRP IR 2.1, Table 5):
To avoid or reduce sedimentation:
o Temporary and permanent erosion and sediment control measures for construction activities and disturbed areas.
o Stabilization and revegetation of disturbed areas.
o Isolation of instream work areas where they are required.
o Best management practices and regulatory guidelines for construction activities in and near watercourses/waterbodies for erosion and sediment control.
o Polishing ponds or other measures to reduce suspended sediment concentrations in discharge waters to avoid increases in sedimentation in the receiving environment.
o Appropriate design of constructed channels and ponds to reduce internal erosion and generation of suspended sediments.
o Appropriate design and construction of reclaimed landscape to reduce sediment yield.
To avoid or reduce changes to water quality:
o Passing muskeg drainage and overburden water through polishing ponds and drainage ditches to reduce changes in water temperatures and dissolved oxygen concentrations.
o Recycling of process affected waters during operations.
o Capture and recycling of ETA seepage and run off water during operations, and use of a passive seepage control system at closure.
o Use of wetlands, pit lakes and constructed reclamation lakes in the closure drainage system to provide biological remediation before release to the environment.
o Removal of organic material from fish habitat compensation lake (FHCL) area prior to flooding.
To avoid or reduce changes to habitat area:
o Diversion of watercourses around the PDA to return natural upslope water back to the diverted watercourse to preserve flows and avoid elimination of downstream habitats.
o Provision of a flow splitter on the diversion channel that will collect water from both upper Redclay Creek and Unnamed Creek 17 to appropriately apportion the flows in lower Redclay Creek and Unnamed Creek 17 to avoid flow changes in the Ronald Lake watershed.
o Operation of the RWI and Off Stream Storage Pond (OSSP) in compliance with the Lower Athabasca River Surface Water Quantity Management Framework.
o Design of the closure drainage channels and pit lakes to provide habitats capable of supporting aquatic ecosystems.
o Best management practices and regulatory guidelines to ensure construction and operation of the RWI, Athabasca River bridge and watercourse crossings associated with access roads do not interfere with fish passage and access to available habitats.
Frontier Oil Sands Mine Project Appendix 10.12
Table 10.12-8: Potential Adverse Environmental Effect and Mitigation Table – Fort McKay Métis (continued)
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Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Change in fish abundance None. Teck commits to implement the following mitigation measures to avoid or reduce changes in fish abundance (see the response to JRP IR 2.1, Table 5):
Fish rescue operations to capture and relocate fish prior to habitat dewatering.
Screening of the RWI in compliance with regulatory guidelines to mitigate fish entrainment or impingement.
Best management practices and regulatory guidelines for scheduling construction activities in and near waterbodies/watercourse to avoid sensitive time periods in adjacent or downstream fish-bearing watercourses.
Education of Project personnel on sustainable fishing practices to support a Teck applied prohibition on their fishing in watercourses or waterbodies in the PDA to mitigate potential increases in recreational fishing pressure.
Access Management Plan for the PDA to limit access to fish bearing habitats to mitigate increased fishing pressure.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Change in fish and fish habitat diversity
Fish rescue operations to focus on all fish species from all disturbed habitats (HEG 2016, Section 16.3.1, Number 57)
Fish rescue and re-introduction (HEG 2016, Section 16.3.1, Number 57)
Teck commits to implement the following mitigation measures to avoid or reduce changes in fish and fish habitat diversity (see the response to JRP IR 2.1, Table 5):
Several of the measures intended to avoid or mitigate effects to fish habitat and fish abundance also apply to fish and fish habitat diversity, in cases where they preserve fish and productive fish habitats or create new habitats, including:
o Diversions designed to preserve flows and avoid elimination of downstream habitats.
o Closure drainage channels and pit lakes designed to provide habitats capable of supporting aquatic ecosystems.
o Fish rescue operations.
o Screening of the RWI.
o Education and prohibition of Project personnel from fishing in the PDA.
o Access Management for the PDA to limit access to fish bearing habitats.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Wildlife
Change in wildlife habitat availability
Support participation in land use planning, collaborative management and resource management (HEG 2016, Section 16.1)
Collaboration in developing an offset plan (HEG 2016, Section 16.3.1, Number 5)
Participate in CEMA or other multi-stakeholder groups that include Indigenous participation focused on wildlife issues (HEG 2016, Section 16.3.1, Number 16)
Teck commits to implement the following mitigation measures to reduce direct habitat loss (see the response to JRP IR 7.14, Table 7.14-1):
Limit the size of the east side access road right-of-way (ROW) and temporary workspace to the extent practical.
Limit the Athabasca River bridge footprint in riparian areas.
Carry out progressive reclamation to reclaim disturbed wildlife habitat as portions of the mine footprint become available.
Develop a weed management plan.
Teck commits to implement the following mitigation measures to reduce indirect habitat loss (see the response to JRP IR 7.14, Table 7.14-1):
Implement strategies to reduce noise and light effects, including design considerations (e.g., Frontier Project plant site engineering and aerodrome operation within regulatory and safety constraints).
Limiting employee and contractor access to identified areas of high-quality habitat adjacent to Project footprint.
Teck commits to developing a Biodiversity Management Plan (BMP) with the underlying goal of optimizing reclamation during operations to reduce offsetting of residual environmental effects (see the response to JRP IR 7.15).
Teck has developed a Draft Wildlife Mitigation, Monitoring and Adaptive Management Plan (WMMP; see the response to JRP IR 7.14, Appendix 7.14). Teck has proposed steps to Indigenous groups that would provide the opportunity for land users and community members to provide direct input into developing wildlife mitigation measures. Input will refine this draft WMMP. Once finalized, the plan will include a communication management section, which will outline how findings of the program will be communicated to interested parties.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Change in wildlife landscape connectivity
Support participation in land use planning, collaborative management and resource management (HEG 2016, Section 16.1)
Collaboration in developing an offset plan (HEG 2016, Section 16.3.1, Number 5)
Participate in CEMA or other multi-stakeholder groups that include Indigenous participation focused on wildlife issues (HEG 2016, Section 16.3.1, Number 16)
Discuss other options for wildlife passage and connectivity (HEG 2016, Section 16.3.1, Number 17)
Teck commits to implement the following mitigation measures to reduce change to landscape connectivity (see the response to JRP IR 7.14, Table 7.14-1):
Carry out progressive reclamation to restore habitat for movement as portions of the mine footprint become available.
To maintain connectivity between Birch Mountains and Athabasca River:
o Coordinate development activities with Canadian Natural Resources Limited (CNRL) who acquired the Pierre River Mine oil sands leases formerly held by Shell Canada Limited should CNRL reapply for and develop the Pierre River Mine project.
o Develop an integrated land management strategy for the Project in consultation with industry, the province, Indigenous communities, and stakeholders.
Provide wildlife passage under both sides of the Athabasca River bridge and river water intake bridge to Dalkin Island to allow north–south wildlife movement along river banks using crossing design considerations (e.g., bridge height and length) outlined in Clevenger and Huijser (2011) and GOA (2011).
Set up educational signage to limit human use of wildlife underpasses.
Evaluate wing fencing along the approach to crossing passages (at least 2.4 m high for large mammals as per GOA 2011) as part of the crossing structure design.
Provide appropriate walking substrate along the wildlife underpass.
Create vegetated buffers adjacent to wildlife underpasses to increase movement opportunities for a variety of species.
Provide coarse woody debris (e.g., stumps) along the wildlife underpass to provide cover and increase use by furbearers and other small mammals.
Teck has developed a Draft WMMP (see the response to JRP IR 7.14, Appendix 7.14). Teck has proposed steps to Indigenous groups that would provide the opportunity for land users and community members to provide direct input into developing wildlife mitigation measures. Input will refine this draft WMMP. Once finalized, the plan will include a communication management section, which will outline how findings of the program will be communicated to interested parties.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Change in wildlife mortality risk
Participate in CEMA or other multi-stakeholder groups that include Indigenous participation
Teck commits to implement the following mitigation measures to reduce wildlife mortality risk resulting from vehicle–wildlife collisions (see the response to JRP IR 7.14, Table 7.14-1):
Implement fly-in/fly-out policy for workers to reduce vehicular traffic volume.
Frontier Oil Sands Mine Project Appendix 10.12
Table 10.12-8: Potential Adverse Environmental Effect and Mitigation Table – Fort McKay Métis (continued)
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TLU Study and CIA Mitigation Teck Commits to Implement
focused on wildlife issues (HEG 2016, Section 16.3.1, Number 16)
Erect wildlife cautionary signage on access roads.
Foster environmental awareness with speed restrictions on access roads report Project-related wildlife fatalities.
Provide vegetation maintenance at roadsides (vegetation will be trimmed regularly to discourage roadside foraging and prevent visual obstruction of wildlife).
Develop seed mixes for roadside reclamation from less palatable species to reduce wildlife attraction to road edges.
Design the road to maximize line of sight.
Remove road kill as soon as practical.
Teck commits to implement the following mitigation measures to reduce wildlife mortality risk resulting from wildlife interactions with equipment (see the response to JRP IR 7.14, Table 7.14-1):
Implement preconstruction surveys for active wildlife habitat features (e.g., nests, breeding wetlands) before starting early works.
Avoid vegetation clearing during the recommended May 1 to August 10 migratory bird-breeding period for the boreal ecozone per Environment Canada guidelines; note that in species at risk habitat, a more conservative breeding window of April 1 to August 31 might apply (Gregoire 2014, pers. comm.); complete nest surveys if clearing activities occur during the breeding window.
Conduct owl nest search if clearing is scheduled within the non-migratory breeding bird window, March 1 to April 15 (based on Enhanced Approval Process guidelines for barred owl, GOA 2013).
Reduce on disturbance of amphibian breeding and overwintering habitat (where possible).
Teck commits to implement the following mitigation measures to reduce wildlife mortality risk resulting from interactions with Infrastructure (see the response to JRP IR 7.14, Table 7.14-1):
Create fuel and chemical spill contingency and response plans.
Confirm adequate spill protection for all fuel storage facilities.
Monitor and maintain waste disposal sites, wastewater storage areas and runoff control structures to prevent surface water impacts.
During overburden dewatering, intermittently backslope the sides of drainage ditches to allow for wildlife crossings and to reduce the potential for entrapment.
Use visible markers, such as aviation spheres and spiral vibration dampeners to make transmission lines near waterfowl staging and potential stopover areas more visible to birds, and where possible, design transmission lines to match the height of surrounding trees to reduce wire strikes by birds.
Teck commits to implement the following mitigation measures to reduce wildlife mortality risk resulting from wildlife–human conflicts (see the response to JRP IR 7.14, Table 7.14-1):
Implement a food waste-management strategy to prevent attraction of nuisance wildlife.
Confirm wildlife is not harassed or fed (to prevent habituation).
Provide wildlife awareness training to Project staff and contractors to reduce disturbance and negative human/bear interactions.
Provide all field staff with bear-aware training courses, personal protective equipment (e.g., bear spray, bear bangers, air horns) and training on proper use of equipment.
Develop a nuisance wildlife mitigation and monitoring plan in cooperation with the regulators.
Teck commits to implement the following mitigation measures to reduce wildlife mortality risk resulting from increased hunter access (see the response to JRP IR 7.14, Table 7.14-1):
Implement deactivation plans for roads no longer in use.
Prohibit construction and operations personnel and contractors from hunting and trapping while working.
Disallow personal recreational vehicle use onsite.
Prohibit firearms on Project lands or at Project facilities.
Consider requesting a Directors Order to limit public access to the west side of the Athabasca River along Project roads.
Teck has developed a Draft WMMP (see the response to JRP IR 7.14, Appendix 7.14). Teck has proposed steps to Indigenous groups that would provide the opportunity for land users and community members to provide direct input into developing wildlife mitigation measures. Input will refine this draft WMMP. Once finalized, the plan will include a communication management section, which will outline how findings of the program will be communicated to interested parties.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Waterfowl
Change in bird mortality risk
Participate in CEMA or other multi-stakeholder groups that include Indigenous participation focused on wildlife issues (HEG 2016, Section 16.3.1, Number 16)
Teck commits to implement the following mitigation measures to reduce migratory water bird mortality risk resulting from the use of ponds (see the response to JRP IR 7.10, Table 7.10-1):
Develop detailed construction and operational procedures and mitigation measures to reduce wildlife mortality during tailings area start-up.
Design the sides of wastewater ponds to reduce attractiveness to birds (e.g., using gravel for sides).
Clear trees and above-ground vegetation including shrubs, herbs and the ground layer prior to placement of tailings into tailings disposal areas.
Remove peat from tailings area prior to flooding.
Develop detailed construction and operational procedures and mitigation measures to reduce wildlife mortality during tailings area start-up.
Reduce attractiveness of tailings areas for birds by keeping the inner walls of the tailings dyke free of vegetation.
Keep slopes of tailings areas as steep as possible to reduce “black beach” areas.
Implement procedure for removing any peat mats that float to the surface of the tailings area.
Implement procedure for controlling floating bitumen mats.
Manage the use and operation of anthropogenic lighting around wastewater ponds and tailings areas.
Bird deterrent systems will be used to discourage birds from landing on wastewater ponds and tailings areas.
Teck commits to implement the following mitigation measure to reduce the potential for birds to land in ponds containing process-affected water (see the response to ESRD/CEAA Round 3 SIR 64):
Bird deterrent systems will be installed on all ponds associated with the Project that have process-affected water that could be detrimental to birds.
Teck commits to implement the following mitigation measures to maximize recovery efficiency should birds use ponds (see the response to JRP IR 7.10, Table 7.10-1):
Develop procedure for handling of any bird recovered from wastewater ponds or tailings areas.
Procedure will be in compliance with directions received from the local Alberta Fish and Wildlife office and/or the Alberta Environment and Parks (AEP) wildlife biologist.
Frontier Oil Sands Mine Project Appendix 10.12
Table 10.12-8: Potential Adverse Environmental Effect and Mitigation Table – Fort McKay Métis (continued)
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Potential Adverse Effects Mitigation Proposed by Fort McKay Métis in
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Procedure will also be in compliance with directions from Environment and Climate Change Canada with respect to whooping cranes.
Teck commits to implement the following mitigation measures to reduce the potential for bird mortality risk resulting from interaction with transmission and distribution lines (see the response to JRP IR 7.10, Table 7.10-1):
Designing transmission and distribution lines, where possible, to match the height of surrounding trees to reduce wire strikes by birds.
Marking of transmission and distribution lines in areas near waterfowl staging and potential stopover areas.
Teck has developed a Draft Waterfowl Protection Plan (see the response to JRP IR 7.10, Appendix 7.10). Teck will continue to pursue collaborative engagement processes, as outlined in the WMMP for the Project as the primary mechanism in which it will engage with potentially affected Indigenous groups regarding the Waterfowl Protection Plan. Once finalized, the plan will include a communication management section, which will outline how findings of the program will be communicated to interested parties.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Bison
Change in bison habitat availability
Support participation in land use planning, collaborative management and resource management (HEG 2016, Section 16.1)
Collaboration in developing an offset plan (HEG 2016, Section 16.3.1, Number 5)
Participate in CEMA or other multi-stakeholder groups that include Indigenous participation focused on wildlife issues (HEG 2016, Section 16.3.1, Number 16)
Teck commits to implement the following mitigation measures to reduce direct habitat loss (see the response to JRP IR 7.5, Table 7.5-1):
Limit the size of the east side access road right-of-way (ROW) and temporary workspace to the extent practical.
Limit the Athabasca Rive bridge footprint in riparian areas.
Carry out progressive reclamation to reclaim disturbed wildlife habitat as portions of the mine footprint become available.
Develop a weed management plan.
Teck commits to implement the following mitigation measures to reduce indirect habitat loss (see the response to JRP IR 7.5, Table 7.5-1):
Implement strategies to reduce noise and light effects, including design considerations (e.g., Frontier Project plant site engineering and aerodrome operation within regulatory and safety constraints).
Limiting employee and contractor access to identified areas of high-quality habitat adjacent to Project footprint.
Teck has developed a Draft Ronald Lake Bison Mitigation, Monitoring and Adaptive Management Plan (see the response to JRP IR 7.5, Appendix 7.5). Teck has proposed steps to Indigenous groups that would provide the opportunity for land users and community members to provide direct input into developing wildlife mitigation measures, including those specific to bison. Once finalized, the plan will include a communication management section, which will outline how findings of the program will be communicated to interested parties.
Teck will also work with the responsible authority to explore possible mitigations for which Teck does not have the authority to implement independently.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Change in bison landscape connectivity
Support participation in land use planning, collaborative management and resource management (HEG 2016, Section 16.1)
Collaboration in developing an offset plan (HEG 2016, Section 16.3.1, Number 5)
Participate in CEMA or other multi-stakeholder groups that include Indigenous participation focused on wildlife issues (HEG 2016, Section 16.3.1, Number 16)
Discuss other options for wildlife passage and connectivity (HEG 2016, Section 16.3.1, Number 17)
Teck commits to implement the following mitigation measures to reduce change to landscape connectivity (see the response to JRP IR 7.5, Table 7.5-1):
Carry out progressive reclamation to restore vegetated corridors as portions of the mine footprint become available.
To maintain connectivity between Birch Mountains and Athabasca River:
o Coordinate development activities with Canadian Natural Resources Limited (CNRL) who acquired the Pierre River Mine oil sands leases formerly held by Shell Canada Limited should CNRL reapply for and develop the Pierre River Mine project.
o Develop an integrated land management strategy for the Project in consultation with industry, Indigenous stakeholders and the Province.
Provide wildlife passage under both sides of the Athabasca River bridge and river water intake bridge to Dalkin Island to allow north–south wildlife movement along river banks using crossing design considerations (e.g., bridge height and length) outlined in Clevenger and Huijser (2011) and GOA (2011):
o Set up educational signage to limit human use of wildlife underpasses.
o Evaluate wing fencing along the approach to crossing passages (at least 2.4 m high for large mammals as per GOA 2011) as part of the crossing structure design.
o Provide appropriate walking substrate along the wildlife underpass.
o Create vegetated buffers adjacent to wildlife underpasses to increase movement opportunities for a variety of species.
Teck has developed a Draft Ronald Lake Bison Mitigation, Monitoring and Adaptive Management Plan (see the response to JRP IR 7.5, Appendix 7.5). Teck has proposed steps to Indigenous groups that would provide the opportunity for land users and community members to provide direct input into developing wildlife mitigation measures, including those specific to bison. Once finalized, the plan will include a communication management section, which will outline how findings of the program will be communicated to interested parties.
Teck will also work with the responsible authority to explore possible mitigations for which Teck does not have the authority to implement independently.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Change in bison mortality risk
Participate in CEMA or other multi-stakeholder groups that include Indigenous participation focused on wildlife issues (HEG 2016, Section 16.3.1, Number 16)
Teck commits to implement the following mitigation measures to reduce bison mortality risk resulting from vehicle–bison collisions (see the response to JRP IR 7.5, Table 7.5-1):
Implement fly-in/fly-out policy for workers to reduce vehicular traffic volume.
Erect wildlife cautionary signage on access roads.
Foster environmental awareness with speed restrictions on access roads, report Project-related wildlife fatalities.
Provide vegetation maintenance at roadsides (vegetation will be trimmed regularly to discourage roadside foraging and prevent visual obstruction of wildlife).
Develop seed mixes for roadside reclamation from less palatable species to reduce wildlife attraction to road edges.
Design the road to maximize line of sight.
Teck commits to implement the following mitigation measures to reduce bison mortality risk resulting from bison-human interactions - interactions with infrastructure (see the response to JRP IR 7.5, Table 7.5-1):
Create fuel and chemical spill contingency and response plans.
Confirm adequate spill protection for all fuel storage facilities.
Monitor and maintain waste disposal sites, wastewater storage areas and runoff control structures to prevent contamination of surface waters.
During overburden dewatering, intermittently backslope the sides of drainage ditches to allow for wildlife crossings and to reduce the potential for entrapment.
Frontier Oil Sands Mine Project Appendix 10.12
Table 10.12-8: Potential Adverse Environmental Effect and Mitigation Table – Fort McKay Métis (continued)
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Potential Adverse Effects Mitigation Proposed by Fort McKay Métis in
TLU Study and CIA Mitigation Teck Commits to Implement
Teck commits to implement the following mitigation measures to reduce bison mortality risk resulting from hunter access (see the response to JRP IR 7.5, Table 7.5-1):
Construct predator access blocks to deter predator use (i.e., reduce line of sight) on linear features in the PDA that may leave core bison areas susceptible to predation.
Deactivate roads in the PDA no longer in use.
Implement employee / contractor policies to prohibit hunting within the Project area.
Reduce linear features in the closure landscape.
Reduce width of linear features in the closure landscape.
Teck commits to implement the following mitigation measures to reduce bison mortality risk resulting from disease transmission to the Ronald Lake bison herd (see the response to JRP IR 7.5, Table 7.5-1):
Implement progressive reclamation in the PDA to create suitable Ronald Lake bison habitat and reduce the potential of shifting habitat use northward.
Mitigations associated with reducing hunter and predator access.
Mitigations associated with reducing wildlife human conflict.
Mitigations associated with reducing indirect habitat loss.
Teck has developed a Draft Ronald Lake Bison Mitigation, Monitoring and Adaptive Management Plan (see the response to JRP IR 7.5, Appendix 7.5). Teck has proposed steps to Indigenous groups that would provide the opportunity for land users and community members to provide direct input into developing wildlife mitigation measures, including those specific to bison. Once finalized, the plan will include a communication management section, which will outline how findings of the program will be communicated to interested parties.
Teck will also work with the responsible authority to explore possible mitigations for which Teck does not have the authority to implement independently.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Vegetation
Change in vegetation
Support participation in land use planning, collaborative management and resource management (HEG 2016, Section 16.1)
Support for development of reclamation planning and criteria (HEG 2016, Section 16.1)
Collaboration in developing an offset plan (HEG 2016, Section 16.3.1, Number 5)
Develop best management practices for peatlands in a multi-stakeholder group acceptable to Fort McKay that allows Fort McKay’s participation (HEG 2016, Section 16.3.1, Number 68)
Follow up-to-date wetland reclamation guidelines (HEG 2016, Section 16.3.1, Number 69)
Develop a program to mitigate wetlands drawdown effects (HEG 2016, Section 16.3.1, Number 70)
Salvage organic soils where possible and direct place them in locations of high potential for peatland reformation (HEG 2016, Section 16.3.1, Number 71)
Engage the community in traditional plant seed collection for reclamation (HEG 2016, Section 16.3.1, Number 72)
On-site research and trial programs for reclaiming native shrubs and groundcover (HEG 2016, Section 16.3.1, Number 75)
On-site research and trial programs for reclamation and conservation of fens and bogs (HEG 2016, Section 16.3.1, Number 75)
Reclaim the land to support self-sustaining, locally common boreal forests and maximize number of pre-disturbance ecosites present (HEG 2016, Section 16.3.1, Number 76)
Control non-native and invasive plant species
Teck is committed to continue working with potentially affected Indigenous groups to refine the closure, conservation and reclamation (CC&R) plan through the life of the Project and to incorporate input from Indigenous groups on reclamation monitoring and thresholds and document the establishment of traditional use vegetation in the reclaimed landscape. Teck plans to co-create Reclamation Working Group(s) with potentially affected Indigenous groups to seek input to the Project’s reclamation plan and measures and targets to determine its success. It anticipates that species of traditional importance will be identified by Reclamation Working Group(s) and incorporated into reclamation planning as feasible. In addition, collaborative participation is planned in reclamation research both from a Project and regional perspective. Results of this research will be incorporated into future Project plans (see the response to JRP IR 6.9, Section 4.2).
Teck also commits to implement the following mitigation measures to reduce change in vegetation (see Volume 3, Appendix 17H, Section 17H.4 of the Project Update; response to JRP IRs 6.8 and 6.10):
Reclamation of the closure landscape will focus on generating a sustainable landscape that is designed to maximize diversity through the generation of landforms that include:
o topographic diversity and associated diversity in moisture regimes
o aspect diversity
o substrate diversity including both fine- and coarse- grained landforms
o mesotopography
Removal of existing linear disturbances that are currently fragmenting the landscape.
Mitigation to reduce effects on community diversity will focus on research results and strategies as summarized in:
o Guidelines for Reclamation to Forest Vegetation in the Athabasca Oil Sands Region (2nd Edition) (ESRD 2010)
o Guideline for Wetland Establishment on Reclaimed Oil Sands Leases (3rd Edition) (CEMA 2014)
o Oil Sands Marshes: A Knowledge Transfer (Charette et al. 2012)
o Best Management Practices for Conservation of Reclamation Materials in the Mineable Oil Sands Region of Alberta (MacKenzie 2011)
o Restoration and Reclamation of Boreal Ecosystems: Attaining Sustainable Development (Vitt and Bhatti 2012)
o Riparian Classification and Reclamation Guide, Revised Edition (Mihajlovich 2012)
Include peatlands in detailed CC&R planning should research results and recommendations prove to be feasible and appropriate.
Work with the governments of Alberta and Canada and look to their guidance on the development of a Conservation Agreement.
Plant additional species on the reclamation landscape, including those with traditional value, to supplement those recommended in provincial reclamation guidelines.
Mitigation for rare plant species will be achieved through avoidance whenever possible. In areas where avoidance is not possible, alternate mitigation strategies will be developed to promote conservation of these species and associated genetic diversity.
A weed management plan will be implemented throughout the life of the Project including during reclamation and at closure.
Develop and implement a program to salvage and relocate known occurrences of rare (vascular) plant species to areas outside of the Project area in consultation with Indigenous communities.
Incorporate species of traditional important as identified through the Reclamation Working Group(s) into reclamation planning, as feasible.
Engage Indigenous communities in preparing plans to harvest and collect seeds, and will invite community members to harvest and collect seeds of rare and culturally important species before disturbance, for use in reproducing the species and revegetation of the Project area.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures related to reclamation and evaluate monitoring results to determine if adaptations are warranted.
Frontier Oil Sands Mine Project Appendix 10.12
Table 10.12-8: Potential Adverse Environmental Effect and Mitigation Table – Fort McKay Métis (continued)
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(HEG 2016, Section 16.3.1, Number 77)
Provide a draft weed management plan addressing all disturbance in the local study area to the community for input (HEG 2016.
Section 16.3.1, Number 77)
Develop and implement a reclamation material stockpile revegetation to re-establish diversity of native vegetation species (HEG 2016, Section 16.3.1, Number 79)
Excess slash and non-merchantable timber are saved and used in the reclaimed site (HEG 2016, Section 16.3.1, Number 80)
Establish biodiversity research to increase biodiversity on the post-reclamation landscape (HEG 2016, Section 16.3.1, Number 81)
Define goals for re-establishing biodiversity and reclaim to equivalent biodiversity post-mining (HEG 2016, Section 16.3.1, Number 82)
Lead initiatives to develop key performance indicators for adaptive management framework for success and pace of reclamation, including progressive reclamation (HEG 2016, Section 16.3.1, Numbers 102, 103 and 104)
Develop cultural key stone species before project approval and consider them in reclamation planning (HEG 2016, Section 16.3.1, Number 105)
Support the community in research developing reclamation certification criteria and indicators (HEG 2016, Section 16.3.1, Number 106)
Reduce the time gap between disturbance and reclamation, maximize direct placement and provide the community a meaningful role in reclamation planning (HEG 2016, Section 16.3.1, Number 109)
Historical Resources
Changes to historical resources within the Project disturbance area
None. Teck commits to implement the following mitigation measures regarding changes to historical resources within the Project disturbance area (see Volume 3, Appendix 17H, Section 17H.9 of the Project Update):
Historical resources sites in the PDA that Alberta Culture and Tourism (ACT) determines to have moderate to high heritage value will likely have requirements for further study. These might include some or all of the following:
o Additional shovel testing to identify site boundaries, areas of highest artifact density, activity areas and areas with unique or specialized artifacts.
o Archaeological excavation at sites with high interpretive potential.
o Mapping and documentation at specific sites.
Teck will phase the required supplemental historic resources impact assessment (HRIA) studies to ensure completion of all necessary studies in the PDA in advance of vegetation clearing in each development area.
Teck will also work collaboratively with local First Nation and Aboriginal communities on mitigation studies, in an effort to address local concerns and interests in relation to historical resources in the area.
Socio-economics
Change to housing needs Long-term economic arrangements to provide social and physical infrastructure (HEG 2016, Section 16.1)
Teck commits to implement the following mitigation measures regarding housing needs (see the response to JRP IR 5.14(a), Table 5.15a-1):
Provide on-site, lodge-based accommodations during construction and operations to reduce the Project’s effect on the resident population and associated effects on social infrastructure and housing in the region.
Offer lodge amenities and services – including individual rooms and shared spaces, the quality of the food services and free-time activities – that are competitive with other lodge accommodations in the region.
Change to social infrastructure needs
Long-term economic arrangements to provide social and physical infrastructure (HEG 2016, Section 16.1)
Social services and programming (HEG 2016, Section 16.2)
Traditional food security system (HEG 2016, Section 16.2)
Teck commits to implement the following mitigation measures regarding social infrastructure needs (see the response to JRP IR 5.14(a), Table 5.15a-2):
Maintain explicit and enforced lodge, workplace and flight policies with regards to the use of alcohol, drugs and illegal activities.
Provide onsite security services, including controlled gates, check-in procedures, perimeter security fencing and lodge-based security officers on duty 24 hours.
Offer in-house security services to assist the Royal Canadian Mounted Police (RCMP) within, and sometimes outside, the Project lease boundaries (e.g., securing accident scenes and assisting with highway closures).
Develop and implement an emergency response plan which includes the required personnel, procedures and equipment resources (e.g., vehicles, fire response, medical response and rescue).
Develop required mitigation measures for areas adjacent to the Project area based on the FireSmart Wildfire Assessment System and implement in the emergency response plan.
Frontier Oil Sands Mine Project Appendix 10.12
Table 10.12-8: Potential Adverse Environmental Effect and Mitigation Table – Fort McKay Métis (continued)
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Program to promote health (HEG 2016, Section 16.3.1, Number 41)
Participate in regional environmental and health management programs including indirect health effects (HEG 2016, Section 16.3.1, Numbers 88 and 89)
Enter into mutual aid agreements with the Regional Municipality of Wood Buffalo (RMWB) and other oil sands companies that include:
o responding to motor vehicle accidents on Highway #63
o responding to forest fire threats to Fort McKay
o responding to regional spills
Participate in the management of regional emergencies at the RMWB’s Regional Emergency Operations Centre.
Make available onsite health services, including an on-site medical facility staffed by qualified health professionals providing 24-hour on-site primary, emergency and occupational health services.
Consider financial and in-kind contributions to the Northern Lights Health Foundation, where appropriate, to support the efforts of Alberta Health Services to meet the needs of Wood Buffalo residents. Recognizing some of the health concerns in the region Teck is prepared to make health promotion and disease prevention initiatives a focus of their community investment policy.
Provide helicopter or fixed-wing aircraft access via the on-site aerodrome for injured workers requiring rapid evacuation for off-site medical care.
Discuss with other industrial proponents near the Project options for coordinating on-site health facilities and resources.
Assess and support school events and education initiatives identified by rural schools in the study area, as appropriate.
Provide employees with access to the company’s confidential Employee and Family Assistance Plan, which provides support for families and individuals who might experience difficulty dealing with personal, family or work-life issues that can affect one’s health and well-being.
Consider support for community level initiatives including social groups providing assistance to those in need.
Continue providing direct support to community initiatives through its social investment programs.
Offer shift schedules that provide workers with sufficient time off to enjoy leisure activities in their home communities.
Make available onsite recreational opportunities and facilities.
Change to transportation needs
Support participation in land use planning, collaborative management and resource management (HEG 2016, Section 16.1)
Long-term economic arrangements to provide social and physical infrastructure (HEG 2016, Section 16.1)
Transportation programming (HEG 2016, Section 16.2)
Teck commits to implement the following mitigation measures regarding transportation needs (see the response to JRP IR 5.14(a), Table 5.14a-3):
Construct and operate an aerodrome near the Project site.
Use on-site as well as regional lodge accommodations during both construction and operations to reduce worker commutes.
Use bus service for transporting construction and operations workers.
Limit private vehicles brought to the Project site.
Schedule truck traffic, including oversized loads, to off-peak hours.
Use an on-site concrete batch plant; and attempt to source aggregates from pits near to site.
Enforce lodge, workplace and flight policies with regards to the use of alcohol, drugs and illegal activities.
Work with the local RCMP to confirm communication on local effects.
Support the efforts of RMWB and Oil Sands Community Alliance (OSCA) to work with the provincial government to progress improvements to highway infrastructure in a timely way.
Keep responsible regional and provincial planners informed of the Project’s development plans and their timing.
Consult and cooperate with other operators regarding shift scheduling with a view to reduce overlap in commuter traffic.
Provide funding to assist in the maintenance and safety of applicable segments of Highway #63 from Fort McKay to Fort Chipewyan that are affected by the Project.
Change to municipal infrastructure needs
Long-term economic arrangements to provide social and physical infrastructure (HEG 2016, Section 16.1)
Transportation programming (HEG 2016, Section 16.2)
Teck commits to implement the following mitigation measures regarding municipal infrastructure (see the response to JRP IR 5.14(a), Table 5.14a-4):
Provide water and sewer services for the different mining areas and the associated processing facilities and infrastructure, including on-site lodges.
Teck commits to implement the following mitigation measures regarding choice of fly-in/fly-out (FIFO) (see the response to JRP IR 5.14(a), Table 5.14a-6):
A FIFO lodge-based approach to construction and operations.
Ongoing monitoring of the operations FIFO model and revisiting the approach should local circumstances change.
Teck’s monitoring will take into consideration input received via its workers, contractors and ongoing local stakeholder and Indigenous engagement process. This would likely include feedback with respect to the social and economic effects of the FIFO model on individual workers, their families and communities.
Commitment to include Fort Chipewyan in a FIFO program.
Engage with potential employees living in Fort Chipewyan to discuss shift schedules and other travel and lodging logistics that influence their choice to work at the Project versus other opportunities.
Discuss with local communities the design of FIFO shifts that best benefit its employees and families while remaining logistically and financially feasible.
Remain open to engaging in broader, regional initiatives, for example through the OSCA and its study of the use of aerodromes in the region.
Change to employment, business and training opportunity needs
Long-term economic arrangements to provide social and physical infrastructure (HEG 2016, Section 16.1)
Employment and procurement (HEG 2016, Section 16.2)
Hiring procedures (HEG 2016, Section 16.2)
Training and capacity building (HEG 2016, Section 16.2)
Provide compensation or implement mitigation for trappers per Fort McKay’s Trapper Compensation Guidelines (HEG 2016, Section 16.3.1, Number 15)
Establish fiscal targets for business
Teck commits to implement the following mitigation measures regarding employment, business and training opportunity needs (see the response to JRP IR 5.14(a), Table 5.14a-5):
Specific contractual commitments to Indigenous communities on employment, business and training opportunities will be made within Participation Agreements negotiated between Teck and the Indigenous community.
Prioritize recruiting residents from the region first, Alberta second, followed by the rest of Canada, then North America and then overseas countries.
Draw on various sources of labour in Canada that are traditionally under-represented in the labour market, including Indigenous people, immigrants and women.
Put in place a policy to hire local businesses and contractors that are competitive and able to meet the company’s needs is already in place.
Teck will consult with Indigenous communities regarding procurement and employment initiatives such as:
o Establishing mechanisms to enhance employment prospects of local residents, including preferential consideration.
o Using procurement processes that regard local ownership and prevalence of workers residing locally as positive criteria in goods and services vendor selection competitions.
o Establishing monitoring programs that measure local involvement, gather feedback and work with interested parties on how to improve results.
Implement Teck’s relevant charters, codes and policies, including its Indigenous Peoples Policy, when working with Indigenous peoples in seeking to develop lasting mutual benefits that respect Indigenous community’s values – including hiring, training and retention of Indigenous employees.
Utilize what Teck’s has learned to date from local Indigenous communities with which it is engaged for the Project to overcome oil sands specific challenges to Indigenous employment and procurement.
Consider work experience in lieu of a high school graduation for Indigenous peoples.
Work with the Fort McMurray Chamber of Commerce, the Northeastern Alberta Aboriginal Business Association (NAABA) and others to maximize contracting and employment opportunities in the region.
Frontier Oil Sands Mine Project Appendix 10.12
Table 10.12-8: Potential Adverse Environmental Effect and Mitigation Table – Fort McKay Métis (continued)
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opportunities and community-specific processes to enhance workforce and training (HEG 2016, Section 16.3.2, Number 111)
Offer a choice of worker turnaround cycles and opportunity to earn premium pay through overtime.
Continue to work with the Indigenous communities in the area and specifically with the communities of Fort McKay and Fort Chipewyan to develop Indigenous employment and business development program(s) guided by a commitment to: maximize opportunities for local Indigenous businesses to supply services and products in support of Project construction and operations; hire qualified Indigenous people from the communities surrounding the Project and support education, training and investment initiatives in local Indigenous communities, where appropriate.
Teck’s Indigenous community employment and business development program(s) will engage with Indigenous communities on establishing employment and procurement policies and procedures, as well as adaptive management mechanisms specific to Indigenous community employment and procurement.
Teck’s Indigenous community employment and business development program(s), as well as community-specific Participation Agreements will take into consideration input provided by local Indigenous communities, and will be guided by a commitment to: develop substantial opportunities for local Indigenous businesses to supply services and products in support of Project construction and operations; hire qualified Indigenous people from the communities surrounding the Project and support education, training and investment initiatives in local Indigenous communities, where appropriate.
Continuously monitor Teck’s local employment and procurement policies and programs, along with reporting the results of this monitoring as part of ongoing community consultation.
Teck has yet to determine the exact reporting and monitoring mechanisms for its local procurement and employment policies, but will engage with Indigenous communities on mechanisms and expects they will likely be similar to mechanisms used by Teck’s other operations. These might include:
o Total employment, attraction and retention rates, average salary levels and other general human resource data. Where possible, the data will be disaggregated at the local community level.
o Procurement activity, including examination of goods and services sourced from providers in local communities, value and length of contracts, types of goods and services provided and employment and enterprise effects associated with procurement.
o Additional potential mechanisms are identified in Teck’s draft socio-economic monitoring plan in response to JRP IR 5.15(a).
Continue supporting local labour force skills development, and work with communities, government and other industrial proponents on programs that assist community members overcome labour market barriers.
Change to culture
Support participation in land use planning, collaborative management and resource management (HEG 2016, Section 16.1)
Support for development of reclamation planning and criteria (HEG 2016, Section 16.1)
Cultural camps (HEG 2016, Section 16.2)
Cultural center (HEG 2016, Section 16.2)
Cultural programming (HEG 2016, Section 16.2)
Social services and programming (HEG 2016, Section 16.2)
Teck commits to implement the following mitigation measures regarding changes to culture (see the response to JRP IR 5.14(a), Tables 5-14a-6 and 5.14a-7):
Continue to expand Teck’s knowledge of, and engagement with, local stakeholders and Indigenous communities near the Project to confirm ongoing and growing participation in Project-related benefits, as well as the design of appropriate and effective mitigation measures to reduce any adverse effect. These efforts are envisioned to include capacity building support within Participation Agreements for Indigenous communities.
Provide cultural diversity awareness training to employees and contractors, focusing on respect for traditional land users as well as respect for Indigenous world views, customs and values.
Consider supportive workplace practices as Teck develops workplace policies and seek local Indigenous community input into cultural awareness programming to be provided at the Project site.
Carry out a review of Teck’s standard bereavement policy, including a review of policies from other fly in/fly out operations in Alberta, as operation specific policies are developed during future planning phases.
Continuing to provide cultural awareness training for all Project staff and contractors.
Considering key Indigenous access routes and access preferences in the Project’s draft Access Management Plan (AMP).
Considering cultural keystone species in the wildlife management and mitigation plan, FHCL and biodiversity management plan.
Incorporating and using Indigenous place names where applicable.
Supporting community-led projects to document Indigenous place names in their respective traditional territories.
Contributing to language retention programs and other programs that support retaining Indigenous culture, knowledge and practice (e.g., culture camps for youth).
Discuss with local communities the design of fly in/fly out shifts that best benefit its employees and families while remaining logistically and financially feasible.
Access
Change to access near the Project disturbance area
Support participation in land use planning, collaborative management and resource management (HEG 2016, Section 16.1)
Transportation programming (HEG 2016, Section 16.2)
Support development of access management plan for West side of Athabasca River, trap lines and other areas (HEG 2016, Section 16.3.1, Numbers 7 and 8)
Teck has developed a draft access management plan (AMP) for the Project to facilitate access to or through Teck’s mineral surface lease to the extent possible while maintaining worker and public safety (see the response to JRP 4.5, Appendix 4.5). Teck has proposed next steps to Indigenous groups that would provide the opportunity for land users and community members to provide direct input into developing access mitigation measures. This input will refine the draft AMP.
Teck commits to implement the following mitigation measures to reduce potential effects on changes to access near the Project disturbance area (see Volume 3, Appendix 17H, Section 17H.8.2 of the Project Update) and the response to JRP IR 10.9):
All individuals wanting to gain access to or through lands being actively developed, which is generally Teck’s mineral surface lease (MSL), will be required to submit an access request.
Traditional land users will be granted temporary access to and through the PDA according to the policy and processes set out in the AMP.
Traditional land users will not have to meet worker site access requirements but will be escorted by someone who has permanent site access (i.e., a worker).
Access through, and to portions of the PDA not being actively developed will not require an access request form be submitted. Individuals will be required to contact the site’s security office and provide adequate notice about when they plan to be in the area, who will be present, and the intended activities and general location(s) as they relate to Teck leases. All individuals passing through the PDA will have to check in at the security office and will be escorted by a Teck worker. Teck understands that Aboriginal communities desire that the advance notice period.
Throughout the life of the mine, access to locations in the PDA by Aboriginal community members will be based on mine advance. For safety reasons, harvesting and use of firearms would not be permitted in areas being actively mined or within and around facilities associated with the mine.
The River Road will be maintained through operations and will provide access to the Fish Habitat Compensation Lake, aerodrome, and areas north of the PDA.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Traditional Land Use
Change in availability of resources (wildlife, fish and vegetation), culturally important sites or areas for traditional activities and use of lands
Support participation in land use planning, collaborative management and resource management (HEG 2016, Section 16.1)
Support for development of reclamation planning and criteria (HEG 2016, Section 16.1)
Traditional food security system (HEG 2016, Section 16.2)
Cultural camps (HEG 2016, Section 16.2)
Teck commits to implement the following mitigation measures to reduce changes in availability of resources (wildlife, fish and vegetation), culturally important sites or areas for traditional activities and use of lands (assessed in Volume 3, Section 17.6 of the Project Update) (see the response to JRP IR 4.6, Table 4.6-1):
Grant traditional land users temporary access to and through the PDA according to the policy and processes set out in the draft access management plan.
Implement measures to mitigate Project-related effects on wildlife through the wildlife monitoring and mitigation plan.
Engage Indigenous communities in the development of a biodiversity management plan.
Implement measures to mitigate Project-related effects on fish and fish habitat through the detailed fisheries offsetting plan.
Implement measures to reduce Project-related effects on vegetation through the conservation closure and reclamation plan and the reclamation monitoring plan.
Historical resources sites in the PDA that Alberta Culture and Tourism (ACT) determines to have moderate to high heritage value will meet the requirements of ACT and aim to meet the desires of Indigenous communities.
Frontier Oil Sands Mine Project Appendix 10.12
Table 10.12-8: Potential Adverse Environmental Effect and Mitigation Table – Fort McKay Métis (continued)
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Collaboration in developing an offset plan (HEG 2016, Section 16.3.1, Number 5)
Provide compensation or implement mitigation for trappers per Fort McKay’s Trapper Compensation Guidelines (HEG 2016, Section 16.3.1, Number 15)
Teck commits to implement the following mitigation measures to reduce effects on the land use experience for traditional land users (see the response to JRP IR 4.6, Table 4.6-1):
Establish Participation Agreements with Indigenous communities.
Invite traditional users to harvest traditional plants before disturbance.
Support the planning and implementation of an excursion for Indigenous communities within the terrestrial local study area prior to Project-related disturbance to describe Indigenous values, access and to recommend mitigation to avoid or limit effects on Indigenous access values.
Provide cultural diversity awareness training to employees and contractors focusing on respect for Indigenous land users, traplines, cabins, trails and equipment, as well as respect for Indigenous world views, customs and values.
Compensate Indigenous trappers following industry-community standards and the Alberta Trappers Compensation Program.
Project personnel will be prohibited from fishing, hunting and trapping within the PDA during work rotations, which is when Teck’s policies’ can be enforced.
Project personnel will be prohibited from using personal recreation vehicles within the PDA.
Investigate with potentially affected Indigenous communities through the Reclamation Working Group the concept of incorporating cultural values into reclamation planning.
Supporting documentation of community-specific cultural heritage.
Teck has developed a Draft Traditional Land Use Mitigation, Monitoring and Adaptive Management Plan (see the response to JRP IR 4.6, Appendix 4.6). Teck will continue to seek input and engage with Indigenous groups, as well as regulators where appropriate, as part of finalizing this plan. Once finalized, Teck will continue to pursue collaborative engagement processes with Indigenous groups as outlined in the plan. Through these collaborative engagement processes Teck will aim to minimize and mitigate potential Project effects on traditional land use. Once finalized, the plan will include a communication management section, which will outline how findings of the program will be communicated to interested parties.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Notes:
Fort McKay Metis mitigations referenced with “Number X” refers to the number system in the table starting on page 383 of HEG 2016.
NOx = oxides of nitrogen; SO2 = sulphur dioxide; PM2.5 = particulate matter
Frontier Oil Sands Mine Project Appendix 10.12
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5 Fort McMurray Métis Local 1935
A summary of established or asserted Aboriginal rights, current use of lands and resources for traditional
purposes and cultural and physical heritage features as described by Fort McMurray Métis Local 1935
(Métis Local 1935) is presented in Table 10.12-9.
Table 10.12-9: Fort McMurray Métis Local 1935 Rights, Land Uses and Cultural and Physical Heritage Features
Established or Asserted Aboriginal Rights, Current Use of Lands and Resources for Traditional Purposes
Cultural and Physical Heritage Feature
Access to the land to hunt, trap, fish and harvest resources
Use of the Athabasca River and surrounding lands
Harvesting rights that depend on wildlife
Access to harvesting areas
Traditional trails
Cabins
Burial sites
Historic and current Registered Fur Management Areas (RFMAs)
Athabasca River
Potential adverse Project effects on Métis Local 1935’s established or asserted Aboriginal rights, current
use of lands and resources for traditional purposes or cultural and physical heritage are presented in
Table 10.12-10, along with mitigation proposed by Métis Local 1935 in their TLU study (Willow Springs
2014) and CIA (Willow Springs 2015), and mitigation that Teck has committed to implement to reduce
these potential effects.
The mitigation proposed by Métis Local 1935 in their TLU study and CIA may not be reflected, as
articulated by Métis Local 1935, in the mitigation measures outlined in Table 10.12-10, for one or more of
the following reasons:
The mitigation measure proposed by Métis Local 1935 is directly or indirectly reflected in one or
more mitigation measures outlined by Teck
The mitigation measure proposed by Métis Local 1935 is beyond the scope of what a single
proponent can mitigate
The mitigation measure proposed by Métis Local 1935 is within the scope of activities that Teck
and Métis Local 1935 will undertake as part of implementing a Participation Agreement
(discussed below).
In 2017, Teck and Métis Local 1935 entered into a Participation Agreement for the Project. Teck’s
mitigation plans for the Project will be further discussed with Métis Local 1935 as part of joint Participation
Agreement implementation efforts.
Frontier Oil Sands Mine Project Appendix 10.12
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Table 10.12-10: Potential Adverse Environmental Effect and Mitigation Table – Fort McMurray Métis Local 1935 (Métis Local 1935)
Potential Adverse Effects Mitigation Proposed by Métis Local 1935
in TLU Study and CIA Mitigation Teck Commits to Implement
Hydrology and Water Quality
Changes in flows, water levels and open water areas
None. The Athabasca River will satisfy the Project’s makeup water requirements, and an off-stream storage pond (OSSP) will supply the Project with water during periods when river water withdrawal is restricted (see the response to Joint Review Panel (JRP) Information Request (IR) 10.26, Appendix 10.26, Section 7.1).
Teck commits to implement the following mitigation measures to reduce changes in flows and water levels in receiving waterbodies (see the response to JRP IR 10.25, Appendix 10.25, Table 10.25-1):
Reduce changes to flows in Ronald Lake by using a flow splitter on the Redclay Creek diversion during operations.
Reduce changes to flows in Big Creek by using a flow splitter on the Big Creek diversion during operations.
Distribute muskeg drainage operations through the mine life, thereby avoiding a large increase in flows in the receiving waters.
Reduce effects of closed-circuit operations on flows and water levels in receiving waters by diverting natural watercourses that will not be disturbed by the mining operations around the mining area to receiving watercourses.
Reduce river-water withdrawal requirements from the Athabasca River by maximizing closed-circuit recycling of surface and groundwater where practical, and by storing sufficient amounts of water in an off-stream storage pond in the event of extended withdrawal restrictions from the Athabasca River.
Progressively construct and develop diversion systems, which helps limit the change in open-water areas during construction and operation by providing new drainage channels to replace the loss of natural watercourses and waterbodies.
Reduce changes to flows and water levels in receiving waters by developing a closure drainage layout that will limit changes in drainage areas contributing flows to the receiving watercourses relative to predevelopment conditions.
Design watercourses, waterbodies and wetlands during reclamation to attenuate floods.
Teck is committed to continue to consult meaningfully with, and engage, all potentially affected Indigenous groups at both a Project-specific and regional level to reduce and mitigate potential Project and cumulative effects on hydrology and surface water quality, including continuing discussions regarding hydrology and surface water quality concerns and is prepared to consider additional mitigation measures to address these concerns (see the response to JRP IR 10.25, Appendix 10.25).
Teck has developed a Draft Hydrology and Water Quality Mitigation, Monitoring and Adaptive Management Plan (see the response to JRP IR 10.25, Appendix 10.25). Once finalized, the plan will include a communication management section, which will outline how findings of the program will be communicated to interested parties.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Changes in sediment yields, concentrations and channel regimes (geomorphology)
None. Teck commits to implement the following mitigation measures to limit release of Total Suspended Solids (TSS) (see the response to JRP IR 10.25, Appendix 10.25, Table 10.25-1):
Follow relevant regulatory guidelines, standards and best management practices during construction and operation to reduce the risk of increased sediment loadings to receiving watercourses.
Construct and operate sedimentation ponds to settle TSS where necessary.
Control sediment generation in diversion channels through revegetation of streambanks, overbank areas and berms as soon as possible after construction and by the use of channel armour (riprap), where required.
Direct muskeg and overburden drainage waters to polishing ponds equipped with oil-separation capability.
Reduce sediment yields from reclaimed surfaces by developing appropriate final topography and soil moisture conditions.
Resuspension of sediments from the bottom of polishing ponds, wetlands and pit lakes will be reduced through appropriate hydraulic design.
Reduce gullying and channel erosion by developing robust and sustainable reclamation drainage systems with built-in self-healing capability and robustness similar to natural drainage systems.
Teck commits to implement the following mitigation measures to reduce changes in flood flows and geomorphology downstream of the Project (see the response to JRP IR 10.25, Appendix 10.25, Table 10.25-1):
Limit changes in flood flows in receiving watercourses relative to predevelopment conditions. Mitigation measures listed for the “reduce changes in flows and water levels” above are relevant for mitigating flood flows.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Direct water emissions:
Muskeg drainage and overburden dewatering flows
Drainage from operating and reclaimed mine site
Basal water sands depressurization
Process-affected seepages from backfilled mine pits and tailings disposal areas
None. Teck commits to implement the following mitigation measures to limit the release of ions, nutrients, metals, polycyclic aromatic hydrocarbons (PAHs) and other parameters during operations and closure and protect sediment quality in downstream watercourses and waterbodies (see the response to JRP IR 10.25, Appendix 10.25, Table 10.25-1):
Recycle process-affected waters and runoff within the Project disturbance area (PDA) in a closed-circuit system during operations.
Using a perimeter ditch and groundwater wells to capture and pump back seepages and runoff from the external tailings areas (ETAs) back into the tailings areas during operations.
Design the closure drainage system to capture seepage and runoff from ETAs, external disposal areas (EDAs) and the Frontier Project plant site and directing it to wetlands, pit lakes or constructed reclamation lakes during the mine closure management phase.
Use wetlands, constructed reclamation lakes and pit lakes during and after the decommissioning and closure phases to provide biological remediation and settling of particulate materials in reclamation waters before discharge.
Respond to spills using best management practices. Project activities will follow safety protocols designed to limit accidents and reduce effects if an accident should occur.
Teck commits to the following mitigation measures to manage depressurization water during preproduction (see Volume 1, Section 7.6.5 and 7.8.4 of the Project Update):
Teck plans to manage depressurization water during preproduction by storing approximately half of it in a storage pond at surface and reinjecting the remaining half into the BWS aquifer.
Teck is committed to continue to consult meaningfully with, and engage, all potentially affected Indigenous groups at both a Project-specific and regional level to reduce and mitigate potential Project and cumulative effects on hydrology and surface water quality, including continuing discussions regarding hydrology and surface water quality concerns and is prepared to consider additional mitigation measures to address these concerns (see the response to JRP IR 10.25, Appendix 10.25).
Teck has developed a Draft Hydrology and Water Quality Mitigation, Monitoring and Adaptive Management Plan (see the response to JRP IR 10.25, Appendix 10.25). Once finalized, the plan will include a communication management section, which will outline how findings of the program will be communicated to interested parties.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Pit lake releases None. Teck will leverage the knowledge gained through its other reclamation efforts, along with research through regional initiatives such as Canada’s Oil Sands Innovation Alliance (COSIA), to develop healthy,
Frontier Oil Sands Mine Project Appendix 10.12
Table 10.12-10: Potential Adverse Environmental Effect and Mitigation Table – Fort McMurray Métis Local 1935 (Métis Local 1935) (continued)
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functional ecosystems in the Project pit lakes (see the response to JRP IR 2.3).
Teck also commits to implement the following mitigation measures when designing closure drainage and pit lakes for hydrological sustainability and to promote effective passive treatment of process-affected waters and to support a viable aquatic ecosystem prior to release and to sequester tailings and other mine waste in the most appropriate location at mine closure (see the response to JRP IR 10.25, Appendix 10.25, Table 10.25-1):
Exclude tailings from pit lakes.
Do not release water from pit lakes until acceptable quality is achieved.
Maintain the water balance of the pit lakes with sufficient inflows to compensate for evaporative losses.
Manage the rate of Athabasca River water input to pit lakes as appropriate to confirm water quality filling targets are met and to comply with Athabasca river low flow restrictions.
Include wetlands reclamation lakes for treatment purposes in reclamation drainages to the pit lakes.
Teck is committed to continue to consult meaningfully with, and engage, all potentially affected Indigenous groups at both a Project-specific and regional level to reduce and mitigate potential Project and cumulative effects on hydrology and surface water quality, including continuing discussions regarding hydrology and surface water quality concerns and is prepared to consider additional mitigation measures to address these concerns (see the response to JRP IR 10.25, Appendix 10.25).
Teck has developed a Draft Hydrology and Water Quality Mitigation, Monitoring and Adaptive Management Plan (see the response to JRP IR 10.25, Appendix 10.25). Once finalized, the plan will include a communication management section, which will outline how findings of the program will be communicated to interested parties.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Changes in quality of groundwater and surface water downgradient of EDAs
None. Teck commits to implement the following mitigation measures to maintain surface water quality in consideration of surface flows into and out of the Project area and groundwater discharge (see the response to JRP IR 10.25, Appendix 10.25, Table 10.25-1):
Groundwater and surface waters draining EDAs will be captured if monitoring data indicate that the drainage waters are unsuitable for release.
Teck is committed to continue to consult meaningfully with, and engage, all potentially affected Indigenous groups at both a Project-specific and regional level to reduce and mitigate potential Project and cumulative effects on hydrology and surface water quality, including continuing discussions regarding hydrology and surface water quality concerns and is prepared to consider additional mitigation measures to address these concerns (see the response to JRP IR 10.25, Appendix 10.25).
Teck has developed a Draft Hydrology and Water Quality Mitigation, Monitoring and Adaptive Management Plan (see the response to JRP IR 10.25, Appendix 10.25). Once finalized, the plan will include a communication management section, which will outline how findings of the program will be communicated to interested parties.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Air Quality and Odour
NOX emissions
None.
Teck commits to implement the following mitigation measures to reduce NOX emissions from combustion sources (see the response to JRP IR 3.18, Table 3.18-1):
Use natural gas as a fuel for the cogeneration plant and boilers and heaters.
Dry low NOX technology to reduce NOX emissions and increase cogeneration plant efficiency.
Boiler and heater technology that will meet provincial and federal government emission requirements.
Purchase Tier IV compliant haul trucks when they become available.
Optimize mine planning to reduce haul distances.
Develop and implement an anti-idling program for the mine fleet.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
SO2 emissions None. Teck commits to implement the following mitigation measures to reduce SO2 emissions from combustion sources (see the response to JRP IR 3.18, Table 3.18-1):
Use natural gas as a fuel for the cogeneration plant and boilers and heaters.
Use ultra-low sulphur diesel for the mine fleet.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
PM2.5 and dust emissions None. Teck commits to implement the following mitigation measures to reduce PM2.5 emissions from combustion sources (see the response to JRP IR 3.18, Table 3.18-1):
Use natural gas as a fuel for the cogeneration plant and boilers and heaters.
Boiler and heater technology that will meet provincial and national government emission requirements.
Purchase Tier IV compliant haul trucks when they become available.
Optimize mine planning to reduce haul distances.
Develop and implement an anti-idling program for the mine fleet.
Teck commits to implement the following mitigation measures to reduce fugitive dust emissions (see the response to JRP IR 3.18, Table 3.18-1):
Dust mitigation measures to be applied to onsite roads during construction include appropriate selection of road materials, limiting vehicle speeds, surface watering, progressive reclamation, temporary vegetation of disturbed land and retain natural vegetation as windbreaks.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Hydrocarbon and reduced sulphur emissions and secondary organic aerosol precursor emissions
None. Teck commits to implement the following mitigation measures to reduce fugitive plant emissions (see the response to JRP IR 3.18, Table 3.18-1):
Use floating roof tanks where appropriate and a vapour recovery system to condense and recover vapours from storage tanks and process areas.
Use dual solvent vapour recovery units to provide full redundancy.
Conduct a leak detection and repair (LDAR) program to identify leaking components and to prioritize associated repairs.
Teck commits to implement the following mitigation measures to reduce fugitive mine face emissions (see the response to JRP IR 3.18, Table 3.18-1):
Frontier Oil Sands Mine Project Appendix 10.12
Table 10.12-10: Potential Adverse Environmental Effect and Mitigation Table – Fort McMurray Métis Local 1935 (Métis Local 1935) (continued)
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Mitigation not currently known.
Teck commits to implement the following mitigation measures to reduce fugitive tailings area emissions (see the response to JRP IR 3.18, Table 3.18-1):
Tailing solvent recovery unit to maintain losses to less than four volumes of solvent to 1,000 volumes of bitumen produced.
Teck commits to implement the following mitigation measures to reduce hydrocarbon and reduced sulphur emissions from combustion sources (see the response to JRP IR 3.18, Table 3.18-1):
Use natural gas as a fuel for the cogeneration plant and boilers and heaters.
Purchase Tier IV compliant haul trucks when they become available.
Optimize mine planning to reduce haul distances.
Develop and implement an anti-idling program for the mine fleet.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Odour None Teck has developed a draft Odour Management and Response Plan (see the response to JRP IR 3.13, Appendix 3.13). The draft Plan. The Plan’s goals are mitigation, monitoring, participation in regional complaint process, and correlation of complaints to Project activities to determine response actions. The Plan will be finalized following consultation with Indigenous communities, regulators and stakeholders.
At any time during Project operation, nearby residences will be able to contact Teck if they are concerned that Project operations are causing odours. The contact will be documented, investigative action will be initiated to determine the potential source, and the caller will be notified. If a source can be identified, a review will be undertaken to implement corrective action to reduce the potential for future occurrences (ERCB Round 1 SIR 113a; Appendix 3.13).
Acoustics
Change in sound levels None. Teck has made an overall commitment to managing and promptly addressing all noise-related concerns (see Volume 3, Section 3.4.9.2, Project Update) and will develop a Noise Management Plan (see Volume 3, Section 3.4.9.1, Project Update).
Teck also commits to implement the following mitigation measures to reduce changes in sound levels (see Volume 3, Appendix 17H, Section 17H.5 of the Project Update and the response to JRP IR 1.3, Table 1.4-1):
Vehicles will be maintained in good working condition (e.g., mufflers will be maintained) and speed limits will be enforced.
Emergency alarms will be tested during daytime, where reasonably practical.
Acoustic performance of building wall construction will meet a minimum sound transmission class (STC) rating of 29, based on published data in the North American Insulation Manufacturers Association for a pre-engineered structure.
For outdoor equipment, the manufacturer incorporates mitigation in the equipment design to achieve the published sound power level.
Noise effects will be mitigated using various measures, including but not limited to the following:
o haul trucks exhaust silencer
o haul truck speed
o trip frequency (number of trips per daytime and nighttime period)
o route location or alignment
Ventilation openings (i.e., air intake and exhaust openings) will be fitted with appropriate acoustic silencers, louvers, or plenums, where applicable, to reduce outdoor sound transmission from indoor equipment.
Buildings housing indoor noise-generating equipment will be appropriately sealed to reduce noise.
Where practical, flanking path and penetrations from plumbing, heating ducts and electrical wire in the buildings will be properly insulated and covered to reduce noise.
Appropriate acoustical lagging will be installed to provide additional attenuation to the steel casing, where practical.
Vibration isolation pads, resilient mounts on equipment, resilient pipe support systems, and dampers will be installed where appropriate.
Teck will incorporate best management practices to reduce Project-related noise into Daily Operational Procedures, Long-Term Operational Procedures, design for low-noise facilities, and performance measurement as described in SPOG (2012) Best Practices Document, where appropriate (ERCB Round 1 SIR 116; Volume 3, Section 3.4.9.1 of the Project Update), including:
Daily Operational Procedures
Keeping compressor station doors and windows closed
Using belt dressing
Inspecting and repairing mufflers
Running fans slower at night (variable frequency drive [VFD])
Using vent silencers on buildings
Using soundproofing (insulation and lagging)
Troubleshooting transient noise
Minimizing flaring and venting
Considering gravel pack around compressor building skids
Developing noise check in daily reading sheets
Long-Term Operational Procedures
Responding quickly to noise concerns
Establishing baseline noise levels (in plant, at fence-line, or both) and resurvey to determine trends
Conducting regular assessment of noise control opportunities
Using best practical technology for noise control
Frontier Oil Sands Mine Project Appendix 10.12
Table 10.12-10: Potential Adverse Environmental Effect and Mitigation Table – Fort McMurray Métis Local 1935 (Métis Local 1935) (continued)
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Maintaining communication links with noise sensitive receptors and communities
Being aware of noise from contractors (e.g., service rigs) and developing processes to meet best practice expectations
Scheduling work to create the least amount of noise effects on noise sensitive receptors and keeping those affected informed
Design for Low Noise Facilities
Considering low noise electric drives versus engine driven compressors
Designing cooler fans for low tip velocity
Orienting noise sources away from residents
Using acoustical pipe lagging
Installing VFDs on coolers
Performance Measurement
Conducting measurements and establishing baseline data
Using best practices as part of the company’s operating procedures
Visual
Change to visual environment None. Teck commits to implement the following mitigation measures to reduce changes to visual effects (see Volume 1, Section 8.3.6, Volume 3, Section 16.4.6, Volume 3, Section 18.10.4.2, Volume 3, Section 18.11.5.4 and Volume 3, Appendix 17H, Section 17H.7 of the Project Update):
Maintaining vegetated buffers between the Project and the Athabasca River as well as along Project transportation corridors to the extent feasible where safety concerns are not an issue.
Using construction materials that reduce contrast, limit visual attraction to Project features, and blending built structures into the natural surrounding environment.
Using construction materials, where practicable, that minimize light reflection, potentially reducing viewing distances of Project features
Reclamation techniques will be used that integrate closure plans with the surrounding landscape.
Teck will seek to develop closure plans that:
o Include integration and contouring of slopes that mimic natural topography.
o Focus on establishing a variety of vegetation communities.
o Avoid unnatural-looking breaks at development boundaries.
Planting a narrow band of white spruce along the edge of the river water intake (RWI) cofferdam and plant dogwood on the cofferdam, except in areas where tall vegetation would impede any maintenance or present safety concerns.
Completing reclamation in the RWI area to minimize erosion and slope instability.
Using lighting that minimizes light pollution.
At closure, infrastructure will be removed and the Project will be reclaimed using vegetation types similar, though not identical to existing conditions, creating a continuous vegetated landscape.
A lighting plan will be developed during future stages of engineering to avoid over-illumination. Lighting design will be part of future stages of engineering, and Teck will consult with interested Indigenous communities about lighting considerations.
Finish the Athabasca River Bridge with low-glare materials and plant vegetation buffers near the bridge. Teck also commits to clear minimal vegetation and to vegetate cleared areas.
Retain treed buffers around or near watercourses.
Fish and Fish Habitat
Change in productive
fish habitat
None. Fish habitat of equivalent or higher productivity than that affected by the Project will be created through offsetting measures where prevention of adverse habitat alteration or loss (i.e., reduced habitat productivity or loss of productive habitat area) is not feasible (see the draft Detailed Fisheries Offsetting Plan, the response to JRP IR 2.1, Appendix 2.1).
Teck also commits to implement the following mitigation measures to avoid or reduce changes in fish habitat quantity or quality (see the response to JRP IR 2.1, Table 5):
To avoid or reduce sedimentation:
o Temporary and permanent erosion and sediment control measures for construction activities and disturbed areas.
o Stabilization and revegetation of disturbed areas.
o Isolation of instream work areas where they are required.
o Best management practices and regulatory guidelines for construction activities in and near watercourses/waterbodies for erosion and sediment control.
o Polishing ponds or other measures to reduce suspended sediment concentrations in discharge waters to avoid increases in sedimentation in the receiving environment.
o Appropriate design of constructed channels and ponds to reduce internal erosion and generation of suspended sediments.
o Appropriate design and construction of reclaimed landscape to reduce sediment yield.
To avoid or reduce changes to water quality:
o Passing muskeg drainage and overburden water through polishing ponds and drainage ditches to reduce changes in water temperatures and dissolved oxygen concentrations.
o Recycling of process affected waters during operations.
o Capture and recycling of ETA seepage and run off water during operations, and use of a passive seepage control system at closure.
o Use of wetlands, pit lakes and constructed reclamation lakes in the closure drainage system to provide biological remediation before release to the environment.
o Removal of organic material from fish habitat compensation lake (FHCL) area prior to flooding.
To avoid or reduce changes to habitat area:
o Diversion of watercourses around the PDA to return natural upslope water back to the diverted watercourse to preserve flows and avoid elimination of downstream habitats.
o Provision of a flow splitter on the diversion channel that will collect water from both upper Redclay Creek and Unnamed Creek 17 to appropriately apportion the flows in lower Redclay Creek and Unnamed Creek 17 to avoid flow changes in the Ronald Lake watershed.
o Operation of the RWI and Off Stream Storage Pond (OSSP) in compliance with the Lower Athabasca River Surface Water Quantity Management Framework.
o Design of the closure drainage channels and pit lakes to provide habitats capable of supporting aquatic ecosystems.
Frontier Oil Sands Mine Project Appendix 10.12
Table 10.12-10: Potential Adverse Environmental Effect and Mitigation Table – Fort McMurray Métis Local 1935 (Métis Local 1935) (continued)
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o Best management practices and regulatory guidelines to ensure construction and operation of the RWI, Athabasca River bridge and watercourse crossings associated with access roads do not interfere with fish passage and access to available habitats.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Change in fish abundance Restrict fishing activities among camp staff and employees with the exception of Métis community members/employees (Willow Springs 2014, p.48).
Teck commits to implement the following mitigation measures to avoid or reduce changes in fish abundance (see the response to JRP IR 2.1, Table 5):
Fish rescue operations to capture and relocate fish prior to habitat dewatering.
Screening of the RWI in compliance with regulatory guidelines to mitigate fish entrainment or impingement.
Best management practices and regulatory guidelines for scheduling construction activities in and near waterbodies/watercourse to avoid sensitive time periods in adjacent or downstream fish-bearing watercourses.
Education of Project personnel on sustainable fishing practices to support a Teck applied prohibition on their fishing in watercourses or waterbodies in the PDA to mitigate potential increases in recreational fishing pressure.
Access Management Plan for the PDA to limit access to fish bearing habitats to mitigate increased fishing pressure.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Change in fish and fish habitat diversity
Restrict fishing activities among camp staff and employees with the exception of Métis community members/employees (Willow Springs 2014, p.48).
Teck commits to implement the following mitigation measures to avoid or reduce changes in fish and fish habitat diversity (see the response to JRP IR 2.1, Table 5):
Several of the measures intended to avoid or mitigate effects to fish habitat and fish abundance also apply to fish and fish habitat diversity, in cases where they preserve fish and productive fish habitats or create new habitats, including:
o Diversions designed to preserve flows and avoid elimination of downstream habitats.
o Closure drainage channels and pit lakes designed to provide habitats capable of supporting aquatic ecosystems.
o Fish rescue operations.
o Screening of the RWI.
o Education and prohibition of Project personnel from fishing in the PDA.
o Access Management for the PDA to limit access to fish bearing habitats.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Wildlife
Change in wildlife habitat availability Develop a more active and aggressive Caribou habitat protection plan, including caribou population recovery efforts (Willow Springs 2014, p.24).
Share local knowledge of caribou habitat to promote landscape level habitat protection (Willow Springs 2014, p.45).
Cooperate with Alberta Caribou Protection Planning and implementation (Willow Springs 2014, p.48).
Teck commits to implement the following mitigation measures to reduce direct habitat loss (see the response to JRP IR 7.14, Table 7.14-1):
Limit the size of the east side access road right-of-way (ROW) and temporary workspace to the extent practical.
Limit the Athabasca River bridge footprint in riparian areas.
Carry out progressive reclamation to reclaim disturbed wildlife habitat as portions of the mine footprint become available.
Develop a weed management plan.
Teck commits to implement the following mitigation measures to reduce indirect habitat loss (see the response to JRP IR 7.14, Table 7.14-1):
Implement strategies to reduce noise and light effects, including design considerations (e.g., Frontier Project plant site engineering and aerodrome operation within regulatory and safety constraints).
Limiting employee and contractor access to identified areas of high-quality habitat adjacent to Project footprint.
Teck commits to developing a Biodiversity Management Plan (BMP) with the underlying goal of optimizing reclamation during operations to reduce offsetting of residual environmental effects (see the response to JRP IR 7.15).
Teck has developed a Draft Wildlife Mitigation, Monitoring and Adaptive Management Plan (WMMP; see the response to JRP IR 7.14, Appendix 7.14). Teck has proposed steps to Indigenous groups that would provide the opportunity for land users and community members to provide direct input into developing wildlife mitigation measures. Input will refine this draft WMMP. Once finalized, the plan will include a communication management section, which will outline how findings of the program will be communicated to interested parties.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Change in wildlife landscape connectivity
Fund Project-specific Métis Environmental Knowledge Assessment to determine pre-development baselines for terrain suitability for subsistence harvesting of large animals and fur-bearers (Willow Springs 2014, p.48).
Teck commits to implement the following mitigation measures to reduce change to landscape connectivity (see the response to JRP IR 7.14, Table 7.14-1):
Carry out progressive reclamation to restore habitat for movement as portions of the mine footprint become available.
To maintain connectivity between Birch Mountains and Athabasca River:
o Coordinate development activities with Canadian Natural Resources Limited (CNRL) who acquired the Pierre River Mine oil sands leases formerly held by Shell Canada Limited should CNRL reapply for and develop the Pierre River Mine project.
o Develop an integrated land management strategy for the Project in consultation with industry, the province, Indigenous communities, and stakeholders.
Provide wildlife passage under both sides of the Athabasca River bridge and river water intake bridge to Dalkin Island to allow north–south wildlife movement along river banks using crossing design considerations (e.g., bridge height and length) outlined in Clevenger and Huijser (2011) and GOA (2011).
Set up educational signage to limit human use of wildlife underpasses.
Evaluate wing fencing along the approach to crossing passages (at least 2.4 m high for large mammals as per GOA 2011) as part of the crossing structure design.
Provide appropriate walking substrate along the wildlife underpass.
Create vegetated buffers adjacent to wildlife underpasses to increase movement opportunities for a variety of species.
Provide coarse woody debris (e.g., stumps) along the wildlife underpass to provide cover and increase use by furbearers and other small mammals.
Teck has developed a Draft WMMP (see the response to JRP IR 7.14, Appendix 7.14). Teck has proposed steps to Indigenous groups that would provide the opportunity for land users and community members to provide direct input into developing wildlife mitigation measures. Input will refine this draft WMMP. Once finalized, the plan will include a communication management section, which will outline how findings of the program will be communicated to interested parties.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Frontier Oil Sands Mine Project Appendix 10.12
Table 10.12-10: Potential Adverse Environmental Effect and Mitigation Table – Fort McMurray Métis Local 1935 (Métis Local 1935) (continued)
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Change in wildlife mortality risk Restrict hunting activities among camp staff and employees with the exception of Métis community members/employees (Willow Springs 2014, p.47).
Inform Métis Local 1935 of potential land use conflicts between the Project and licensed commercial outfitters and hunters within Project-related Wildlife Management Units (Willow Springs 2014, p.49).
Teck commits to implement the following mitigation measures to reduce wildlife mortality risk resulting from vehicle–wildlife collisions (see the response to JRP IR 7.14, Table 7.14-1):
Implement fly-in/fly-out policy for workers to reduce vehicular traffic volume.
Erect wildlife cautionary signage on access roads.
Foster environmental awareness with speed restrictions on access roads report Project-related wildlife fatalities.
Provide vegetation maintenance at roadsides (vegetation will be trimmed regularly to discourage roadside foraging and prevent visual obstruction of wildlife).
Develop seed mixes for roadside reclamation from less palatable species to reduce wildlife attraction to road edges.
Design the road to maximize line of sight.
Remove road kill as soon as practical.
Teck commits to implement the following mitigation measures to reduce wildlife mortality risk resulting from wildlife interactions with equipment (see the response to JRP IR 7.14, Table 7.14-1):
Implement preconstruction surveys for active wildlife habitat features (e.g., nests, breeding wetlands) before starting early works.
Avoid vegetation clearing during the recommended May 1 to August 10 migratory bird-breeding period for the boreal ecozone per Environment Canada guidelines; note that in species at risk habitat, a more conservative breeding window of April 1 to August 31 might apply (Gregoire 2014, pers. comm.); complete nest surveys if clearing activities occur during the breeding window.
Conduct owl nest search if clearing is scheduled within the non-migratory breeding bird window, March 1 to April 15 (based on Enhanced Approval Process guidelines for barred owl, GOA 2013).
Reduce on disturbance of amphibian breeding and overwintering habitat (where possible).
Teck commits to implement the following mitigation measures to reduce wildlife mortality risk resulting from interactions with Infrastructure (see the response to JRP IR 7.14, Table 7.14-1):
Create fuel and chemical spill contingency and response plans.
Confirm adequate spill protection for all fuel storage facilities.
Monitor and maintain waste disposal sites, wastewater storage areas and runoff control structures to prevent surface water impacts.
During overburden dewatering, intermittently backslope the sides of drainage ditches to allow for wildlife crossings and to reduce the potential for entrapment.
Use visible markers, such as aviation spheres and spiral vibration dampeners to make transmission lines near waterfowl staging and potential stopover areas more visible to birds, and where possible, design transmission lines to match the height of surrounding trees to reduce wire strikes by birds.
Teck commits to implement the following mitigation measures to reduce wildlife mortality risk resulting from wildlife–human conflicts (see the response to JRP IR 7.14, Table 7.14-1):
Implement a food waste-management strategy to prevent attraction of nuisance wildlife.
Confirm wildlife is not harassed or fed (to prevent habituation).
Provide wildlife awareness training to Project staff and contractors to reduce disturbance and negative human/bear interactions.
Provide all field staff with bear-aware training courses, personal protective equipment (e.g., bear spray, bear bangers, air horns) and training on proper use of equipment.
Develop a nuisance wildlife mitigation and monitoring plan in cooperation with the regulators.
Teck commits to implement the following mitigation measures to reduce wildlife mortality risk resulting from increased hunter access (see the response to JRP IR 7.14, Table 7.14-1):
Implement deactivation plans for roads no longer in use.
Prohibit construction and operations personnel and contractors from hunting and trapping while working.
Disallow personal recreational vehicle use onsite.
Prohibit firearms on Project lands or at Project facilities.
Consider requesting a Directors Order to limit public access to the west side of the Athabasca River along Project roads.
Teck has developed a Draft WMMP (see the response to JRP IR 7.14, Appendix 7.14). Teck has proposed steps to Indigenous groups that would provide the opportunity for land users and community members to provide direct input into developing wildlife mitigation measures. Input will refine this draft WMMP. Once finalized, the plan will include a communication management section, which will outline how findings of the program will be communicated to interested parties.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Waterfowl
Change in bird mortality risk
None. Teck commits to implement the following mitigation measures to reduce migratory water bird mortality risk resulting from the use of ponds (see the response to JRP IR 7.10, Table 7.10-1):
Develop detailed construction and operational procedures and mitigation measures to reduce wildlife mortality during tailings area start-up.
Design the sides of wastewater ponds to reduce attractiveness to birds (e.g., using gravel for sides).
Clear trees and above-ground vegetation including shrubs, herbs and the ground layer prior to placement of tailings into tailings disposal areas.
Remove peat from tailings area prior to flooding.
Develop detailed construction and operational procedures and mitigation measures to reduce wildlife mortality during tailings area start-up.
Reduce attractiveness of tailings areas for birds by keeping the inner walls of the tailings dyke free of vegetation.
Keep slopes of tailings areas as steep as possible to reduce “black beach” areas.
Implement procedure for removing any peat mats that float to the surface of the tailings area.
Implement procedure for controlling floating bitumen mats.
Manage the use and operation of anthropogenic lighting around wastewater ponds and tailings areas.
Bird deterrent systems will be used to discourage birds from landing on wastewater ponds and tailings areas.
Teck commits to implement the following mitigation measure to reduce the potential for birds to land in ponds containing process-affected water (see the response to ESRD/CEAA Round 3 SIR 64):
Bird deterrent systems will be installed on all ponds associated with the Project that have process-affected water that could be detrimental to birds.
Teck commits to implement the following mitigation measures to maximize recovery efficiency should birds use ponds (see the response to JRP IR 7.10, Table 7.10-1):
Frontier Oil Sands Mine Project Appendix 10.12
Table 10.12-10: Potential Adverse Environmental Effect and Mitigation Table – Fort McMurray Métis Local 1935 (Métis Local 1935) (continued)
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Develop procedure for handling of any bird recovered from wastewater ponds or tailings areas.
Procedure will be in compliance with directions received from the local Alberta Fish and Wildlife office and/or the Alberta Environment and Parks (AEP) wildlife biologist.
Procedure will also be in compliance with directions from Environment and Climate Change Canada with respect to whooping cranes.
Teck commits to implement the following mitigation measures to reduce the potential for bird mortality risk resulting from interaction with transmission and distribution lines (see the response to JRP IR 7.10, Table 7.10-1):
Designing transmission and distribution lines, where possible, to match the height of surrounding trees to reduce wire strikes by birds.
Marking of transmission and distribution lines in areas near waterfowl staging and potential stopover areas.
Teck has developed a Draft Waterfowl Protection Plan (see the response to JRP IR 7.10, Appendix 7.10). Teck will continue to pursue collaborative engagement processes, as outlined in the WMMP for the Project as the primary mechanism in which it will engage with potentially affected Indigenous groups regarding the Waterfowl Protection Plan. Once finalized, the plan will include a communication management section, which will outline how findings of the program will be communicated to interested parties.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Bison
Change in bison habitat availability None. Teck commits to implement the following mitigation measures to reduce direct habitat loss (see the response to JRP IR 7.5, Table 7.5-1):
Limit the size of the east side access road right-of-way (ROW) and temporary workspace to the extent practical.
Limit the Athabasca Rive bridge footprint in riparian areas.
Carry out progressive reclamation to reclaim disturbed wildlife habitat as portions of the mine footprint become available.
Develop a weed management plan.
Teck commits to implement the following mitigation measures to reduce indirect habitat loss (see the response to JRP IR 7.5, Table 7.5-1):
Implement strategies to reduce noise and light effects, including design considerations (e.g., Frontier Project plant site engineering and aerodrome operation within regulatory and safety constraints).
Limiting employee and contractor access to identified areas of high-quality habitat adjacent to Project footprint.
Teck has developed a Draft Ronald Lake Bison Mitigation, Monitoring and Adaptive Management Plan (see the response to JRP IR 7.5, Appendix 7.5). Teck has proposed steps to Indigenous groups that would provide the opportunity for land users and community members to provide direct input into developing wildlife mitigation measures, including those specific to bison. Once finalized, the plan will include a communication management section, which will outline how findings of the program will be communicated to interested parties.
Teck will also work with the responsible authority to explore possible mitigations for which Teck does not have the authority to implement independently.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Change in bison landscape connectivity
None. Teck commits to implement the following mitigation measures to reduce change to landscape connectivity (see the response to JRP IR 7.5, Table 7.5-1):
Carry out progressive reclamation to restore vegetated corridors as portions of the mine footprint become available.
To maintain connectivity between Birch Mountains and Athabasca River:
o Coordinate development activities with Canadian Natural Resources Limited (CNRL) who acquired the Pierre River Mine oil sands leases formerly held by Shell Canada Limited should CNRL reapply for and develop the Pierre River Mine project.
o Develop an integrated land management strategy for the Project in consultation with industry, Indigenous stakeholders and the Province.
Provide wildlife passage under both sides of the Athabasca River bridge and river water intake bridge to Dalkin Island to allow north–south wildlife movement along river banks using crossing design considerations (e.g., bridge height and length) outlined in Clevenger and Huijser (2011) and GOA (2011):
o Set up educational signage to limit human use of wildlife underpasses.
o Evaluate wing fencing along the approach to crossing passages (at least 2.4 m high for large mammals as per GOA 2011) as part of the crossing structure design.
o Provide appropriate walking substrate along the wildlife underpass.
o Create vegetated buffers adjacent to wildlife underpasses to increase movement opportunities for a variety of species.
Teck has developed a Draft Ronald Lake Bison Mitigation, Monitoring and Adaptive Management Plan (see the response to JRP IR 7.5, Appendix 7.5). Teck has proposed steps to Indigenous groups that would provide the opportunity for land users and community members to provide direct input into developing wildlife mitigation measures, including those specific to bison. Once finalized, the plan will include a communication management section, which will outline how findings of the program will be communicated to interested parties.
Teck will also work with the responsible authority to explore possible mitigations for which Teck does not have the authority to implement independently.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Change in bison mortality risk None. Teck commits to implement the following mitigation measures to reduce bison mortality risk resulting from vehicle–bison collisions (see the response to JRP IR 7.5, Table 7.5-1):
Implement fly-in/fly-out policy for workers to reduce vehicular traffic volume.
Erect wildlife cautionary signage on access roads.
Foster environmental awareness with speed restrictions on access roads, report Project-related wildlife fatalities.
Provide vegetation maintenance at roadsides (vegetation will be trimmed regularly to discourage roadside foraging and prevent visual obstruction of wildlife).
Develop seed mixes for roadside reclamation from less palatable species to reduce wildlife attraction to road edges.
Design the road to maximize line of sight.
Teck commits to implement the following mitigation measures to reduce bison mortality risk resulting from bison-human interactions - interactions with infrastructure (see the response to JRP IR 7.5, Table 7.5-1):
Create fuel and chemical spill contingency and response plans.
Confirm adequate spill protection for all fuel storage facilities.
Frontier Oil Sands Mine Project Appendix 10.12
Table 10.12-10: Potential Adverse Environmental Effect and Mitigation Table – Fort McMurray Métis Local 1935 (Métis Local 1935) (continued)
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Monitor and maintain waste disposal sites, wastewater storage areas and runoff control structures to prevent contamination of surface waters.
During overburden dewatering, intermittently backslope the sides of drainage ditches to allow for wildlife crossings and to reduce the potential for entrapment.
Teck commits to implement the following mitigation measures to reduce bison mortality risk resulting from hunter access (see the response to JRP IR 7.5, Table 7.5-1):
Construct predator access blocks to deter predator use (i.e., reduce line of sight) on linear features in the PDA that may leave core bison areas susceptible to predation.
Deactivate roads in the PDA no longer in use.
Implement employee / contractor policies to prohibit hunting within the Project area.
Reduce linear features in the closure landscape.
Reduce width of linear features in the closure landscape.
Teck commits to implement the following mitigation measures to reduce bison mortality risk resulting from disease transmission to the Ronald Lake bison herd (see the response to JRP IR 7.5, Table 7.5-1):
Implement progressive reclamation in the PDA to create suitable Ronald Lake bison habitat and reduce the potential of shifting habitat use northward.
Mitigations associated with reducing hunter and predator access.
Mitigations associated with reducing wildlife human conflict.
Mitigations associated with reducing indirect habitat loss.
Teck has developed a Draft Ronald Lake Bison Mitigation, Monitoring and Adaptive Management Plan (see the response to JRP IR 7.5, Appendix 7.5). Teck has proposed steps to Indigenous groups that would provide the opportunity for land users and community members to provide direct input into developing wildlife mitigation measures, including those specific to bison. Once finalized, the plan will include a communication management section, which will outline how findings of the program will be communicated to interested parties.
Teck will also work with the responsible authority to explore possible mitigations for which Teck does not have the authority to implement independently.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Vegetation
Change in vegetation Document and preserve native plant species, hydrology and forest/tree types (Willow Springs 2014, p.43).
Teck is committed to continue working with potentially affected Indigenous groups to refine the closure, conservation and reclamation (CC&R) plan through the life of the Project and to incorporate input from Indigenous groups on reclamation monitoring and thresholds and document the establishment of traditional use vegetation in the reclaimed landscape. Teck plans to co-create Reclamation Working Group(s) with potentially affected Indigenous groups to seek input to the Project’s reclamation plan and measures and targets to determine its success. It anticipates that species of traditional importance will be identified by Reclamation Working Group(s) and incorporated into reclamation planning as feasible. In addition, collaborative participation is planned in reclamation research both from a Project and regional perspective. Results of this research will be incorporated into future Project plans (see the response to JRP IR 6.9, Section 4.2).
Teck also commits to implement the following mitigation measures to reduce change in vegetation (see Volume 3, Appendix 17H, Section 17H.4 of the Project Update; response to JRP IRs 6.8 and 6.10):
Reclamation of the closure landscape will focus on generating a sustainable landscape that is designed to maximize diversity through the generation of landforms that include:
o topographic diversity and associated diversity in moisture regimes
o aspect diversity
o substrate diversity including both fine- and coarse- grained landforms
o mesotopography
Removal of existing linear disturbances that are currently fragmenting the landscape.
Mitigation to reduce effects on community diversity will focus on research results and strategies as summarized in:
o Guidelines for Reclamation to Forest Vegetation in the Athabasca Oil Sands Region (2nd Edition) (ESRD 2010)
o Guideline for Wetland Establishment on Reclaimed Oil Sands Leases (3rd Edition) (CEMA 2014)
o Oil Sands Marshes: A Knowledge Transfer (Charette et al. 2012)
o Best Management Practices for Conservation of Reclamation Materials in the Mineable Oil Sands Region of Alberta (MacKenzie 2011)
o Restoration and Reclamation of Boreal Ecosystems: Attaining Sustainable Development (Vitt and Bhatti 2012)
o Riparian Classification and Reclamation Guide, Revised Edition (Mihajlovich 2012)
Include peatlands in detailed CC&R planning should research results and recommendations prove to be feasible and appropriate.
Work with the governments of Alberta and Canada and look to their guidance on the development of a Conservation Agreement.
Plant additional species on the reclamation landscape, including those with traditional value, to supplement those recommended in provincial reclamation guidelines.
Mitigation for rare plant species will be achieved through avoidance whenever possible. In areas where avoidance is not possible, alternate mitigation strategies will be developed to promote conservation of these species and associated genetic diversity.
A weed management plan will be implemented throughout the life of the Project including during reclamation and at closure.
Develop and implement a program to salvage and relocate known occurrences of rare (vascular) plant species to areas outside of the Project area in consultation with Indigenous communities.
Incorporate species of traditional important as identified through the Reclamation Working Group(s) into reclamation planning, as feasible.
Engage Indigenous communities in preparing plans to harvest and collect seeds, and will invite community members to harvest and collect seeds of rare and culturally important species before disturbance, for use in reproducing the species and revegetation of the Project area.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures related to reclamation and evaluate monitoring results to determine if adaptations are warranted.
Historical Resources
Changes to historical resources within the Project disturbance area
Consult with community members to identify exact location of the burial sites and perform field verification to ensure sites are protected
Teck commits to implement the following mitigation measures regarding changes to historical resources within the Project disturbance area (see Volume 3, Appendix 17H, Section 17H.9 of the Project Update):
Historical resources sites in the PDA that Alberta Culture and Tourism (ACT) determines to have moderate to high heritage value will likely have requirements for further study. These might include some or all of the following:
Frontier Oil Sands Mine Project Appendix 10.12
Table 10.12-10: Potential Adverse Environmental Effect and Mitigation Table – Fort McMurray Métis Local 1935 (Métis Local 1935) (continued)
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(Willow Springs 2014, p.49).
o Additional shovel testing to identify site boundaries, areas of highest artifact density, activity areas and areas with unique or specialized artifacts.
o Archaeological excavation at sites with high interpretive potential.
o Mapping and documentation at specific sites.
Teck will phase the required supplemental historic resources impact assessment (HRIA) studies to ensure completion of all necessary studies in the PDA in advance of vegetation clearing in each development area.
Teck will also work collaboratively with local First Nation and Aboriginal communities on mitigation studies, in an effort to address local concerns and interests in relation to historical resources in the area.
Socio-economics
Change to housing needs Fund the construction of subsidized housing for Fort McMurray elders (Willow Springs 2015, p. 156).
Teck commits to implement the following mitigation measures regarding housing needs (see the response to JRP IR 5.14(a), Table 5.15a-1):
Provide on-site, lodge-based accommodations during construction and operations to reduce the Project’s effect on the resident population and associated effects on social infrastructure and housing in the region.
Offer lodge amenities and services – including individual rooms and shared spaces, the quality of the food services and free-time activities – that are competitive with other lodge accommodations in the region.
Change to social infrastructure needs Fund Métis community development initiatives including elder care, cultural centre, Métis scholarships and youth programming (Willow Springs 2014, p.49).
Teck commits to implement the following mitigation measures regarding social infrastructure needs (see the response to JRP IR 5.14(a), Table 5.15a-2):
Maintain explicit and enforced lodge, workplace and flight policies with regards to the use of alcohol, drugs and illegal activities.
Provide onsite security services, including controlled gates, check-in procedures, perimeter security fencing and lodge-based security officers on duty 24 hours.
Offer in-house security services to assist the Royal Canadian Mounted Police (RCMP) within, and sometimes outside, the Project lease boundaries (e.g., securing accident scenes and assisting with highway closures).
Develop and implement an emergency response plan which includes the required personnel, procedures and equipment resources (e.g., vehicles, fire response, medical response and rescue).
Develop required mitigation measures for areas adjacent to the Project area based on the FireSmart Wildfire Assessment System and implement in the emergency response plan.
Enter into mutual aid agreements with the Regional Municipality of Wood Buffalo (RMWB) and other oil sands companies that include:
o responding to motor vehicle accidents on Highway #63
o responding to forest fire threats to Fort McKay
o responding to regional spills
Participate in the management of regional emergencies at the RMWB’s Regional Emergency Operations Centre.
Make available onsite health services, including an on-site medical facility staffed by qualified health professionals providing 24-hour on-site primary, emergency and occupational health services.
Consider financial and in-kind contributions to the Northern Lights Health Foundation, where appropriate, to support the efforts of Alberta Health Services to meet the needs of Wood Buffalo residents. Recognizing some of the health concerns in the region Teck is prepared to make health promotion and disease prevention initiatives a focus of their community investment policy.
Provide helicopter or fixed-wing aircraft access via the on-site aerodrome for injured workers requiring rapid evacuation for off-site medical care.
Discuss with other industrial proponents near the Project options for coordinating on-site health facilities and resources.
Assess and support school events and education initiatives identified by rural schools in the study area, as appropriate.
Provide employees with access to the company’s confidential Employee and Family Assistance Plan, which provides support for families and individuals who might experience difficulty dealing with personal, family or work-life issues that can affect one’s health and well-being.
Consider support for community level initiatives including social groups providing assistance to those in need.
Continue providing direct support to community initiatives through its social investment programs.
Offer shift schedules that provide workers with sufficient time off to enjoy leisure activities in their home communities.
Make available onsite recreational opportunities and facilities.
Change to transportation needs None. Teck commits to implement the following mitigation measures regarding transportation needs (see the response to JRP IR 5.14(a), Table 5.14a-3):
Construct and operate an aerodrome near the Project site.
Use on-site as well as regional lodge accommodations during both construction and operations to reduce worker commutes.
Use bus service for transporting construction and operations workers.
Limit private vehicles brought to the Project site.
Schedule truck traffic, including oversized loads, to off-peak hours.
Use an on-site concrete batch plant; and attempt to source aggregates from pits near to site.
Enforce lodge, workplace and flight policies with regards to the use of alcohol, drugs and illegal activities.
Work with the local RCMP to confirm communication on local effects.
Support the efforts of RMWB and Oil Sands Community Alliance (OSCA) to work with the provincial government to progress improvements to highway infrastructure in a timely way.
Keep responsible regional and provincial planners informed of the Project’s development plans and their timing.
Consult and cooperate with other operators regarding shift scheduling with a view to reduce overlap in commuter traffic.
Provide funding to assist in the maintenance and safety of applicable segments of Highway #63 from Fort McKay to Fort Chipewyan that are affected by the Project.
Change to municipal infrastructure needs
None. Teck commits to implement the following mitigation measures regarding municipal infrastructure (see the response to JRP IR 5.14(a), Table 5.14a-4):
Provide water and sewer services for the different mining areas and the associated processing facilities and infrastructure, including on-site lodges.
Teck commits to implement the following mitigation measures regarding choice of fly-in/fly-out (FIFO) (see the response to JRP IR 5.14(a), Table 5.14a-6):
A FIFO lodge-based approach to construction and operations.
Ongoing monitoring of the operations FIFO model and revisiting the approach should local circumstances change.
Teck’s monitoring will take into consideration input received via its workers, contractors and ongoing local stakeholder and Indigenous engagement process. This would likely include feedback with respect to the social and economic effects of the FIFO model on individual workers, their families and communities.
Frontier Oil Sands Mine Project Appendix 10.12
Table 10.12-10: Potential Adverse Environmental Effect and Mitigation Table – Fort McMurray Métis Local 1935 (Métis Local 1935) (continued)
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Commitment to include Fort Chipewyan in a FIFO program.
Engage with potential employees living in Fort Chipewyan to discuss shift schedules and other travel and lodging logistics that influence their choice to work at the Project versus other opportunities.
Discuss with local communities the design of FIFO shifts that best benefit its employees and families while remaining logistically and financially feasible.
Remain open to engaging in broader, regional initiatives, for example through the OSCA and its study of the use of aerodromes in the region.
Change to employment, business and training opportunity needs
Provide opportunities for employment for Métis workers (Willow Springs 2014, p.49).
Offer contracts to Métis owned community businesses (Willow Springs 2014, p.49 and Willow Springs 2015, p. 157).
Set employment targets across various categories and emphasize long-term, permanent positions (Willow Springs 2015, p. 157).
Develop a recruitment and training program that targets Métis youth and women for employment (Willow Springs 2015, p. 157).
Establish a day-care subsidy for Métis Local 1935 employees of the Project (Willow Springs 2015, p. 157).
Teck commits to implement the following mitigation measures regarding employment, business and training opportunity needs (see the response to JRP IR 5.14(a), Table 5.14a-5):
Specific contractual commitments to Indigenous communities on employment, business and training opportunities will be made within Participation Agreements negotiated between Teck and the Indigenous community.
Prioritize recruiting residents from the region first, Alberta second, followed by the rest of Canada, then North America and then overseas countries.
Draw on various sources of labour in Canada that are traditionally under-represented in the labour market, including Indigenous people, immigrants and women.
Put in place a policy to hire local businesses and contractors that are competitive and able to meet the company’s needs is already in place.
Teck will consult with Indigenous communities regarding procurement and employment initiatives such as:
o Establishing mechanisms to enhance employment prospects of local residents, including preferential consideration.
o Using procurement processes that regard local ownership and prevalence of workers residing locally as positive criteria in goods and services vendor selection competitions.
o Establishing monitoring programs that measure local involvement, gather feedback and work with interested parties on how to improve results.
Implement Teck’s relevant charters, codes and policies, including its Indigenous Peoples Policy, when working with Indigenous peoples in seeking to develop lasting mutual benefits that respect Indigenous community’s values – including hiring, training and retention of Indigenous employees.
Utilize what Teck’s has learned to date from local Indigenous communities with which it is engaged for the Project to overcome oil sands specific challenges to Indigenous employment and procurement.
Consider work experience in lieu of a high school graduation for Indigenous peoples.
Work with the Fort McMurray Chamber of Commerce, the Northeastern Alberta Aboriginal Business Association (NAABA) and others to maximize contracting and employment opportunities in the region.
Offer a choice of worker turnaround cycles and opportunity to earn premium pay through overtime.
Continue to work with the Indigenous communities in the area and specifically with the communities of Fort McKay and Fort Chipewyan to develop Indigenous employment and business development program(s) guided by a commitment to: maximize opportunities for local Indigenous businesses to supply services and products in support of Project construction and operations; hire qualified Indigenous people from the communities surrounding the Project and support education, training and investment initiatives in local Indigenous communities, where appropriate.
Teck’s Indigenous community employment and business development program(s) will engage with Indigenous communities on establishing employment and procurement policies and procedures, as well as adaptive management mechanisms specific to Indigenous community employment and procurement.
Teck’s Indigenous community employment and business development program(s), as well as community-specific Participation Agreements will take into consideration input provided by local Indigenous communities, and will be guided by a commitment to: develop substantial opportunities for local Indigenous businesses to supply services and products in support of Project construction and operations; hire qualified Indigenous people from the communities surrounding the Project and support education, training and investment initiatives in local Indigenous communities, where appropriate.
Continuously monitor Teck’s local employment and procurement policies and programs, along with reporting the results of this monitoring as part of ongoing community consultation.
Teck has yet to determine the exact reporting and monitoring mechanisms for its local procurement and employment policies, but will engage with Indigenous communities on mechanisms and expects they will likely be similar to mechanisms used by Teck’s other operations. These might include:
o Total employment, attraction and retention rates, average salary levels and other general human resource data. Where possible, the data will be disaggregated at the local community level.
o Procurement activity, including examination of goods and services sourced from providers in local communities, value and length of contracts, types of goods and services provided and employment and enterprise effects associated with procurement.
o Additional potential mechanisms are identified in Teck’s draft socio-economic monitoring plan in response to JRP IR 5.15(a).
Continue supporting local labour force skills development, and work with communities, government and other industrial proponents on programs that assist community members overcome labour market barriers.
Change to culture Develop mandatory programs for employees to raise awareness about local Métis history, culture and the requirements of subsistence land users (Willow Springs 2014, p.44).
Properly assess the potential cultural impacts of wage labour and provide adequate mitigation and compensation initiatives to offset negative impacts on Métis Local 1935 families and communities (Willow Springs 2015, p. 103).
Fund and assist with the construction and operation of a McMurray Métis Cultural Centre in Fort McMurray (Willow Springs 2015, p. 155 -156).
Fund an annual summer culture camp for Métis Local 1935 youth (Willow Springs 2015, p.156).
Work with Métis Local 1935 in the design and implementation of a mandatory Aboriginal-cultural-sensitivity training so that content specific to the Métis Local 1935 community is
Teck commits to implement the following mitigation measures regarding changes to culture (see the response to JRP IR 5.14(a), Tables 5-14a-6 and 5.14a-7):
Continue to expand Teck’s knowledge of, and engagement with, local stakeholders and Indigenous communities near the Project to confirm ongoing and growing participation in Project-related benefits, as well as the design of appropriate and effective mitigation measures to reduce any adverse effect. These efforts are envisioned to include capacity building support within Participation Agreements for Indigenous communities.
Provide cultural diversity awareness training to employees and contractors, focusing on respect for traditional land users as well as respect for Indigenous world views, customs and values.
Consider supportive workplace practices as Teck develops workplace policies and seek local Indigenous community input into cultural awareness programming to be provided at the Project site.
Carry out a review of Teck’s standard bereavement policy, including a review of policies from other fly in/fly out operations in Alberta, as operation specific policies are developed during future planning phases.
Continuing to provide cultural awareness training for all Project staff and contractors.
Considering key Indigenous access routes and access preferences in the Project’s draft Access Management Plan (AMP).
Considering cultural keystone species in the wildlife management and mitigation plan, FHCL and biodiversity management plan.
Incorporating and using Indigenous place names where applicable.
Supporting community-led projects to document Indigenous place names in their respective traditional territories.
Contributing to language retention programs and other programs that support retaining Indigenous culture, knowledge and practice (e.g., culture camps for youth).
Discuss with local communities the design of fly in/fly out shifts that best benefit its employees and families while remaining logistically and financially feasible.
Frontier Oil Sands Mine Project Appendix 10.12
Table 10.12-10: Potential Adverse Environmental Effect and Mitigation Table – Fort McMurray Métis Local 1935 (Métis Local 1935) (continued)
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included and members are active participants (Willow Springs 2015, p. 157).
Establish a Youth Harvesting Program to support the transmission of traditional harvesting knowledge to the next generation (Willow Springs 2015, p. 157).
Access
Change to access near the Project disturbance area
Develop mandatory programs for employees to raise awareness about local Métis history, culture and the requirements of subsistence land users (Willow Springs 2014, p.44).
Communicate plans for proposed roads to community members and develop local study area access management plan for Métis harvesters (Willow Springs 2014, p.48).
Limit construction traffic to weekdays and regular working hours (Willow Springs 2014, p.48).
Identify and promote best practices and routes for safe access to harvesting areas (Willow Springs 2014, p.48).
Restrict recreational use activities among camp staff and employees with the exception of Métis community members/employees (Willow Springs 2014, p.48).
Teck has developed a draft access management plan (AMP) for the Project to facilitate access to or through Teck’s mineral surface lease to the extent possible while maintaining worker and public safety (see the response to JRP 4.5, Appendix 4.5). Teck has proposed next steps to Indigenous groups that would provide the opportunity for land users and community members to provide direct input into developing access mitigation measures. This input will refine the draft AMP.
Teck commits to implement the following mitigation measures to reduce potential effects on changes to access near the Project disturbance area (see Volume 3, Appendix 17H, Section 17H.8.2 of the Project Update) and the response to JRP IR 10.9):
All individuals wanting to gain access to or through lands being actively developed, which is generally Teck’s mineral surface lease (MSL), will be required to submit an access request.
Traditional land users will be granted temporary access to and through the PDA according to the policy and processes set out in the AMP.
Traditional land users will not have to meet worker site access requirements but will be escorted by someone who has permanent site access (i.e., a worker).
Access through, and to portions of the PDA not being actively developed will not require an access request form be submitted. Individuals will be required to contact the site’s security office and provide adequate notice about when they plan to be in the area, who will be present, and the intended activities and general location(s) as they relate to Teck leases. All individuals passing through the PDA will have to check in at the security office and will be escorted by a Teck worker. Teck understands that Aboriginal communities desire that the advance notice period.
Throughout the life of the mine, access to locations in the PDA by Aboriginal community members will be based on mine advance. For safety reasons, harvesting and use of firearms would not be permitted in areas being actively mined or within and around facilities associated with the mine.
The River Road will be maintained through operations and will provide access to the Fish Habitat Compensation Lake, aerodrome, and areas north of the PDA.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Traditional Land Use
Change in availability of resources (wildlife, fish and vegetation), culturally important sites or areas for traditional activities and use of lands
Develop mandatory programs for employees to raise awareness about local Métis history, culture and the requirements of subsistence land users (Willow Springs 2014, p.44).
Restrict hunting/fishing activities among camp staff and employees with the exception of Métis community members/employees (Willow Springs 2014, p.48).
Establish a McMurray Métis Trapline Reclamation Program (Willow Springs 2015, p.156).
Establish a Youth Harvesting Program to support the transmission of traditional harvesting knowledge to the next generation (Willow Springs 2015, p. 157).
Teck commits to implement the following mitigation measures to reduce changes in availability of resources (wildlife, fish and vegetation), culturally important sites or areas for traditional activities and use of lands (assessed in Volume 3, Section 17.6 of the Project Update) (see the response to JRP IR 4.6, Table 4.6-1):
Grant traditional land users temporary access to and through the PDA according to the policy and processes set out in the draft access management plan.
Implement measures to mitigate Project-related effects on wildlife through the wildlife monitoring and mitigation plan.
Engage Indigenous communities in the development of a biodiversity management plan.
Implement measures to mitigate Project-related effects on fish and fish habitat through the detailed fisheries offsetting plan.
Implement measures to reduce Project-related effects on vegetation through the conservation closure and reclamation plan and the reclamation monitoring plan.
Historical resources sites in the PDA that Alberta Culture and Tourism (ACT) determines to have moderate to high heritage value will meet the requirements of ACT and aim to meet the desires of Indigenous communities.
Teck commits to implement the following mitigation measures to reduce effects on the land use experience for traditional land users (see the response to JRP IR 4.6, Table 4.6-1):
Establish Participation Agreements with Indigenous communities.
Invite traditional users to harvest traditional plants before disturbance.
Support the planning and implementation of an excursion for Indigenous communities within the terrestrial local study area prior to Project-related disturbance to describe Indigenous values, access and to recommend mitigation to avoid or limit effects on Indigenous access values.
Provide cultural diversity awareness training to employees and contractors focusing on respect for Indigenous land users, traplines, cabins, trails and equipment, as well as respect for Indigenous world views, customs and values.
Compensate Indigenous trappers following industry-community standards and the Alberta Trappers Compensation Program.
Project personnel will be prohibited from fishing, hunting and trapping within the PDA during work rotations, which is when Teck’s policies’ can be enforced.
Project personnel will be prohibited from using personal recreation vehicles within the PDA.
Investigate with potentially affected Indigenous communities through the Reclamation Working Group the concept of incorporating cultural values into reclamation planning.
Supporting documentation of community-specific cultural heritage.
Teck has developed a Draft Traditional Land Use Mitigation, Monitoring and Adaptive Management Plan (see the response to JRP IR 4.6, Appendix 4.6). Teck will continue to seek input and engage with Indigenous groups, as well as regulators where appropriate, as part of finalizing this plan. Once finalized, Teck will continue to pursue collaborative engagement processes with Indigenous groups as outlined in the plan. Through these collaborative engagement processes Teck will aim to minimize and mitigate potential Project effects on traditional land use. Once finalized, the plan will include a communication management section, which will outline how findings of the program will be communicated to interested parties.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Notes:
NOx = oxides of nitrogen; SO2 = sulphur dioxide; PM2.5 = particulate matter
Frontier Oil Sands Mine Project Appendix 10.12
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6 Lac La Biche Métis Local 1909
A summary of established or asserted Aboriginal rights, current use of lands and resources for traditional
purposes and cultural and physical heritage features as described by Lac La Biche Métis Local (Métis
Local 1909) is presented in Table 10.12-11.
Table 10.12-11: Lac La Biche Métis Local 1909 Rights, Land Uses and Cultural and Physical Heritage Features
Established or Asserted Aboriginal Rights, Current Use of Lands and Resources for Traditional Purposes
Cultural and Physical Heritage Feature
Hunting
Fishing
Trapping
Plant harvesting
Livelihood from traditional lands
Commercial trapping and outfitting
Cultural practices
Way of life
Potential adverse Project effects on Métis Local 1909’s established or asserted Aboriginal rights, current
use of lands and resources for traditional purposes or cultural and physical heritage are presented in
Table 10.12-12, along with mitigation proposed by Métis Local 1909 in their TLU study (Willow Springs
and Métis Local 1909), and mitigation that Teck has committed to implement to reduce these potential
effects.
The mitigation proposed by Métis Local 1909 in their TLU study may not be reflected, as articulated by
Métis Local 1909, in the mitigation measures outlined in Table 10.12-12 for one or more of the following
reasons:
The mitigation measure proposed by Métis Local 1909 is directly or indirectly reflected in one or
more mitigation measures outlined by Teck.
The mitigation measure proposed by Métis Local 1909 is beyond the scope of what a single
proponent can mitigate.
The mitigation measure proposed by Métis Local 1909 is within the scope of activities that Teck
and Métis Local 1909 will undertake as part of implementing a Participation Agreement
(discussed below).
In 2017, Teck and Métis Local 1909 entered into a Participation Agreement for the Project. Teck’s
mitigation plans for the Project will be further discussed with Métis Local 1909 as part of joint Participation
Agreement implementation efforts.
Frontier Oil Sands Mine Project Appendix 10.12
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Table 10.12-12: Potential Adverse Environmental Effect and Mitigation Table – Lac La Biche Metis Local 1909
Potential Adverse Effects
Mitigation Proposed by Lac La Biche
Metis Local 1909 in TLU Study
Mitigation Teck Commits to Implement
Hydrology and Water Quality
Changes in flows, water levels and open water areas
None. The Athabasca River will satisfy the Project’s makeup water requirements, and an off-stream storage pond (OSSP) will supply the Project with water during periods when river water withdrawal is restricted (see the response to Joint Review Panel (JRP) Information Request (IR) 10.26, Appendix 10.26, Section 7.1).
Teck commits to implement the following mitigation measures to reduce changes in flows and water levels in receiving waterbodies (see the response to JRP IR 10.25, Appendix 10.25, Table 10.25-1):
Reduce changes to flows in Ronald Lake by using a flow splitter on the Redclay Creek diversion during operations.
Reduce changes to flows in Big Creek by using a flow splitter on the Big Creek diversion during operations.
Distribute muskeg drainage operations through the mine life, thereby avoiding a large increase in flows in the receiving waters.
Reduce effects of closed-circuit operations on flows and water levels in receiving waters by diverting natural watercourses that will not be disturbed by the mining operations around the mining area to receiving watercourses.
Reduce river-water withdrawal requirements from the Athabasca River by maximizing closed-circuit recycling of surface and groundwater where practical, and by storing sufficient amounts of water in an off-stream storage pond in the event of extended withdrawal restrictions from the Athabasca River.
Progressively construct and develop diversion systems, which helps limit the change in open-water areas during construction and operation by providing new drainage channels to replace the loss of natural watercourses and waterbodies.
Reduce changes to flows and water levels in receiving waters by developing a closure drainage layout that will limit changes in drainage areas contributing flows to the receiving watercourses relative to predevelopment conditions.
Design watercourses, waterbodies and wetlands during reclamation to attenuate floods.
Teck is committed to continue to consult meaningfully with, and engage, all potentially affected Indigenous groups at both a Project-specific and regional level to reduce and mitigate potential Project and cumulative effects on hydrology and surface water quality, including continuing discussions regarding hydrology and surface water quality concerns and is prepared to consider additional mitigation measures to address these concerns (see the response to JRP IR 10.25, Appendix 10.25).
Teck has developed a Draft Hydrology and Water Quality Mitigation, Monitoring and Adaptive Management Plan (see the response to JRP IR 10.25, Appendix 10.25). Once finalized, the plan will include a communication management section, which will outline how findings of the program will be communicated to interested parties.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Changes in sediment yields, concentrations and channel regimes (geomorphology)
None. Teck commits to implement the following mitigation measures to limit release of Total Suspended Solids (TSS) (see the response to JRP IR 10.25, Appendix 10.25, Table 10.25-1):
Follow relevant regulatory guidelines, standards and best management practices during construction and operation to reduce the risk of increased sediment loadings to receiving watercourses.
Construct and operate sedimentation ponds to settle TSS where necessary.
Control sediment generation in diversion channels through revegetation of streambanks, overbank areas and berms as soon as possible after construction and by the use of channel armour (riprap), where required.
Direct muskeg and overburden drainage waters to polishing ponds equipped with oil-separation capability.
Reduce sediment yields from reclaimed surfaces by developing appropriate final topography and soil moisture conditions.
Resuspension of sediments from the bottom of polishing ponds, wetlands and pit lakes will be reduced through appropriate hydraulic design.
Reduce gullying and channel erosion by developing robust and sustainable reclamation drainage systems with built-in self-healing capability and robustness similar to natural drainage systems.
Teck commits to implement the following mitigation measures to reduce changes in flood flows and geomorphology downstream of the Project (see the response to JRP IR 10.25, Appendix 10.25, Table 10.25-1):
Limit changes in flood flows in receiving watercourses relative to predevelopment conditions. Mitigation measures listed for the “reduce changes in flows and water levels” above are relevant for mitigating flood flows.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Direct water emissions:
Muskeg drainage and overburden dewatering flows
Drainage from operating and reclaimed mine site
Basal water sands depressurization
Process-affected seepages from backfilled mine pits and tailings disposal areas
None. Teck commits to implement the following mitigation measures to limit the release of ions, nutrients, metals, polycyclic aromatic hydrocarbons (PAHs) and other parameters during operations and closure and protect sediment quality in downstream watercourses and waterbodies (see the response to JRP IR 10.25, Appendix 10.25, Table 10.25-1):
Recycle process-affected waters and runoff within the Project disturbance area (PDA) in a closed-circuit system during operations.
Using a perimeter ditch and groundwater wells to capture and pump back seepages and runoff from the external tailings areas (ETAs) back into the tailings areas during operations.
Design the closure drainage system to capture seepage and runoff from ETAs, external disposal areas (EDAs) and the Frontier Project plant site and directing it to wetlands, pit lakes or constructed reclamation lakes during the mine closure management phase.
Use wetlands, constructed reclamation lakes and pit lakes during and after the decommissioning and closure phases to provide biological remediation and settling of particulate materials in reclamation waters before discharge.
Respond to spills using best management practices. Project activities will follow safety protocols designed to limit accidents and reduce effects if an accident should occur.
Teck commits to the following mitigation measures to manage depressurization water during preproduction (see Volume 1, Section 7.6.5 and 7.8.4 of the Project Update):
Teck plans to manage depressurization water during preproduction by storing approximately half of it in a storage pond at surface and reinjecting the remaining half into the BWS aquifer.
Teck is committed to continue to consult meaningfully with, and engage, all potentially affected Indigenous groups at both a Project-specific and regional level to reduce and mitigate potential Project and cumulative effects on hydrology and surface water quality, including continuing discussions regarding hydrology and surface water quality concerns and is prepared to consider additional mitigation measures to address these concerns (see the response to JRP IR 10.25, Appendix 10.25).
Teck has developed a Draft Hydrology and Water Quality Mitigation, Monitoring and Adaptive Management Plan (see the response to JRP IR 10.25, Appendix 10.25). Once finalized, the plan will include a communication management section, which will outline how findings of the program will be communicated to interested parties.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Pit lake releases None. Teck will leverage the knowledge gained through its other reclamation efforts, along with research through regional initiatives such as Canada’s Oil Sands Innovation Alliance (COSIA), to develop healthy, functional ecosystems in the Project pit lakes (see the response to JRP IR 2.3).
Teck also commits to implement the following mitigation measures when designing closure drainage and pit lakes for hydrological sustainability and to promote effective passive treatment of process-affected waters and to support a
Frontier Oil Sands Mine Project Appendix 10.12
Table 10.12-12: Potential Adverse Environmental Effect and Mitigation Table – Lac La Biche Metis Local 1909 (continued)
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Potential Adverse Effects
Mitigation Proposed by Lac La Biche
Metis Local 1909 in TLU Study
Mitigation Teck Commits to Implement
viable aquatic ecosystem prior to release and to sequester tailings and other mine waste in the most appropriate location at mine closure (see the response to JRP IR 10.25, Appendix 10.25, Table 10.25-1):
Exclude tailings from pit lakes.
Do not release water from pit lakes until acceptable quality is achieved.
Maintain the water balance of the pit lakes with sufficient inflows to compensate for evaporative losses.
Manage the rate of Athabasca River water input to pit lakes as appropriate to confirm water quality filling targets are met and to comply with Athabasca river low flow restrictions.
Include wetlands reclamation lakes for treatment purposes in reclamation drainages to the pit lakes.
Teck is committed to continue to consult meaningfully with, and engage, all potentially affected Indigenous groups at both a Project-specific and regional level to reduce and mitigate potential Project and cumulative effects on hydrology and surface water quality, including continuing discussions regarding hydrology and surface water quality concerns and is prepared to consider additional mitigation measures to address these concerns (see the response to JRP IR 10.25, Appendix 10.25).
Teck has developed a Draft Hydrology and Water Quality Mitigation, Monitoring and Adaptive Management Plan (see the response to JRP IR 10.25, Appendix 10.25). Once finalized, the plan will include a communication management section, which will outline how findings of the program will be communicated to interested parties.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Changes in quality of groundwater and surface water downgradient of EDAs
None. Teck commits to implement the following mitigation measures to maintain surface water quality in consideration of surface flows into and out of the Project area and groundwater discharge (see the response to JRP IR 10.25, Appendix 10.25, Table 10.25-1):
Groundwater and surface waters draining EDAs will be captured if monitoring data indicate that the drainage waters are unsuitable for release.
Teck is committed to continue to consult meaningfully with, and engage, all potentially affected Indigenous groups at both a Project-specific and regional level to reduce and mitigate potential Project and cumulative effects on hydrology and surface water quality, including continuing discussions regarding hydrology and surface water quality concerns and is prepared to consider additional mitigation measures to address these concerns (see the response to JRP IR 10.25, Appendix 10.25).
Teck has developed a Draft Hydrology and Water Quality Mitigation, Monitoring and Adaptive Management Plan (see the response to JRP IR 10.25, Appendix 10.25). Once finalized, the plan will include a communication management section, which will outline how findings of the program will be communicated to interested parties.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Air Quality and Odour
NOX emissions None. Teck commits to implement the following mitigation measures to reduce NOX emissions from combustion sources (see the response to JRP IR 3.18, Table 3.18-1):
Use natural gas as a fuel for the cogeneration plant and boilers and heaters.
Dry low NOX technology to reduce NOX emissions and increase cogeneration plant efficiency.
Boiler and heater technology that will meet provincial and federal government emission requirements.
Purchase Tier IV compliant haul trucks when they become available.
Optimize mine planning to reduce haul distances.
Develop and implement an anti-idling program for the mine fleet.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
SO2 emissions None. Teck commits to implement the following mitigation measures to reduce SO2 emissions from combustion sources (see the response to JRP IR 3.18, Table 3.18-1):
Use natural gas as a fuel for the cogeneration plant and boilers and heaters.
Use ultra-low sulphur diesel for the mine fleet.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
PM2.5 and dust emissions
None. Teck commits to implement the following mitigation measures to reduce PM2.5 emissions from combustion sources (see the response to JRP IR 3.18, Table 3.18-1):
Use natural gas as a fuel for the cogeneration plant and boilers and heaters.
Boiler and heater technology that will meet provincial and national government emission requirements.
Purchase Tier IV compliant haul trucks when they become available.
Optimize mine planning to reduce haul distances.
Develop and implement an anti-idling program for the mine fleet.
Teck commits to implement the following mitigation measures to reduce fugitive dust emissions (see the response to JRP IR 3.18, Table 3.18-1):
Dust mitigation measures to be applied to onsite roads during construction include appropriate selection of road materials, limiting vehicle speeds, surface watering, progressive reclamation, temporary vegetation of disturbed land and retain natural vegetation as windbreaks.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Hydrocarbon and reduced sulphur emissions and secondary organic aerosol precursor emissions
None. Teck commits to implement the following mitigation measures to reduce fugitive plant emissions (see the response to JRP IR 3.18, Table 3.18-1):
Use floating roof tanks where appropriate and a vapour recovery system to condense and recover vapours from storage tanks and process areas.
Use dual solvent vapour recovery units to provide full redundancy.
Conduct a leak detection and repair (LDAR) program to identify leaking components and to prioritize associated repairs.
Teck commits to implement the following mitigation measures to reduce fugitive mine face emissions (see the response to JRP IR 3.18, Table 3.18-1):
Mitigation not currently known.
Frontier Oil Sands Mine Project Appendix 10.12
Table 10.12-12: Potential Adverse Environmental Effect and Mitigation Table – Lac La Biche Metis Local 1909 (continued)
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Potential Adverse Effects
Mitigation Proposed by Lac La Biche
Metis Local 1909 in TLU Study
Mitigation Teck Commits to Implement
Teck commits to implement the following mitigation measures to reduce fugitive tailings area emissions (see the response to JRP IR 3.18, Table 3.18-1):
Tailing solvent recovery unit to maintain losses to less than four volumes of solvent to 1,000 volumes of bitumen produced.
Teck commits to implement the following mitigation measures to reduce hydrocarbon and reduced sulphur emissions from combustion sources (see the response to JRP IR 3.18, Table 3.18-1):
Use natural gas as a fuel for the cogeneration plant and boilers and heaters.
Purchase Tier IV compliant haul trucks when they become available.
Optimize mine planning to reduce haul distances.
Develop and implement an anti-idling program for the mine fleet.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Odour None. Teck has developed a draft Odour Management and Response Plan (see the response to JRP IR 3.13, Appendix 3.13). The draft Plan. The Plan’s goals are mitigation, monitoring, participation in regional complaint process, and correlation of complaints to Project activities to determine response actions. The Plan will be finalized following consultation with Indigenous communities, regulators and stakeholders.
At any time during Project operation, nearby residences will be able to contact Teck if they are concerned that Project operations are causing odours. The contact will be documented, investigative action will be initiated to determine the potential source, and the caller will be notified. If a source can be identified, a review will be undertaken to implement corrective action to reduce the potential for future occurrences (ERCB Round 1 SIR 113a; Appendix 3.13).
Acoustics
Change in sound levels
None. Teck has made an overall commitment to managing and promptly addressing all noise-related concerns (see Volume 3, Section 3.4.9.2, Project Update) and will develop a Noise Management Plan (see Volume 3, Section 3.4.9.1, Project Update).
Teck also commits to implement the following mitigation measures to reduce changes in sound levels (see Volume 3, Appendix 17H, Section 17H.5 of the Project Update and the response to JRP IR 1.3, Table 1.4-1):
Vehicles will be maintained in good working condition (e.g., mufflers will be maintained) and speed limits will be enforced.
Emergency alarms will be tested during daytime, where reasonably practical.
Acoustic performance of building wall construction will meet a minimum sound transmission class (STC) rating of 29, based on published data in the North American Insulation Manufacturers Association for a pre-engineered structure.
For outdoor equipment, the manufacturer incorporates mitigation in the equipment design to achieve the published sound power level.
Noise effects will be mitigated using various measures, including but not limited to the following:
o haul trucks exhaust silencer
o haul truck speed
o trip frequency (number of trips per daytime and nighttime period)
o route location or alignment
Ventilation openings (i.e., air intake and exhaust openings) will be fitted with appropriate acoustic silencers, louvers, or plenums, where applicable, to reduce outdoor sound transmission from indoor equipment.
Buildings housing indoor noise-generating equipment will be appropriately sealed to reduce noise.
Where practical, flanking path and penetrations from plumbing, heating ducts and electrical wire in the buildings will be properly insulated and covered to reduce noise.
Appropriate acoustical lagging will be installed to provide additional attenuation to the steel casing, where practical.
Vibration isolation pads, resilient mounts on equipment, resilient pipe support systems, and dampers will be installed where appropriate.
Teck will incorporate best management practices to reduce Project-related noise into Daily Operational Procedures, Long-Term Operational Procedures, design for low-noise facilities, and performance measurement as described in SPOG (2012) Best Practices Document, where appropriate (ERCB Round 1 SIR 116; Volume 3, Section 3.4.9.1 of the Project Update), including:
Daily Operational Procedures
Keeping compressor station doors and windows closed
Using belt dressing
Inspecting and repairing mufflers
Running fans slower at night (variable frequency drive [VFD])
Using vent silencers on buildings
Using soundproofing (insulation and lagging)
Troubleshooting transient noise
Minimizing flaring and venting
Considering gravel pack around compressor building skids
Developing noise check in daily reading sheets
Long-Term Operational Procedures
Responding quickly to noise concerns
Establishing baseline noise levels (in plant, at fence-line, or both) and resurvey to determine trends
Conducting regular assessment of noise control opportunities
Using best practical technology for noise control
Maintaining communication links with noise sensitive receptors and communities
Being aware of noise from contractors (e.g., service rigs) and developing processes to meet best practice expectations
Frontier Oil Sands Mine Project Appendix 10.12
Table 10.12-12: Potential Adverse Environmental Effect and Mitigation Table – Lac La Biche Metis Local 1909 (continued)
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Potential Adverse Effects
Mitigation Proposed by Lac La Biche
Metis Local 1909 in TLU Study
Mitigation Teck Commits to Implement
Scheduling work to create the least amount of noise effects on noise sensitive receptors and keeping those affected informed
Design for Low Noise Facilities
Considering low noise electric drives versus engine driven compressors
Designing cooler fans for low tip velocity
Orienting noise sources away from residents
Using acoustical pipe lagging
Installing VFDs on coolers
Performance Measurement
Conducting measurements and establishing baseline data
Using best practices as part of the company’s operating procedures
Visual
Change to visual environment None. Teck commits to implement the following mitigation measures to reduce changes to visual effects (see Volume 1, Section 8.3.6, Volume 3, Section 16.4.6, Volume 3, Section 18.10.4.2, Volume 3, Section 18.11.5.4 and Volume 3, Appendix 17H, Section 17H.7 of the Project Update):
Maintaining vegetated buffers between the Project and the Athabasca River as well as along Project transportation corridors to the extent feasible where safety concerns are not an issue.
Using construction materials that reduce contrast, limit visual attraction to Project features, and blending built structures into the natural surrounding environment.
Using construction materials, where practicable, that minimize light reflection, potentially reducing viewing distances of Project features
Reclamation techniques will be used that integrate closure plans with the surrounding landscape.
Teck will seek to develop closure plans that:
o Include integration and contouring of slopes that mimic natural topography.
o Focus on establishing a variety of vegetation communities.
o Avoid unnatural-looking breaks at development boundaries.
Planting a narrow band of white spruce along the edge of the river water intake (RWI) cofferdam and plant dogwood on the cofferdam, except in areas where tall vegetation would impede any maintenance or present safety concerns.
Completing reclamation in the RWI area to minimize erosion and slope instability.
Using lighting that minimizes light pollution.
At closure, infrastructure will be removed and the Project will be reclaimed using vegetation types similar, though not identical to existing conditions, creating a continuous vegetated landscape.
A lighting plan will be developed during future stages of engineering to avoid over-illumination. Lighting design will be part of future stages of engineering, and Teck will consult with interested Indigenous communities about lighting considerations.
Finish the Athabasca River Bridge with low-glare materials and plant vegetation buffers near the bridge. Teck also commits to clear minimal vegetation and to vegetate cleared areas.
Retain treed buffers around or near watercourses.
Fish and Fish Habitat
Change in productive fish habitat
None. Fish habitat of equivalent or higher productivity than that affected by the Project will be created through offsetting measures where prevention of adverse habitat alteration or loss (i.e., reduced habitat productivity or loss of productive habitat area) is not feasible (see the draft Detailed Fisheries Offsetting Plan, the response to JRP IR 2.1, Appendix 2.1).
Teck also commits to implement the following mitigation measures to avoid or reduce changes in fish habitat quantity or quality (see the response to JRP IR 2.1, Table 5):
To avoid or reduce sedimentation:
o Temporary and permanent erosion and sediment control measures for construction activities and disturbed areas.
o Stabilization and revegetation of disturbed areas.
o Isolation of instream work areas where they are required.
o Best management practices and regulatory guidelines for construction activities in and near watercourses/waterbodies for erosion and sediment control.
o Polishing ponds or other measures to reduce suspended sediment concentrations in discharge waters to avoid increases in sedimentation in the receiving environment.
o Appropriate design of constructed channels and ponds to reduce internal erosion and generation of suspended sediments.
o Appropriate design and construction of reclaimed landscape to reduce sediment yield.
To avoid or reduce changes to water quality:
o Passing muskeg drainage and overburden water through polishing ponds and drainage ditches to reduce changes in water temperatures and dissolved oxygen concentrations.
o Recycling of process affected waters during operations.
o Capture and recycling of ETA seepage and run off water during operations, and use of a passive seepage control system at closure.
o Use of wetlands, pit lakes and constructed reclamation lakes in the closure drainage system to provide biological remediation before release to the environment.
o Removal of organic material from fish habitat compensation lake (FHCL) area prior to flooding.
To avoid or reduce changes to habitat area:
o Diversion of watercourses around the PDA to return natural upslope water back to the diverted watercourse to preserve flows and avoid elimination of downstream habitats.
o Provision of a flow splitter on the diversion channel that will collect water from both upper Redclay Creek and Unnamed Creek 17 to appropriately apportion the flows in lower Redclay Creek and Unnamed Creek 17 to avoid flow changes in the Ronald Lake watershed.
o Operation of the RWI and Off Stream Storage Pond (OSSP) in compliance with the Lower Athabasca River Surface Water Quantity Management Framework.
o Design of the closure drainage channels and pit lakes to provide habitats capable of supporting aquatic ecosystems.
Frontier Oil Sands Mine Project Appendix 10.12
Table 10.12-12: Potential Adverse Environmental Effect and Mitigation Table – Lac La Biche Metis Local 1909 (continued)
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Potential Adverse Effects
Mitigation Proposed by Lac La Biche
Metis Local 1909 in TLU Study
Mitigation Teck Commits to Implement
o Best management practices and regulatory guidelines to ensure construction and operation of the RWI, Athabasca River bridge and watercourse crossings associated with access roads do not interfere with fish passage and access to available habitats.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Change in fish abundance None. Teck commits to implement the following mitigation measures to avoid or reduce changes in fish abundance (see the response to JRP IR 2.1, Table 5):
Fish rescue operations to capture and relocate fish prior to habitat dewatering.
Screening of the RWI in compliance with regulatory guidelines to mitigate fish entrainment or impingement.
Best management practices and regulatory guidelines for scheduling construction activities in and near waterbodies/watercourse to avoid sensitive time periods in adjacent or downstream fish-bearing watercourses.
Education of Project personnel on sustainable fishing practices to support a Teck applied prohibition on their fishing in watercourses or waterbodies in the PDA to mitigate potential increases in recreational fishing pressure.
Access Management Plan for the PDA to limit access to fish bearing habitats to mitigate increased fishing pressure.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Change in fish and fish habitat diversity
None. Teck commits to implement the following mitigation measures to avoid or reduce changes in fish and fish habitat diversity (see the response to JRP IR 2.1, Table 5):
Several of the measures intended to avoid or mitigate effects to fish habitat and fish abundance also apply to fish and fish habitat diversity, in cases where they preserve fish and productive fish habitats or create new habitats, including:
o Diversions designed to preserve flows and avoid elimination of downstream habitats.
o Closure drainage channels and pit lakes designed to provide habitats capable of supporting aquatic ecosystems.
o Fish rescue operations.
o Screening of the RWI.
o Education and prohibition of Project personnel from fishing in the PDA.
o Access Management for the PDA to limit access to fish bearing habitats.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Wildlife
Change in wildlife habitat availability None. Teck commits to implement the following mitigation measures to reduce direct habitat loss (see the response to JRP IR 7.14, Table 7.14-1):
Limit the size of the east side access road right-of-way (ROW) and temporary workspace to the extent practical.
Limit the Athabasca River bridge footprint in riparian areas.
Carry out progressive reclamation to reclaim disturbed wildlife habitat as portions of the mine footprint become available.
Develop a weed management plan.
Teck commits to implement the following mitigation measures to reduce indirect habitat loss (see the response to JRP IR 7.14, Table 7.14-1):
Implement strategies to reduce noise and light effects, including design considerations (e.g., Frontier Project plant site engineering and aerodrome operation within regulatory and safety constraints).
Limiting employee and contractor access to identified areas of high-quality habitat adjacent to Project footprint.
Teck commits to developing a Biodiversity Management Plan (BMP) with the underlying goal of optimizing reclamation during operations to reduce offsetting of residual environmental effects (see the response to JRP IR 7.15).
Teck has developed a Draft Wildlife Mitigation, Monitoring and Adaptive Management Plan (WMMP; see the response to JRP IR 7.14, Appendix 7.14). Teck has proposed steps to Indigenous groups that would provide the opportunity for land users and community members to provide direct input into developing wildlife mitigation measures. Input will refine this draft WMMP. Once finalized, the plan will include a communication management section, which will outline how findings of the program will be communicated to interested parties.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Change in wildlife landscape connectivity Maintain wildlife corridors (Willow Springs and Métis Local 1909, p.70)
Reclamation (Willow Springs and Métis Local 1909, p.70)
Teck commits to implement the following mitigation measures to reduce change to landscape connectivity (see the response to JRP IR 7.14, Table 7.14-1):
Carry out progressive reclamation to restore habitat for movement as portions of the mine footprint become available.
To maintain connectivity between Birch Mountains and Athabasca River:
o Coordinate development activities with Canadian Natural Resources Limited (CNRL) who acquired the Pierre River Mine oil sands leases formerly held by Shell Canada Limited should CNRL reapply for and develop the Pierre River Mine project.
o Develop an integrated land management strategy for the Project in consultation with industry, the province, Indigenous communities, and stakeholders.
Provide wildlife passage under both sides of the Athabasca River bridge and river water intake bridge to Dalkin Island to allow north–south wildlife movement along river banks using crossing design considerations (e.g., bridge height and length) outlined in Clevenger and Huijser (2011) and GOA (2011).
Set up educational signage to limit human use of wildlife underpasses.
Evaluate wing fencing along the approach to crossing passages (at least 2.4 m high for large mammals as per GOA 2011) as part of the crossing structure design.
Provide appropriate walking substrate along the wildlife underpass.
Create vegetated buffers adjacent to wildlife underpasses to increase movement opportunities for a variety of species.
Provide coarse woody debris (e.g., stumps) along the wildlife underpass to provide cover and increase use by furbearers and other small mammals.
Teck has developed a Draft WMMP (see the response to JRP IR 7.14, Appendix 7.14). Teck has proposed steps to Indigenous groups that would provide the opportunity for land users and community members to provide direct input into developing wildlife mitigation measures. Input will refine this draft WMMP. Once finalized, the plan will include a communication management section, which will outline how findings of the program will be communicated to interested parties.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Frontier Oil Sands Mine Project Appendix 10.12
Table 10.12-12: Potential Adverse Environmental Effect and Mitigation Table – Lac La Biche Metis Local 1909 (continued)
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Potential Adverse Effects
Mitigation Proposed by Lac La Biche
Metis Local 1909 in TLU Study
Mitigation Teck Commits to Implement
Change in wildlife mortality risk
None.
Teck commits to implement the following mitigation measures to reduce wildlife mortality risk resulting from vehicle–wildlife collisions (see the response to JRP IR 7.14, Table 7.14-1):
Implement fly-in/fly-out policy for workers to reduce vehicular traffic volume.
Erect wildlife cautionary signage on access roads.
Foster environmental awareness with speed restrictions on access roads report Project-related wildlife fatalities.
Provide vegetation maintenance at roadsides (vegetation will be trimmed regularly to discourage roadside foraging and prevent visual obstruction of wildlife).
Develop seed mixes for roadside reclamation from less palatable species to reduce wildlife attraction to road edges.
Design the road to maximize line of sight.
Remove road kill as soon as practical.
Teck commits to implement the following mitigation measures to reduce wildlife mortality risk resulting from wildlife interactions with equipment (see the response to JRP IR 7.14, Table 7.14-1):
Implement preconstruction surveys for active wildlife habitat features (e.g., nests, breeding wetlands) before starting early works.
Avoid vegetation clearing during the recommended May 1 to August 10 migratory bird-breeding period for the boreal ecozone per Environment Canada guidelines; note that in species at risk habitat, a more conservative breeding window of April 1 to August 31 might apply (Gregoire 2014, pers. comm.); complete nest surveys if clearing activities occur during the breeding window.
Conduct owl nest search if clearing is scheduled within the non-migratory breeding bird window, March 1 to April 15 (based on Enhanced Approval Process guidelines for barred owl, GOA 2013).
Reduce on disturbance of amphibian breeding and overwintering habitat (where possible).
Teck commits to implement the following mitigation measures to reduce wildlife mortality risk resulting from interactions with Infrastructure (see the response to JRP IR 7.14, Table 7.14-1):
Create fuel and chemical spill contingency and response plans.
Confirm adequate spill protection for all fuel storage facilities.
Monitor and maintain waste disposal sites, wastewater storage areas and runoff control structures to prevent surface water impacts.
During overburden dewatering, intermittently backslope the sides of drainage ditches to allow for wildlife crossings and to reduce the potential for entrapment.
Use visible markers, such as aviation spheres and spiral vibration dampeners to make transmission lines near waterfowl staging and potential stopover areas more visible to birds, and where possible, design transmission lines to match the height of surrounding trees to reduce wire strikes by birds.
Teck commits to implement the following mitigation measures to reduce wildlife mortality risk resulting from wildlife–human conflicts (see the response to JRP IR 7.14, Table 7.14-1):
Implement a food waste-management strategy to prevent attraction of nuisance wildlife.
Confirm wildlife is not harassed or fed (to prevent habituation).
Provide wildlife awareness training to Project staff and contractors to reduce disturbance and negative human/bear interactions.
Provide all field staff with bear-aware training courses, personal protective equipment (e.g., bear spray, bear bangers, air horns) and training on proper use of equipment.
Develop a nuisance wildlife mitigation and monitoring plan in cooperation with the regulators.
Teck commits to implement the following mitigation measures to reduce wildlife mortality risk resulting from increased hunter access (see the response to JRP IR 7.14, Table 7.14-1):
Implement deactivation plans for roads no longer in use.
Prohibit construction and operations personnel and contractors from hunting and trapping while working.
Disallow personal recreational vehicle use onsite.
Prohibit firearms on Project lands or at Project facilities.
Consider requesting a Directors Order to limit public access to the west side of the Athabasca River along Project roads.
Teck has developed a Draft WMMP (see the response to JRP IR 7.14, Appendix 7.14). Teck has proposed steps to Indigenous groups that would provide the opportunity for land users and community members to provide direct input into developing wildlife mitigation measures. Input will refine this draft WMMP. Once finalized, the plan will include a communication management section, which will outline how findings of the program will be communicated to interested parties.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Waterfowl
Change in bird mortality risk
None.
Teck commits to implement the following mitigation measures to reduce migratory water bird mortality risk resulting from the use of ponds (see the response to JRP IR 7.10, Table 7.10-1):
Develop detailed construction and operational procedures and mitigation measures to reduce wildlife mortality during tailings area start-up.
Design the sides of wastewater ponds to reduce attractiveness to birds (e.g., using gravel for sides).
Clear trees and above-ground vegetation including shrubs, herbs and the ground layer prior to placement of tailings into tailings disposal areas.
Remove peat from tailings area prior to flooding.
Develop detailed construction and operational procedures and mitigation measures to reduce wildlife mortality during tailings area start-up.
Reduce attractiveness of tailings areas for birds by keeping the inner walls of the tailings dyke free of vegetation.
Keep slopes of tailings areas as steep as possible to reduce “black beach” areas.
Implement procedure for removing any peat mats that float to the surface of the tailings area.
Implement procedure for controlling floating bitumen mats.
Manage the use and operation of anthropogenic lighting around wastewater ponds and tailings areas.
Bird deterrent systems will be used to discourage birds from landing on wastewater ponds and tailings areas.
Teck commits to implement the following mitigation measure to reduce the potential for birds to land in ponds containing process-affected water (see the response to ESRD/CEAA Round 3 SIR 64):
Frontier Oil Sands Mine Project Appendix 10.12
Table 10.12-12: Potential Adverse Environmental Effect and Mitigation Table – Lac La Biche Metis Local 1909 (continued)
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Potential Adverse Effects
Mitigation Proposed by Lac La Biche
Metis Local 1909 in TLU Study
Mitigation Teck Commits to Implement
Bird deterrent systems will be installed on all ponds associated with the Project that have process-affected water that could be detrimental to birds.
Teck commits to implement the following mitigation measures to maximize recovery efficiency should birds use ponds (see the response to JRP IR 7.10, Table 7.10-1):
Develop procedure for handling of any bird recovered from wastewater ponds or tailings areas.
Procedure will be in compliance with directions received from the local Alberta Fish and Wildlife office and/or the Alberta Environment and Parks (AEP) wildlife biologist.
Procedure will also be in compliance with directions from Environment and Climate Change Canada with respect to whooping cranes.
Teck commits to implement the following mitigation measures to reduce the potential for bird mortality risk resulting from interaction with transmission and distribution lines (see the response to JRP IR 7.10, Table 7.10-1):
Designing transmission and distribution lines, where possible, to match the height of surrounding trees to reduce wire strikes by birds.
Marking of transmission and distribution lines in areas near waterfowl staging and potential stopover areas.
Teck has developed a Draft Waterfowl Protection Plan (see the response to JRP IR 7.10, Appendix 7.10). Teck will continue to pursue collaborative engagement processes, as outlined in the WMMP for the Project as the primary mechanism in which it will engage with potentially affected Indigenous groups regarding the Waterfowl Protection Plan. Once finalized, the plan will include a communication management section, which will outline how findings of the program will be communicated to interested parties.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Bison
Change in bison habitat availability None. Teck commits to implement the following mitigation measures to reduce direct habitat loss (see the response to JRP IR 7.5, Table 7.5-1):
Limit the size of the east side access road right-of-way (ROW) and temporary workspace to the extent practical.
Limit the Athabasca Rive bridge footprint in riparian areas.
Carry out progressive reclamation to reclaim disturbed wildlife habitat as portions of the mine footprint become available.
Develop a weed management plan.
Teck commits to implement the following mitigation measures to reduce indirect habitat loss (see the response to JRP IR 7.5, Table 7.5-1):
Implement strategies to reduce noise and light effects, including design considerations (e.g., Frontier Project plant site engineering and aerodrome operation within regulatory and safety constraints).
Limiting employee and contractor access to identified areas of high-quality habitat adjacent to Project footprint.
Teck has developed a Draft Ronald Lake Bison Mitigation, Monitoring and Adaptive Management Plan (see the response to JRP IR 7.5, Appendix 7.5). Teck has proposed steps to Indigenous groups that would provide the opportunity for land users and community members to provide direct input into developing wildlife mitigation measures, including those specific to bison. Once finalized, the plan will include a communication management section, which will outline how findings of the program will be communicated to interested parties.
Teck will also work with the responsible authority to explore possible mitigations for which Teck does not have the authority to implement independently.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Change in bison landscape connectivity Maintain wildlife corridors (Willow Springs and Métis Local 1909, p.70)
Reclamation (Willow Springs and Métis Local 1909, p.70)
Teck commits to implement the following mitigation measures to reduce change to landscape connectivity (see the response to JRP IR 7.5, Table 7.5-1):
Carry out progressive reclamation to restore vegetated corridors as portions of the mine footprint become available.
To maintain connectivity between Birch Mountains and Athabasca River:
o Coordinate development activities with Canadian Natural Resources Limited (CNRL) who acquired the Pierre River Mine oil sands leases formerly held by Shell Canada Limited should CNRL reapply for and develop the Pierre River Mine project.
o Develop an integrated land management strategy for the Project in consultation with industry, Indigenous stakeholders and the Province.
Provide wildlife passage under both sides of the Athabasca River bridge and river water intake bridge to Dalkin Island to allow north–south wildlife movement along river banks using crossing design considerations (e.g., bridge height and length) outlined in Clevenger and Huijser (2011) and GOA (2011):
o Set up educational signage to limit human use of wildlife underpasses.
o Evaluate wing fencing along the approach to crossing passages (at least 2.4 m high for large mammals as per GOA 2011) as part of the crossing structure design.
o Provide appropriate walking substrate along the wildlife underpass.
o Create vegetated buffers adjacent to wildlife underpasses to increase movement opportunities for a variety of species.
Teck has developed a Draft Ronald Lake Bison Mitigation, Monitoring and Adaptive Management Plan (see the response to JRP IR 7.5, Appendix 7.5). Teck has proposed steps to Indigenous groups that would provide the opportunity for land users and community members to provide direct input into developing wildlife mitigation measures, including those specific to bison. Once finalized, the plan will include a communication management section, which will outline how findings of the program will be communicated to interested parties.
Teck will also work with the responsible authority to explore possible mitigations for which Teck does not have the authority to implement independently.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Change in bison mortality risk
None.
Teck commits to implement the following mitigation measures to reduce bison mortality risk resulting from vehicle–bison collisions (see the response to JRP IR 7.5, Table 7.5-1):
Implement fly-in/fly-out policy for workers to reduce vehicular traffic volume.
Erect wildlife cautionary signage on access roads.
Foster environmental awareness with speed restrictions on access roads, report Project-related wildlife fatalities.
Provide vegetation maintenance at roadsides (vegetation will be trimmed regularly to discourage roadside foraging and prevent visual obstruction of wildlife).
Develop seed mixes for roadside reclamation from less palatable species to reduce wildlife attraction to road edges.
Design the road to maximize line of sight.
Frontier Oil Sands Mine Project Appendix 10.12
Table 10.12-12: Potential Adverse Environmental Effect and Mitigation Table – Lac La Biche Metis Local 1909 (continued)
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Potential Adverse Effects
Mitigation Proposed by Lac La Biche
Metis Local 1909 in TLU Study
Mitigation Teck Commits to Implement
Teck commits to implement the following mitigation measures to reduce bison mortality risk resulting from bison-human interactions - interactions with infrastructure (see the response to JRP IR 7.5, Table 7.5-1):
Create fuel and chemical spill contingency and response plans.
Confirm adequate spill protection for all fuel storage facilities.
Monitor and maintain waste disposal sites, wastewater storage areas and runoff control structures to prevent contamination of surface waters.
During overburden dewatering, intermittently backslope the sides of drainage ditches to allow for wildlife crossings and to reduce the potential for entrapment.
Teck commits to implement the following mitigation measures to reduce bison mortality risk resulting from hunter access (see the response to JRP IR 7.5, Table 7.5-1):
Construct predator access blocks to deter predator use (i.e., reduce line of sight) on linear features in the PDA that may leave core bison areas susceptible to predation.
Deactivate roads in the PDA no longer in use.
Implement employee / contractor policies to prohibit hunting within the Project area.
Reduce linear features in the closure landscape.
Reduce width of linear features in the closure landscape.
Teck commits to implement the following mitigation measures to reduce bison mortality risk resulting from disease transmission to the Ronald Lake bison herd (see the response to JRP IR 7.5, Table 7.5-1):
Implement progressive reclamation in the PDA to create suitable Ronald Lake bison habitat and reduce the potential of shifting habitat use northward.
Mitigations associated with reducing hunter and predator access.
Mitigations associated with reducing wildlife human conflict.
Mitigations associated with reducing indirect habitat loss.
Teck has developed a Draft Ronald Lake Bison Mitigation, Monitoring and Adaptive Management Plan (see the response to JRP IR 7.5, Appendix 7.5). Teck has proposed steps to Indigenous groups that would provide the opportunity for land users and community members to provide direct input into developing wildlife mitigation measures, including those specific to bison. Once finalized, the plan will include a communication management section, which will outline how findings of the program will be communicated to interested parties.
Teck will also work with the responsible authority to explore possible mitigations for which Teck does not have the authority to implement independently.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Vegetation
Change in vegetation None. Teck is committed to continue working with potentially affected Indigenous groups to refine the closure, conservation and reclamation (CC&R) plan through the life of the Project and to incorporate input from Indigenous groups on reclamation monitoring and thresholds and document the establishment of traditional use vegetation in the reclaimed landscape. Teck plans to co-create Reclamation Working Group(s) with potentially affected Indigenous groups to seek input to the Project’s reclamation plan and measures and targets to determine its success. It anticipates that species of traditional importance will be identified by Reclamation Working Group(s) and incorporated into reclamation planning as feasible. In addition, collaborative participation is planned in reclamation research both from a Project and regional perspective. Results of this research will be incorporated into future Project plans (see the response to JRP IR 6.9, Section 4.2).
Teck also commits to implement the following mitigation measures to reduce change in vegetation (see Volume 3, Appendix 17H, Section 17H.4 of the Project Update; response to JRP IRs 6.8 and 6.10):
Reclamation of the closure landscape will focus on generating a sustainable landscape that is designed to maximize diversity through the generation of landforms that include:
o topographic diversity and associated diversity in moisture regimes
o aspect diversity
o substrate diversity including both fine- and coarse- grained landforms
o mesotopography
Removal of existing linear disturbances that are currently fragmenting the landscape.
Mitigation to reduce effects on community diversity will focus on research results and strategies as summarized in:
o Guidelines for Reclamation to Forest Vegetation in the Athabasca Oil Sands Region (2nd Edition) (ESRD 2010)
o Guideline for Wetland Establishment on Reclaimed Oil Sands Leases (3rd Edition) (CEMA 2014)
o Oil Sands Marshes: A Knowledge Transfer (Charette et al. 2012)
o Best Management Practices for Conservation of Reclamation Materials in the Mineable Oil Sands Region of Alberta (MacKenzie 2011)
o Restoration and Reclamation of Boreal Ecosystems: Attaining Sustainable Development (Vitt and Bhatti 2012)
o Riparian Classification and Reclamation Guide, Revised Edition (Mihajlovich 2012)
Include peatlands in detailed CC&R planning should research results and recommendations prove to be feasible and appropriate.
Work with the governments of Alberta and Canada and look to their guidance on the development of a Conservation Agreement.
Plant additional species on the reclamation landscape, including those with traditional value, to supplement those recommended in provincial reclamation guidelines.
Mitigation for rare plant species will be achieved through avoidance whenever possible. In areas where avoidance is not possible, alternate mitigation strategies will be developed to promote conservation of these species and associated genetic diversity.
A weed management plan will be implemented throughout the life of the Project including during reclamation and at closure.
Develop and implement a program to salvage and relocate known occurrences of rare (vascular) plant species to areas outside of the Project area in consultation with Indigenous communities.
Incorporate species of traditional important as identified through the Reclamation Working Group(s) into reclamation planning, as feasible.
Engage Indigenous communities in preparing plans to harvest and collect seeds, and will invite community members to harvest and collect seeds of rare and culturally important species before disturbance, for use in reproducing the species and revegetation of the Project area.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures related to reclamation and evaluate monitoring results to determine if adaptations are warranted.
Frontier Oil Sands Mine Project Appendix 10.12
Table 10.12-12: Potential Adverse Environmental Effect and Mitigation Table – Lac La Biche Metis Local 1909 (continued)
Teck Resources Limited Page 75
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Potential Adverse Effects
Mitigation Proposed by Lac La Biche
Metis Local 1909 in TLU Study
Mitigation Teck Commits to Implement
Historical Resources
Changes to historical resources within the Project disturbance area
None. Teck commits to implement the following mitigation measures regarding changes to historical resources within the Project disturbance area (see Volume 3, Appendix 17H, Section 17H.9 of the Project Update):
Historical resources sites in the PDA that Alberta Culture and Tourism (ACT) determines to have moderate to high heritage value will likely have requirements for further study. These might include some or all of the following:
o Additional shovel testing to identify site boundaries, areas of highest artifact density, activity areas and areas with unique or specialized artifacts.
o Archaeological excavation at sites with high interpretive potential.
o Mapping and documentation at specific sites.
Teck will phase the required supplemental historic resources impact assessment (HRIA) studies to ensure completion of all necessary studies in the PDA in advance of vegetation clearing in each development area.
Teck will also work collaboratively with local First Nation and Aboriginal communities on mitigation studies, in an effort to address local concerns and interests in relation to historical resources in the area.
Socio-economics
Change to housing needs None. Teck commits to implement the following mitigation measures regarding housing needs (see the response to JRP IR 5.14(a), Table 5.15a-1):
Provide on-site, lodge-based accommodations during construction and operations to reduce the Project’s effect on the resident population and associated effects on social infrastructure and housing in the region.
Offer lodge amenities and services – including individual rooms and shared spaces, the quality of the food services and free-time activities – that are competitive with other lodge accommodations in the region.
Change to social infrastructure needs
None. Teck commits to implement the following mitigation measures regarding social infrastructure needs (see the response to JRP IR 5.14(a), Table 5.15a-2):
Maintain explicit and enforced lodge, workplace and flight policies with regards to the use of alcohol, drugs and illegal activities.
Provide onsite security services, including controlled gates, check-in procedures, perimeter security fencing and lodge-based security officers on duty 24 hours.
Offer in-house security services to assist the Royal Canadian Mounted Police (RCMP) within, and sometimes outside, the Project lease boundaries (e.g., securing accident scenes and assisting with highway closures).
Develop and implement an emergency response plan which includes the required personnel, procedures and equipment resources (e.g., vehicles, fire response, medical response and rescue).
Develop required mitigation measures for areas adjacent to the Project area based on the FireSmart Wildfire Assessment System and implement in the emergency response plan.
Enter into mutual aid agreements with the Regional Municipality of Wood Buffalo (RMWB) and other oil sands companies that include:
o responding to motor vehicle accidents on Highway #63
o responding to forest fire threats to Fort McKay
o responding to regional spills
Participate in the management of regional emergencies at the RMWB’s Regional Emergency Operations Centre.
Make available onsite health services, including an on-site medical facility staffed by qualified health professionals providing 24-hour on-site primary, emergency and occupational health services.
Consider financial and in-kind contributions to the Northern Lights Health Foundation, where appropriate, to support the efforts of Alberta Health Services to meet the needs of Wood Buffalo residents. Recognizing some of the health concerns in the region Teck is prepared to make health promotion and disease prevention initiatives a focus of their community investment policy.
Provide helicopter or fixed-wing aircraft access via the on-site aerodrome for injured workers requiring rapid evacuation for off-site medical care.
Discuss with other industrial proponents near the Project options for coordinating on-site health facilities and resources.
Assess and support school events and education initiatives identified by rural schools in the study area, as appropriate.
Provide employees with access to the company’s confidential Employee and Family Assistance Plan, which provides support for families and individuals who might experience difficulty dealing with personal, family or work-life issues that can affect one’s health and well-being.
Consider support for community level initiatives including social groups providing assistance to those in need.
Continue providing direct support to community initiatives through its social investment programs.
Offer shift schedules that provide workers with sufficient time off to enjoy leisure activities in their home communities.
Make available onsite recreational opportunities and facilities.
Change to transportation needs
None. Teck commits to implement the following mitigation measures regarding transportation needs (see the response to JRP IR 5.14(a), Table 5.14a-3):
Construct and operate an aerodrome near the Project site.
Use on-site as well as regional lodge accommodations during both construction and operations to reduce worker commutes.
Use bus service for transporting construction and operations workers.
Limit private vehicles brought to the Project site.
Schedule truck traffic, including oversized loads, to off-peak hours.
Use an on-site concrete batch plant; and attempt to source aggregates from pits near to site.
Enforce lodge, workplace and flight policies with regards to the use of alcohol, drugs and illegal activities.
Work with the local RCMP to confirm communication on local effects.
Support the efforts of RMWB and Oil Sands Community Alliance (OSCA) to work with the provincial government to progress improvements to highway infrastructure in a timely way.
Keep responsible regional and provincial planners informed of the Project’s development plans and their timing.
Consult and cooperate with other operators regarding shift scheduling with a view to reduce overlap in commuter traffic.
Provide funding to assist in the maintenance and safety of applicable segments of Highway #63 from Fort McKay to Fort Chipewyan that are affected by the Project.
Frontier Oil Sands Mine Project Appendix 10.12
Table 10.12-12: Potential Adverse Environmental Effect and Mitigation Table – Lac La Biche Metis Local 1909 (continued)
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Potential Adverse Effects
Mitigation Proposed by Lac La Biche
Metis Local 1909 in TLU Study
Mitigation Teck Commits to Implement
Change to municipal infrastructure needs None. Teck commits to implement the following mitigation measures regarding municipal infrastructure (see the response to JRP IR 5.14(a), Table 5.14a-4):
Provide water and sewer services for the different mining areas and the associated processing facilities and infrastructure, including on-site lodges.
Teck commits to implement the following mitigation measures regarding choice of fly-in/fly-out (FIFO) (see the response to JRP IR 5.14(a), Table 5.14a-6):
A FIFO lodge-based approach to construction and operations.
Ongoing monitoring of the operations FIFO model and revisiting the approach should local circumstances change.
Teck’s monitoring will take into consideration input received via its workers, contractors and ongoing local stakeholder and Indigenous engagement process. This would likely include feedback with respect to the social and economic effects of the FIFO model on individual workers, their families and communities.
Commitment to include Fort Chipewyan in a FIFO program.
Engage with potential employees living in Fort Chipewyan to discuss shift schedules and other travel and lodging logistics that influence their choice to work at the Project versus other opportunities.
Discuss with local communities the design of FIFO shifts that best benefit its employees and families while remaining logistically and financially feasible.
Remain open to engaging in broader, regional initiatives, for example through the OSCA and its study of the use of aerodromes in the region.
Change to employment, business and training opportunity needs
None. Teck commits to implement the following mitigation measures regarding employment, business and training opportunity needs (see the response to JRP IR 5.14(a), Table 5.14a-5):
Specific contractual commitments to Indigenous communities on employment, business and training opportunities will be made within Participation Agreements negotiated between Teck and the Indigenous community.
Prioritize recruiting residents from the region first, Alberta second, followed by the rest of Canada, then North America and then overseas countries.
Draw on various sources of labour in Canada that are traditionally under-represented in the labour market, including Indigenous people, immigrants and women.
Put in place a policy to hire local businesses and contractors that are competitive and able to meet the company’s needs is already in place.
Teck will consult with Indigenous communities regarding procurement and employment initiatives such as:
o Establishing mechanisms to enhance employment prospects of local residents, including preferential consideration.
o Using procurement processes that regard local ownership and prevalence of workers residing locally as positive criteria in goods and services vendor selection competitions.
o Establishing monitoring programs that measure local involvement, gather feedback and work with interested parties on how to improve results.
Implement Teck’s relevant charters, codes and policies, including its Indigenous Peoples Policy, when working with Indigenous peoples in seeking to develop lasting mutual benefits that respect Indigenous community’s values – including hiring, training and retention of Indigenous employees.
Utilize what Teck’s has learned to date from local Indigenous communities with which it is engaged for the Project to overcome oil sands specific challenges to Indigenous employment and procurement.
Consider work experience in lieu of a high school graduation for Indigenous peoples.
Work with the Fort McMurray Chamber of Commerce, the Northeastern Alberta Aboriginal Business Association (NAABA) and others to maximize contracting and employment opportunities in the region.
Offer a choice of worker turnaround cycles and opportunity to earn premium pay through overtime.
Continue to work with the Indigenous communities in the area and specifically with the communities of Fort McKay and Fort Chipewyan to develop Indigenous employment and business development program(s) guided by a commitment to: maximize opportunities for local Indigenous businesses to supply services and products in support of Project construction and operations; hire qualified Indigenous people from the communities surrounding the Project and support education, training and investment initiatives in local Indigenous communities, where appropriate.
Teck’s Indigenous community employment and business development program(s) will engage with Indigenous communities on establishing employment and procurement policies and procedures, as well as adaptive management mechanisms specific to Indigenous community employment and procurement.
Teck’s Indigenous community employment and business development program(s), as well as community-specific Participation Agreements will take into consideration input provided by local Indigenous communities, and will be guided by a commitment to: develop substantial opportunities for local Indigenous businesses to supply services and products in support of Project construction and operations; hire qualified Indigenous people from the communities surrounding the Project and support education, training and investment initiatives in local Indigenous communities, where appropriate.
Continuously monitor Teck’s local employment and procurement policies and programs, along with reporting the results of this monitoring as part of ongoing community consultation.
Teck has yet to determine the exact reporting and monitoring mechanisms for its local procurement and employment policies, but will engage with Indigenous communities on mechanisms and expects they will likely be similar to mechanisms used by Teck’s other operations. These might include:
o Total employment, attraction and retention rates, average salary levels and other general human resource data. Where possible, the data will be disaggregated at the local community level.
o Procurement activity, including examination of goods and services sourced from providers in local communities, value and length of contracts, types of goods and services provided and employment and enterprise effects associated with procurement.
o Additional potential mechanisms are identified in Teck’s draft socio-economic monitoring plan in response to JRP IR 5.15(a).
Continue supporting local labour force skills development, and work with communities, government and other industrial proponents on programs that assist community members overcome labour market barriers.
Change to culture
None. Teck commits to implement the following mitigation measures regarding changes to culture (see the response to JRP IR 5.14(a), Tables 5-14a-6 and 5.14a-7):
Continue to expand Teck’s knowledge of, and engagement with, local stakeholders and Indigenous communities near the Project to confirm ongoing and growing participation in Project-related benefits, as well as the design of appropriate and effective mitigation measures to reduce any adverse effect. These efforts are envisioned to include capacity building support within Participation Agreements for Indigenous communities.
Provide cultural diversity awareness training to employees and contractors, focusing on respect for traditional land users as well as respect for Indigenous world views, customs and values.
Consider supportive workplace practices as Teck develops workplace policies and seek local Indigenous community input into cultural awareness programming to be provided at the Project site.
Carry out a review of Teck’s standard bereavement policy, including a review of policies from other fly in/fly out operations in Alberta, as operation specific policies are developed during future planning phases.
Continuing to provide cultural awareness training for all Project staff and contractors.
Considering key Indigenous access routes and access preferences in the Project’s draft Access Management Plan (AMP).
Considering cultural keystone species in the wildlife management and mitigation plan, FHCL and biodiversity management plan.
Incorporating and using Indigenous place names where applicable.
Supporting community-led projects to document Indigenous place names in their respective traditional territories.
Contributing to language retention programs and other programs that support retaining Indigenous culture, knowledge and practice (e.g., culture camps for youth).
Discuss with local communities the design of fly in/fly out shifts that best benefit its employees and families while remaining logistically and financially feasible.
Frontier Oil Sands Mine Project Appendix 10.12
Table 10.12-12: Potential Adverse Environmental Effect and Mitigation Table – Lac La Biche Metis Local 1909 (continued)
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Potential Adverse Effects
Mitigation Proposed by Lac La Biche
Metis Local 1909 in TLU Study
Mitigation Teck Commits to Implement
Access
Change to access near the Project disturbance area
None. Teck has developed a draft access management plan (AMP) for the Project to facilitate access to or through Teck’s mineral surface lease to the extent possible while maintaining worker and public safety (see the response to JRP 4.5, Appendix 4.5). Teck has proposed next steps to Indigenous groups that would provide the opportunity for land users and community members to provide direct input into developing access mitigation measures. This input will refine the draft AMP.
Teck commits to implement the following mitigation measures to reduce potential effects on changes to access near the Project disturbance area (see Volume 3, Appendix 17H, Section 17H.8.2 of the Project Update) and the response to JRP IR 10.9):
All individuals wanting to gain access to or through lands being actively developed, which is generally Teck’s mineral surface lease (MSL), will be required to submit an access request.
Traditional land users will be granted temporary access to and through the PDA according to the policy and processes set out in the AMP.
Traditional land users will not have to meet worker site access requirements but will be escorted by someone who has permanent site access (i.e., a worker).
Access through, and to portions of the PDA not being actively developed will not require an access request form be submitted. Individuals will be required to contact the site’s security office and provide adequate notice about when they plan to be in the area, who will be present, and the intended activities and general location(s) as they relate to Teck leases. All individuals passing through the PDA will have to check in at the security office and will be escorted by a Teck worker. Teck understands that Aboriginal communities desire that the advance notice period.
Throughout the life of the mine, access to locations in the PDA by Aboriginal community members will be based on mine advance. For safety reasons, harvesting and use of firearms would not be permitted in areas being actively mined or within and around facilities associated with the mine.
The River Road will be maintained through operations and will provide access to the Fish Habitat Compensation Lake, aerodrome, and areas north of the PDA.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Traditional Land Use
Change in availability of resources (wildlife, fish and vegetation), culturally important sites or areas for traditional activities and use of lands
None. Teck commits to implement the following mitigation measures to reduce changes in availability of resources (wildlife, fish and vegetation), culturally important sites or areas for traditional activities and use of lands (assessed in Volume 3, Section 17.6 of the Project Update) (see the response to JRP IR 4.6, Table 4.6-1):
Grant traditional land users temporary access to and through the PDA according to the policy and processes set out in the draft access management plan.
Implement measures to mitigate Project-related effects on wildlife through the wildlife monitoring and mitigation plan.
Engage Indigenous communities in the development of a biodiversity management plan.
Implement measures to mitigate Project-related effects on fish and fish habitat through the detailed fisheries offsetting plan.
Implement measures to reduce Project-related effects on vegetation through the conservation closure and reclamation plan and the reclamation monitoring plan.
Historical resources sites in the PDA that Alberta Culture and Tourism (ACT) determines to have moderate to high heritage value will meet the requirements of ACT and aim to meet the desires of Indigenous communities.
Teck commits to implement the following mitigation measures to reduce effects on the land use experience for traditional land users (see the response to JRP IR 4.6, Table 4.6-1):
Establish Participation Agreements with Indigenous communities.
Invite traditional users to harvest traditional plants before disturbance.
Support the planning and implementation of an excursion for Indigenous communities within the terrestrial local study area prior to Project-related disturbance to describe Indigenous values, access and to recommend mitigation to avoid or limit effects on Indigenous access values.
Provide cultural diversity awareness training to employees and contractors focusing on respect for Indigenous land users, traplines, cabins, trails and equipment, as well as respect for Indigenous world views, customs and values.
Compensate Indigenous trappers following industry-community standards and the Alberta Trappers Compensation Program.
Project personnel will be prohibited from fishing, hunting and trapping within the PDA during work rotations, which is when Teck’s policies’ can be enforced.
Project personnel will be prohibited from using personal recreation vehicles within the PDA.
Investigate with potentially affected Indigenous communities through the Reclamation Working Group the concept of incorporating cultural values into reclamation planning.
Supporting documentation of community-specific cultural heritage.
Teck has developed a Draft Traditional Land Use Mitigation, Monitoring and Adaptive Management Plan (see the response to JRP IR 4.6, Appendix 4.6). Teck will continue to seek input and engage with Indigenous groups, as well as regulators where appropriate, as part of finalizing this plan. Once finalized, Teck will continue to pursue collaborative engagement processes with Indigenous groups as outlined in the plan. Through these collaborative engagement processes Teck will aim to minimize and mitigate potential Project effects on traditional land use. Once finalized, the plan will include a communication management section, which will outline how findings of the program will be communicated to interested parties.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Notes:
NOx = oxides of nitrogen; SO2 = sulphur dioxide; PM2.5 = particulate matter
Frontier Oil Sands Mine Project Appendix 10.12
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7 Métis Nation of Alberta Region 1
A summary of established or asserted Aboriginal rights, current use of lands and resources for traditional
purposes and cultural and physical heritage features as described by Métis Nation of Alberta (MNA
Region 1) is presented in Table 10.12-13.
Table 10.12-13: Métis Nation of Alberta Region 1 Rights, Land Uses and Cultural and Physical Heritage Features
Established or Asserted Aboriginal, Current Use of Lands and Resources for Traditional Purposes
Cultural and Physical Heritage Feature
Hunting
Fishing
Trapping
Gathering
River-bed harvesting
Traditional Métis harvesting
Access to preferred areas to hunt, fish and gather by water
Cultural and social gatherings
Natural and traditional resource conservation
Potential adverse Project effects on MNA Region 1’s established or asserted Aboriginal rights, current
use of lands and resources for traditional purposes or cultural and physical heritage are presented in
Table 10.12-14. Also included is mitigation that Teck has committed to implement to reduce these
potential effects.
Fort McKay Métis, Métis Local 125, Métis Local 1935 and Métis Local 1909 are all members of MNA
Region 1. Teck has engaged directly with potentially-affected locals in the development of TLU studies
and CIAs specific to the Project. As a result, no TLU studies or CIAs were completed specific to MNA
Region 1, and no mitigation proposed by MNA Region 1 is included in Table 10.12-14.
Frontier Oil Sands Miine Project Appendix 10.12
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Table 10.12-14: Potential Adverse Environmental Effect and Mitigation Table – Métis Nation of Alberta Region 1
Potential Adverse Effects Mitigation Proposed by Métis Nation of Alberta Region 1
Mitigation Teck Commits to Implement
Hydrology and Water Quality
Changes in flows, water levels and open water areas
None. The Athabasca River will satisfy the Project’s makeup water requirements, and an off-stream storage pond (OSSP) will supply the Project with water during periods when river water withdrawal is restricted (see the response to Joint Review Panel (JRP) Information Request (IR) 10.26, Appendix 10.26, Section 7.1).
Teck commits to implement the following mitigation measures to reduce changes in flows and water levels in receiving waterbodies (see the response to JRP IR 10.25, Appendix 10.25, Table 10.25-1):
Reduce changes to flows in Ronald Lake by using a flow splitter on the Redclay Creek diversion during operations.
Reduce changes to flows in Big Creek by using a flow splitter on the Big Creek diversion during operations.
Distribute muskeg drainage operations through the mine life, thereby avoiding a large increase in flows in the receiving waters.
Reduce effects of closed-circuit operations on flows and water levels in receiving waters by diverting natural watercourses that will not be disturbed by the mining operations around the mining area to receiving watercourses.
Reduce river-water withdrawal requirements from the Athabasca River by maximizing closed-circuit recycling of surface and groundwater where practical, and by storing sufficient amounts of water in an off-stream storage pond in the event of extended withdrawal restrictions from the Athabasca River.
Progressively construct and develop diversion systems, which helps limit the change in open-water areas during construction and operation by providing new drainage channels to replace the loss of natural watercourses and waterbodies.
Reduce changes to flows and water levels in receiving waters by developing a closure drainage layout that will limit changes in drainage areas contributing flows to the receiving watercourses relative to predevelopment conditions.
Design watercourses, waterbodies and wetlands during reclamation to attenuate floods.
Teck is committed to continue to consult meaningfully with, and engage, all potentially affected Indigenous groups at both a Project-specific and regional level to reduce and mitigate potential Project and cumulative effects on hydrology and surface water quality, including continuing discussions regarding hydrology and surface water quality concerns and is prepared to consider additional mitigation measures to address these concerns (see the response to JRP IR 10.25, Appendix 10.25).
Teck has developed a Draft Hydrology and Water Quality Mitigation, Monitoring and Adaptive Management Plan (see the response to JRP IR 10.25, Appendix 10.25). Once finalized, the plan will include a communication management section, which will outline how findings of the program will be communicated to interested parties.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Changes in sediment yields, concentrations and channel regimes (geomorphology)
None. Teck commits to implement the following mitigation measures to limit release of Total Suspended Solids (TSS) (see the response to JRP IR 10.25, Appendix 10.25, Table 10.25-1):
Follow relevant regulatory guidelines, standards and best management practices during construction and operation to reduce the risk of increased sediment loadings to receiving watercourses.
Construct and operate sedimentation ponds to settle TSS where necessary.
Control sediment generation in diversion channels through revegetation of streambanks, overbank areas and berms as soon as possible after construction and by the use of channel armour (riprap), where required.
Direct muskeg and overburden drainage waters to polishing ponds equipped with oil-separation capability.
Reduce sediment yields from reclaimed surfaces by developing appropriate final topography and soil moisture conditions.
Resuspension of sediments from the bottom of polishing ponds, wetlands and pit lakes will be reduced through appropriate hydraulic design.
Reduce gullying and channel erosion by developing robust and sustainable reclamation drainage systems with built-in self-healing capability and robustness similar to natural drainage systems.
Teck commits to implement the following mitigation measures to reduce changes in flood flows and geomorphology downstream of the Project (see the response to JRP IR 10.25, Appendix 10.25, Table 10.25-1):
Limit changes in flood flows in receiving watercourses relative to predevelopment conditions. Mitigation measures listed for the “reduce changes in flows and water levels” above are relevant for mitigating flood flows.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Direct water emissions:
Muskeg drainage and overburden dewatering flows
Drainage from operating and reclaimed mine site
Basal water sands depressurization
Process-affected seepages from backfilled mine pits and tailings disposal areas
None.
Teck commits to implement the following mitigation measures to limit the release of ions, nutrients, metals, polycyclic aromatic hydrocarbons (PAHs) and other parameters during operations and closure and protect sediment quality in downstream watercourses and waterbodies (see the response to JRP IR 10.25, Appendix 10.25, Table 10.25-1):
Recycle process-affected waters and runoff within the Project disturbance area (PDA) in a closed-circuit system during operations.
Using a perimeter ditch and groundwater wells to capture and pump back seepages and runoff from the external tailings areas (ETAs) back into the tailings areas during operations.
Design the closure drainage system to capture seepage and runoff from ETAs, external disposal areas (EDAs) and the Frontier Project plant site and directing it to wetlands, pit lakes or constructed reclamation lakes during the mine closure management phase.
Use wetlands, constructed reclamation lakes and pit lakes during and after the decommissioning and closure phases to provide biological remediation and settling of particulate materials in reclamation waters before discharge.
Respond to spills using best management practices. Project activities will follow safety protocols designed to limit accidents and reduce effects if an accident should occur.
Teck commits to the following mitigation measures to manage depressurization water during preproduction (see Volume 1, Section 7.6.5 and 7.8.4 of the Project Update):
Teck plans to manage depressurization water during preproduction by storing approximately half of it in a storage pond at surface and reinjecting the remaining half into the BWS aquifer.
Teck is committed to continue to consult meaningfully with, and engage, all potentially affected Indigenous groups at both a Project-specific and regional level to reduce and mitigate potential Project and cumulative effects on hydrology and surface water quality, including continuing discussions regarding hydrology and surface water quality concerns and is prepared to consider additional mitigation measures to address these concerns (see the response to JRP IR 10.25, Appendix 10.25).
Teck has developed a Draft Hydrology and Water Quality Mitigation, Monitoring and Adaptive Management Plan (see the response to JRP IR 10.25, Appendix 10.25). Once finalized, the plan will include a communication management section, which will outline how findings of the program will be communicated to interested parties.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Pit lake releases None. Teck will leverage the knowledge gained through its other reclamation efforts, along with research through regional initiatives such as Canada’s Oil Sands Innovation Alliance (COSIA), to develop healthy, functional ecosystems in the Project pit lakes (see the response to JRP IR 2.3).
Teck also commits to implement the following mitigation measures when designing closure drainage and pit lakes for hydrological sustainability and to promote effective passive treatment of process-affected waters and to support a viable aquatic ecosystem prior to release and to sequester tailings and other mine waste in the most appropriate location at mine closure (see the response to JRP IR 10.25, Appendix 10.25, Table 10.25-1):
Frontier Oil Sands Mine Project Appendix 10.12
Table 10.12-14: Potential Adverse Environmental Effect and Mitigation Table – Métis Nation of Alberta Region 1 (continued)
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Potential Adverse Effects Mitigation Proposed by Métis Nation of Alberta Region 1
Mitigation Teck Commits to Implement
Exclude tailings from pit lakes.
Do not release water from pit lakes until acceptable quality is achieved.
Maintain the water balance of the pit lakes with sufficient inflows to compensate for evaporative losses.
Manage the rate of Athabasca River water input to pit lakes as appropriate to confirm water quality filling targets are met and to comply with Athabasca river low flow restrictions.
Include wetlands reclamation lakes for treatment purposes in reclamation drainages to the pit lakes.
Teck is committed to continue to consult meaningfully with, and engage, all potentially affected Indigenous groups at both a Project-specific and regional level to reduce and mitigate potential Project and cumulative effects on hydrology and surface water quality, including continuing discussions regarding hydrology and surface water quality concerns and is prepared to consider additional mitigation measures to address these concerns (see the response to JRP IR 10.25, Appendix 10.25).
Teck has developed a Draft Hydrology and Water Quality Mitigation, Monitoring and Adaptive Management Plan (see the response to JRP IR 10.25, Appendix 10.25). Once finalized, the plan will include a communication management section, which will outline how findings of the program will be communicated to interested parties.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Changes in quality of groundwater and surface water downgradient of EDAs
None. Teck commits to implement the following mitigation measures to maintain surface water quality in consideration of surface flows into and out of the Project area and groundwater discharge (see the response to JRP IR 10.25, Appendix 10.25, Table 10.25-1):
Groundwater and surface waters draining EDAs will be captured if monitoring data indicate that the drainage waters are unsuitable for release.
Teck is committed to continue to consult meaningfully with, and engage, all potentially affected Indigenous groups at both a Project-specific and regional level to reduce and mitigate potential Project and cumulative effects on hydrology and surface water quality, including continuing discussions regarding hydrology and surface water quality concerns and is prepared to consider additional mitigation measures to address these concerns (see the response to JRP IR 10.25, Appendix 10.25).
Teck has developed a Draft Hydrology and Water Quality Mitigation, Monitoring and Adaptive Management Plan (see the response to JRP IR 10.25, Appendix 10.25). Once finalized, the plan will include a communication management section, which will outline how findings of the program will be communicated to interested parties.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Air Quality and Odour
NOX emissions None. Teck commits to implement the following mitigation measures to reduce NOX emissions from combustion sources (see the response to JRP IR 3.18, Table 3.18-1):
Use natural gas as a fuel for the cogeneration plant and boilers and heaters.
Dry low NOX technology to reduce NOX emissions and increase cogeneration plant efficiency.
Boiler and heater technology that will meet provincial and federal government emission requirements.
Purchase Tier IV compliant haul trucks when they become available.
Optimize mine planning to reduce haul distances.
Develop and implement an anti-idling program for the mine fleet.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
SO2 emissions None. Teck commits to implement the following mitigation measures to reduce SO2 emissions from combustion sources (see the response to JRP IR 3.18, Table 3.18-1):
Use natural gas as a fuel for the cogeneration plant and boilers and heaters.
Use ultra-low sulphur diesel for the mine fleet.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
PM2.5 and dust emissions
None. Teck commits to implement the following mitigation measures to reduce PM2.5 emissions from combustion sources (see the response to JRP IR 3.18, Table 3.18-1):
Use natural gas as a fuel for the cogeneration plant and boilers and heaters.
Boiler and heater technology that will meet provincial and national government emission requirements.
Purchase Tier IV compliant haul trucks when they become available.
Optimize mine planning to reduce haul distances.
Develop and implement an anti-idling program for the mine fleet.
Teck commits to implement the following mitigation measures to reduce fugitive dust emissions (see the response to JRP IR 3.18, Table 3.18-1):
Dust mitigation measures to be applied to onsite roads during construction include appropriate selection of road materials, limiting vehicle speeds, surface watering, progressive reclamation, temporary vegetation of disturbed land and retain natural vegetation as windbreaks.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Hydrocarbon and reduced sulphur emissions and secondary organic aerosol precursor emissions
None. Teck commits to implement the following mitigation measures to reduce fugitive plant emissions (see the response to JRP IR 3.18, Table 3.18-1):
Use floating roof tanks where appropriate and a vapour recovery system to condense and recover vapours from storage tanks and process areas.
Use dual solvent vapour recovery units to provide full redundancy.
Conduct a leak detection and repair (LDAR) program to identify leaking components and to prioritize associated repairs.
Teck commits to implement the following mitigation measures to reduce fugitive mine face emissions (see the response to JRP IR 3.18, Table 3.18-1):
Mitigation not currently known.
Teck commits to implement the following mitigation measures to reduce fugitive tailings area emissions (see the response to JRP IR 3.18, Table 3.18-1):
Frontier Oil Sands Mine Project Appendix 10.12
Table 10.12-14: Potential Adverse Environmental Effect and Mitigation Table – Métis Nation of Alberta Region 1 (continued)
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Potential Adverse Effects Mitigation Proposed by Métis Nation of Alberta Region 1
Mitigation Teck Commits to Implement
Tailing solvent recovery unit to maintain losses to less than four volumes of solvent to 1,000 volumes of bitumen produced.
Teck commits to implement the following mitigation measures to reduce hydrocarbon and reduced sulphur emissions from combustion sources (see the response to JRP IR 3.18, Table 3.18-1):
Use natural gas as a fuel for the cogeneration plant and boilers and heaters.
Purchase Tier IV compliant haul trucks when they become available.
Optimize mine planning to reduce haul distances.
Develop and implement an anti-idling program for the mine fleet.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Odour None. Teck has developed a draft Odour Management and Response Plan (see the response to JRP IR 3.13, Appendix 3.13). The draft Plan. The Plan’s goals are mitigation, monitoring, participation in regional complaint process, and correlation of complaints to Project activities to determine response actions. The Plan will be finalized following consultation with Indigenous communities, regulators and stakeholders.
At any time during Project operation, nearby residences will be able to contact Teck if they are concerned that Project operations are causing odours. The contact will be documented, investigative action will be initiated to determine the potential source, and the caller will be notified. If a source can be identified, a review will be undertaken to implement corrective action to reduce the potential for future occurrences (ERCB Round 1 SIR 113a; Appendix 3.13).
Acoustics
Change in sound levels
None. Teck has made an overall commitment to managing and promptly addressing all noise-related concerns (see Volume 3, Section 3.4.9.2, Project Update) and will develop a Noise Management Plan (see Volume 3, Section 3.4.9.1, Project Update).
Teck also commits to implement the following mitigation measures to reduce changes in sound levels (see Volume 3, Appendix 17H, Section 17H.5 of the Project Update and the response to JRP IR 1.3, Table 1.4-1):
Vehicles will be maintained in good working condition (e.g., mufflers will be maintained) and speed limits will be enforced.
Emergency alarms will be tested during daytime, where reasonably practical.
Acoustic performance of building wall construction will meet a minimum sound transmission class (STC) rating of 29, based on published data in the North American Insulation Manufacturers Association for a pre-engineered structure.
For outdoor equipment, the manufacturer incorporates mitigation in the equipment design to achieve the published sound power level.
Noise effects will be mitigated using various measures, including but not limited to the following:
o haul trucks exhaust silencer
o haul truck speed
o trip frequency (number of trips per daytime and nighttime period)
o route location or alignment
Ventilation openings (i.e., air intake and exhaust openings) will be fitted with appropriate acoustic silencers, louvers, or plenums, where applicable, to reduce outdoor sound transmission from indoor equipment.
Buildings housing indoor noise-generating equipment will be appropriately sealed to reduce noise.
Where practical, flanking path and penetrations from plumbing, heating ducts and electrical wire in the buildings will be properly insulated and covered to reduce noise.
Appropriate acoustical lagging will be installed to provide additional attenuation to the steel casing, where practical.
Vibration isolation pads, resilient mounts on equipment, resilient pipe support systems, and dampers will be installed where appropriate.
Teck will incorporate best management practices to reduce Project-related noise into Daily Operational Procedures, Long-Term Operational Procedures, design for low-noise facilities, and performance measurement as described in SPOG (2012) Best Practices Document, where appropriate (ERCB Round 1 SIR 116; Volume 3, Section 3.4.9.1 of the Project Update), including:
Daily Operational Procedures
Keeping compressor station doors and windows closed
Using belt dressing
Inspecting and repairing mufflers
Running fans slower at night (variable frequency drive [VFD])
Using vent silencers on buildings
Using soundproofing (insulation and lagging)
Troubleshooting transient noise
Minimizing flaring and venting
Considering gravel pack around compressor building skids
Developing noise check in daily reading sheets
Long-Term Operational Procedures
Responding quickly to noise concerns
Establishing baseline noise levels (in plant, at fence-line, or both) and resurvey to determine trends
Conducting regular assessment of noise control opportunities
Using best practical technology for noise control
Maintaining communication links with noise sensitive receptors and communities
Being aware of noise from contractors (e.g., service rigs) and developing processes to meet best practice expectations
Scheduling work to create the least amount of noise effects on noise sensitive receptors and keeping those affected informed
Design for Low Noise Facilities
Frontier Oil Sands Mine Project Appendix 10.12
Table 10.12-14: Potential Adverse Environmental Effect and Mitigation Table – Métis Nation of Alberta Region 1 (continued)
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Potential Adverse Effects Mitigation Proposed by Métis Nation of Alberta Region 1
Mitigation Teck Commits to Implement
Considering low noise electric drives versus engine driven compressors
Designing cooler fans for low tip velocity
Orienting noise sources away from residents
Using acoustical pipe lagging
Installing VFDs on coolers
Performance Measurement
Conducting measurements and establishing baseline data
Using best practices as part of the company’s operating procedures
Visual
Change to visual environment None. Teck commits to implement the following mitigation measures to reduce changes to visual effects (see Volume 1, Section 8.3.6, Volume 3, Section 16.4.6, Volume 3, Section 18.10.4.2, Volume 3, Section 18.11.5.4 and Volume 3, Appendix 17H, Section 17H.7 of the Project Update):
Maintaining vegetated buffers between the Project and the Athabasca River as well as along Project transportation corridors to the extent feasible where safety concerns are not an issue.
Using construction materials that reduce contrast, limit visual attraction to Project features, and blending built structures into the natural surrounding environment.
Using construction materials, where practicable, that minimize light reflection, potentially reducing viewing distances of Project features
Reclamation techniques will be used that integrate closure plans with the surrounding landscape.
Teck will seek to develop closure plans that:
o Include integration and contouring of slopes that mimic natural topography.
o Focus on establishing a variety of vegetation communities.
o Avoid unnatural-looking breaks at development boundaries.
Planting a narrow band of white spruce along the edge of the river water intake (RWI) cofferdam and plant dogwood on the cofferdam, except in areas where tall vegetation would impede any maintenance or present safety concerns.
Completing reclamation in the RWI area to minimize erosion and slope instability.
Using lighting that minimizes light pollution.
At closure, infrastructure will be removed and the Project will be reclaimed using vegetation types similar, though not identical to existing conditions, creating a continuous vegetated landscape.
A lighting plan will be developed during future stages of engineering to avoid over-illumination. Lighting design will be part of future stages of engineering, and Teck will consult with interested Indigenous communities about lighting considerations.
Finish the Athabasca River Bridge with low-glare materials and plant vegetation buffers near the bridge. Teck also commits to clear minimal vegetation and to vegetate cleared areas.
Retain treed buffers around or near watercourses.
Fish and Fish Habitat
Change in productive fish habitat
None. Fish habitat of equivalent or higher productivity than that affected by the Project will be created through offsetting measures where prevention of adverse habitat alteration or loss (i.e., reduced habitat productivity or loss of productive habitat area) is not feasible (see the draft Detailed Fisheries Offsetting Plan, the response to JRP IR 2.1, Appendix 2.1).
Teck also commits to implement the following mitigation measures to avoid or reduce changes in fish habitat quantity or quality (see the response to JRP IR 2.1, Table 5):
To avoid or reduce sedimentation:
o Temporary and permanent erosion and sediment control measures for construction activities and disturbed areas.
o Stabilization and revegetation of disturbed areas.
o Isolation of instream work areas where they are required.
o Best management practices and regulatory guidelines for construction activities in and near watercourses/waterbodies for erosion and sediment control.
o Polishing ponds or other measures to reduce suspended sediment concentrations in discharge waters to avoid increases in sedimentation in the receiving environment.
o Appropriate design of constructed channels and ponds to reduce internal erosion and generation of suspended sediments.
o Appropriate design and construction of reclaimed landscape to reduce sediment yield.
To avoid or reduce changes to water quality:
o Passing muskeg drainage and overburden water through polishing ponds and drainage ditches to reduce changes in water temperatures and dissolved oxygen concentrations.
o Recycling of process affected waters during operations.
o Capture and recycling of ETA seepage and run off water during operations, and use of a passive seepage control system at closure.
o Use of wetlands, pit lakes and constructed reclamation lakes in the closure drainage system to provide biological remediation before release to the environment.
o Removal of organic material from fish habitat compensation lake (FHCL) area prior to flooding.
To avoid or reduce changes to habitat area:
o Diversion of watercourses around the PDA to return natural upslope water back to the diverted watercourse to preserve flows and avoid elimination of downstream habitats.
o Provision of a flow splitter on the diversion channel that will collect water from both upper Redclay Creek and Unnamed Creek 17 to appropriately apportion the flows in lower Redclay Creek and Unnamed Creek 17 to avoid flow changes in the Ronald Lake watershed.
o Operation of the RWI and Off Stream Storage Pond (OSSP) in compliance with the Lower Athabasca River Surface Water Quantity Management Framework.
o Design of the closure drainage channels and pit lakes to provide habitats capable of supporting aquatic ecosystems.
o Best management practices and regulatory guidelines to ensure construction and operation of the RWI, Athabasca River bridge and watercourse crossings associated with access roads do not interfere with fish passage and access to available habitats.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Frontier Oil Sands Mine Project Appendix 10.12
Table 10.12-14: Potential Adverse Environmental Effect and Mitigation Table – Métis Nation of Alberta Region 1 (continued)
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Potential Adverse Effects Mitigation Proposed by Métis Nation of Alberta Region 1
Mitigation Teck Commits to Implement
Change in fish abundance None. eck commits to implement the following mitigation measures to avoid or reduce changes in fish abundance (see the response to JRP IR 2.1, Table 5):
Fish rescue operations to capture and relocate fish prior to habitat dewatering.
Screening of the RWI in compliance with regulatory guidelines to mitigate fish entrainment or impingement.
Best management practices and regulatory guidelines for scheduling construction activities in and near waterbodies/watercourse to avoid sensitive time periods in adjacent or downstream fish-bearing watercourses.
Education of Project personnel on sustainable fishing practices to support a Teck applied prohibition on their fishing in watercourses or waterbodies in the PDA to mitigate potential increases in recreational fishing pressure.
Access Management Plan for the PDA to limit access to fish bearing habitats to mitigate increased fishing pressure.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Change in fish and fish habitat diversity None. Teck commits to implement the following mitigation measures to avoid or reduce changes in fish and fish habitat diversity (see the response to JRP IR 2.1, Table 5):
Several of the measures intended to avoid or mitigate effects to fish habitat and fish abundance also apply to fish and fish habitat diversity, in cases where they preserve fish and productive fish habitats or create new habitats, including:
o Diversions designed to preserve flows and avoid elimination of downstream habitats.
o Closure drainage channels and pit lakes designed to provide habitats capable of supporting aquatic ecosystems.
o Fish rescue operations.
o Screening of the RWI.
o Education and prohibition of Project personnel from fishing in the PDA.
o Access Management for the PDA to limit access to fish bearing habitats.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Wildlife
Change in wildlife habitat availability None. Teck commits to implement the following mitigation measures to reduce direct habitat loss (see the response to JRP IR 7.14, Table 7.14-1):
Limit the size of the east side access road right-of-way (ROW) and temporary workspace to the extent practical.
Limit the Athabasca River bridge footprint in riparian areas.
Carry out progressive reclamation to reclaim disturbed wildlife habitat as portions of the mine footprint become available.
Develop a weed management plan.
Teck commits to implement the following mitigation measures to reduce indirect habitat loss (see the response to JRP IR 7.14, Table 7.14-1):
Implement strategies to reduce noise and light effects, including design considerations (e.g., Frontier Project plant site engineering and aerodrome operation within regulatory and safety constraints).
Limiting employee and contractor access to identified areas of high-quality habitat adjacent to Project footprint.
Teck commits to developing a Biodiversity Management Plan (BMP) with the underlying goal of optimizing reclamation during operations to reduce offsetting of residual environmental effects (see the response to JRP IR 7.15).
Teck has developed a Draft Wildlife Mitigation, Monitoring and Adaptive Management Plan (WMMP; see the response to JRP IR 7.14, Appendix 7.14). Teck has proposed steps to Indigenous groups that would provide the opportunity for land users and community members to provide direct input into developing wildlife mitigation measures. Input will refine this draft WMMP. Once finalized, the plan will include a communication management section, which will outline how findings of the program will be communicated to interested parties.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Change in wildlife landscape connectivity None. Teck commits to implement the following mitigation measures to reduce change to landscape connectivity (see the response to JRP IR 7.14, Table 7.14-1):
Carry out progressive reclamation to restore habitat for movement as portions of the mine footprint become available.
To maintain connectivity between Birch Mountains and Athabasca River:
o Coordinate development activities with Canadian Natural Resources Limited (CNRL) who acquired the Pierre River Mine oil sands leases formerly held by Shell Canada Limited should CNRL reapply for and develop the Pierre River Mine project.
o Develop an integrated land management strategy for the Project in consultation with industry, the province, Indigenous communities, and stakeholders.
Provide wildlife passage under both sides of the Athabasca River bridge and river water intake bridge to Dalkin Island to allow north–south wildlife movement along river banks using crossing design considerations (e.g., bridge height and length) outlined in Clevenger and Huijser (2011) and GOA (2011).
Set up educational signage to limit human use of wildlife underpasses.
Evaluate wing fencing along the approach to crossing passages (at least 2.4 m high for large mammals as per GOA 2011) as part of the crossing structure design.
Provide appropriate walking substrate along the wildlife underpass.
Create vegetated buffers adjacent to wildlife underpasses to increase movement opportunities for a variety of species.
Provide coarse woody debris (e.g., stumps) along the wildlife underpass to provide cover and increase use by furbearers and other small mammals.
Teck has developed a Draft WMMP (see the response to JRP IR 7.14, Appendix 7.14). Teck has proposed steps to Indigenous groups that would provide the opportunity for land users and community members to provide direct input into developing wildlife mitigation measures. Input will refine this draft WMMP. Once finalized, the plan will include a communication management section, which will outline how findings of the program will be communicated to interested parties.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Change in wildlife mortality risk
None.
Teck commits to implement the following mitigation measures to reduce wildlife mortality risk resulting from vehicle–wildlife collisions (see the response to JRP IR 7.14, Table 7.14-1):
Implement fly-in/fly-out policy for workers to reduce vehicular traffic volume.
Erect wildlife cautionary signage on access roads.
Foster environmental awareness with speed restrictions on access roads report Project-related wildlife fatalities.
Frontier Oil Sands Mine Project Appendix 10.12
Table 10.12-14: Potential Adverse Environmental Effect and Mitigation Table – Métis Nation of Alberta Region 1 (continued)
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Potential Adverse Effects Mitigation Proposed by Métis Nation of Alberta Region 1
Mitigation Teck Commits to Implement
Provide vegetation maintenance at roadsides (vegetation will be trimmed regularly to discourage roadside foraging and prevent visual obstruction of wildlife).
Develop seed mixes for roadside reclamation from less palatable species to reduce wildlife attraction to road edges.
Design the road to maximize line of sight.
Remove road kill as soon as practical.
Teck commits to implement the following mitigation measures to reduce wildlife mortality risk resulting from wildlife interactions with equipment (see the response to JRP IR 7.14, Table 7.14-1):
Implement preconstruction surveys for active wildlife habitat features (e.g., nests, breeding wetlands) before starting early works.
Avoid vegetation clearing during the recommended May 1 to August 10 migratory bird-breeding period for the boreal ecozone per Environment Canada guidelines; note that in species at risk habitat, a more conservative breeding window of April 1 to August 31 might apply (Gregoire 2014, pers. comm.); complete nest surveys if clearing activities occur during the breeding window.
Conduct owl nest search if clearing is scheduled within the non-migratory breeding bird window, March 1 to April 15 (based on Enhanced Approval Process guidelines for barred owl, GOA 2013).
Reduce on disturbance of amphibian breeding and overwintering habitat (where possible).
Teck commits to implement the following mitigation measures to reduce wildlife mortality risk resulting from interactions with Infrastructure (see the response to JRP IR 7.14, Table 7.14-1):
Create fuel and chemical spill contingency and response plans.
Confirm adequate spill protection for all fuel storage facilities.
Monitor and maintain waste disposal sites, wastewater storage areas and runoff control structures to prevent surface water impacts.
During overburden dewatering, intermittently backslope the sides of drainage ditches to allow for wildlife crossings and to reduce the potential for entrapment.
Use visible markers, such as aviation spheres and spiral vibration dampeners to make transmission lines near waterfowl staging and potential stopover areas more visible to birds, and where possible, design transmission lines to match the height of surrounding trees to reduce wire strikes by birds.
Teck commits to implement the following mitigation measures to reduce wildlife mortality risk resulting from wildlife–human conflicts (see the response to JRP IR 7.14, Table 7.14-1):
Implement a food waste-management strategy to prevent attraction of nuisance wildlife.
Confirm wildlife is not harassed or fed (to prevent habituation).
Provide wildlife awareness training to Project staff and contractors to reduce disturbance and negative human/bear interactions.
Provide all field staff with bear-aware training courses, personal protective equipment (e.g., bear spray, bear bangers, air horns) and training on proper use of equipment.
Develop a nuisance wildlife mitigation and monitoring plan in cooperation with the regulators.
Teck commits to implement the following mitigation measures to reduce wildlife mortality risk resulting from increased hunter access (see the response to JRP IR 7.14, Table 7.14-1):
Implement deactivation plans for roads no longer in use.
Prohibit construction and operations personnel and contractors from hunting and trapping while working.
Disallow personal recreational vehicle use onsite.
Prohibit firearms on Project lands or at Project facilities.
Consider requesting a Directors Order to limit public access to the west side of the Athabasca River along Project roads.
Teck has developed a Draft WMMP (see the response to JRP IR 7.14, Appendix 7.14). Teck has proposed steps to Indigenous groups that would provide the opportunity for land users and community members to provide direct input into developing wildlife mitigation measures. Input will refine this draft WMMP. Once finalized, the plan will include a communication management section, which will outline how findings of the program will be communicated to interested parties.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Waterfowl
Change in bird mortality risk
None.
Teck commits to implement the following mitigation measures to reduce migratory water bird mortality risk resulting from the use of ponds (see the response to JRP IR 7.10, Table 7.10-1):
Develop detailed construction and operational procedures and mitigation measures to reduce wildlife mortality during tailings area start-up.
Design the sides of wastewater ponds to reduce attractiveness to birds (e.g., using gravel for sides).
Clear trees and above-ground vegetation including shrubs, herbs and the ground layer prior to placement of tailings into tailings disposal areas.
Remove peat from tailings area prior to flooding.
Develop detailed construction and operational procedures and mitigation measures to reduce wildlife mortality during tailings area start-up.
Reduce attractiveness of tailings areas for birds by keeping the inner walls of the tailings dyke free of vegetation.
Keep slopes of tailings areas as steep as possible to reduce “black beach” areas.
Implement procedure for removing any peat mats that float to the surface of the tailings area.
Implement procedure for controlling floating bitumen mats.
Manage the use and operation of anthropogenic lighting around wastewater ponds and tailings areas.
Bird deterrent systems will be used to discourage birds from landing on wastewater ponds and tailings areas.
Teck commits to implement the following mitigation measure to reduce the potential for birds to land in ponds containing process-affected water (see the response to ESRD/CEAA Round 3 SIR 64):
Bird deterrent systems will be installed on all ponds associated with the Project that have process-affected water that could be detrimental to birds.
Teck commits to implement the following mitigation measures to maximize recovery efficiency should birds use ponds (see the response to JRP IR 7.10, Table 7.10-1):
Develop procedure for handling of any bird recovered from wastewater ponds or tailings areas.
Procedure will be in compliance with directions received from the local Alberta Fish and Wildlife office and/or the Alberta Environment and Parks (AEP) wildlife biologist.
Procedure will also be in compliance with directions from Environment and Climate Change Canada with respect to whooping cranes.
Frontier Oil Sands Mine Project Appendix 10.12
Table 10.12-14: Potential Adverse Environmental Effect and Mitigation Table – Métis Nation of Alberta Region 1 (continued)
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Potential Adverse Effects Mitigation Proposed by Métis Nation of Alberta Region 1
Mitigation Teck Commits to Implement
Teck commits to implement the following mitigation measures to reduce the potential for bird mortality risk resulting from interaction with transmission and distribution lines (see the response to JRP IR 7.10, Table 7.10-1):
Designing transmission and distribution lines, where possible, to match the height of surrounding trees to reduce wire strikes by birds.
Marking of transmission and distribution lines in areas near waterfowl staging and potential stopover areas.
Teck has developed a Draft Waterfowl Protection Plan (see the response to JRP IR 7.10, Appendix 7.10). Teck will continue to pursue collaborative engagement processes, as outlined in the WMMP for the Project as the primary mechanism in which it will engage with potentially affected Indigenous groups regarding the Waterfowl Protection Plan. Once finalized, the plan will include a communication management section, which will outline how findings of the program will be communicated to interested parties.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Bison
Change in bison habitat availability
None. Teck commits to implement the following mitigation measures to reduce direct habitat loss (see the response to JRP IR 7.5, Table 7.5-1):
Limit the size of the east side access road right-of-way (ROW) and temporary workspace to the extent practical.
Limit the Athabasca Rive bridge footprint in riparian areas.
Carry out progressive reclamation to reclaim disturbed wildlife habitat as portions of the mine footprint become available.
Develop a weed management plan.
Teck commits to implement the following mitigation measures to reduce indirect habitat loss (see the response to JRP IR 7.5, Table 7.5-1):
Implement strategies to reduce noise and light effects, including design considerations (e.g., Frontier Project plant site engineering and aerodrome operation within regulatory and safety constraints).
Limiting employee and contractor access to identified areas of high-quality habitat adjacent to Project footprint.
Teck has developed a Draft Ronald Lake Bison Mitigation, Monitoring and Adaptive Management Plan (see the response to JRP IR 7.5, Appendix 7.5). Teck has proposed steps to Indigenous groups that would provide the opportunity for land users and community members to provide direct input into developing wildlife mitigation measures, including those specific to bison. Once finalized, the plan will include a communication management section, which will outline how findings of the program will be communicated to interested parties.
Teck will also work with the responsible authority to explore possible mitigations for which Teck does not have the authority to implement independently.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Change in bison landscape connectivity None. Teck commits to implement the following mitigation measures to reduce change to landscape connectivity (see the response to JRP IR 7.5, Table 7.5-1):
Carry out progressive reclamation to restore vegetated corridors as portions of the mine footprint become available.
To maintain connectivity between Birch Mountains and Athabasca River:
o Coordinate development activities with Canadian Natural Resources Limited (CNRL) who acquired the Pierre River Mine oil sands leases formerly held by Shell Canada Limited should CNRL reapply for and develop the Pierre River Mine project.
o Develop an integrated land management strategy for the Project in consultation with industry, Indigenous stakeholders and the Province.
Provide wildlife passage under both sides of the Athabasca River bridge and river water intake bridge to Dalkin Island to allow north–south wildlife movement along river banks using crossing design considerations (e.g., bridge height and length) outlined in Clevenger and Huijser (2011) and GOA (2011):
o Set up educational signage to limit human use of wildlife underpasses.
o Evaluate wing fencing along the approach to crossing passages (at least 2.4 m high for large mammals as per GOA 2011) as part of the crossing structure design.
o Provide appropriate walking substrate along the wildlife underpass.
o Create vegetated buffers adjacent to wildlife underpasses to increase movement opportunities for a variety of species.
Teck has developed a Draft Ronald Lake Bison Mitigation, Monitoring and Adaptive Management Plan (see the response to JRP IR 7.5, Appendix 7.5). Teck has proposed steps to Indigenous groups that would provide the opportunity for land users and community members to provide direct input into developing wildlife mitigation measures, including those specific to bison. Once finalized, the plan will include a communication management section, which will outline how findings of the program will be communicated to interested parties.
Teck will also work with the responsible authority to explore possible mitigations for which Teck does not have the authority to implement independently.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Change in bison mortality risk
None.
Teck commits to implement the following mitigation measures to reduce bison mortality risk resulting from vehicle–bison collisions (see the response to JRP IR 7.5, Table 7.5-1):
Implement fly-in/fly-out policy for workers to reduce vehicular traffic volume.
Erect wildlife cautionary signage on access roads.
Foster environmental awareness with speed restrictions on access roads, report Project-related wildlife fatalities.
Provide vegetation maintenance at roadsides (vegetation will be trimmed regularly to discourage roadside foraging and prevent visual obstruction of wildlife).
Develop seed mixes for roadside reclamation from less palatable species to reduce wildlife attraction to road edges.
Design the road to maximize line of sight.
Teck commits to implement the following mitigation measures to reduce bison mortality risk resulting from bison-human interactions - interactions with infrastructure (see the response to JRP IR 7.5, Table 7.5-1):
Create fuel and chemical spill contingency and response plans.
Confirm adequate spill protection for all fuel storage facilities.
Monitor and maintain waste disposal sites, wastewater storage areas and runoff control structures to prevent contamination of surface waters.
During overburden dewatering, intermittently backslope the sides of drainage ditches to allow for wildlife crossings and to reduce the potential for entrapment.
Teck commits to implement the following mitigation measures to reduce bison mortality risk resulting from hunter access (see the response to JRP IR 7.5, Table 7.5-1):
Frontier Oil Sands Mine Project Appendix 10.12
Table 10.12-14: Potential Adverse Environmental Effect and Mitigation Table – Métis Nation of Alberta Region 1 (continued)
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Potential Adverse Effects Mitigation Proposed by Métis Nation of Alberta Region 1
Mitigation Teck Commits to Implement
Construct predator access blocks to deter predator use (i.e., reduce line of sight) on linear features in the PDA that may leave core bison areas susceptible to predation.
Deactivate roads in the PDA no longer in use.
Implement employee / contractor policies to prohibit hunting within the Project area.
Reduce linear features in the closure landscape.
Reduce width of linear features in the closure landscape.
Teck commits to implement the following mitigation measures to reduce bison mortality risk resulting from disease transmission to the Ronald Lake bison herd (see the response to JRP IR 7.5, Table 7.5-1):
Implement progressive reclamation in the PDA to create suitable Ronald Lake bison habitat and reduce the potential of shifting habitat use northward.
Mitigations associated with reducing hunter and predator access.
Mitigations associated with reducing wildlife human conflict.
Mitigations associated with reducing indirect habitat loss.
Teck has developed a Draft Ronald Lake Bison Mitigation, Monitoring and Adaptive Management Plan (see the response to JRP IR 7.5, Appendix 7.5). Teck has proposed steps to Indigenous groups that would provide the opportunity for land users and community members to provide direct input into developing wildlife mitigation measures, including those specific to bison. Once finalized, the plan will include a communication management section, which will outline how findings of the program will be communicated to interested parties.
Teck will also work with the responsible authority to explore possible mitigations for which Teck does not have the authority to implement independently.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Vegetation
Change in vegetation
None. Teck is committed to continue working with potentially affected Indigenous groups to refine the closure, conservation and reclamation (CC&R) plan through the life of the Project and to incorporate input from Indigenous groups on reclamation monitoring and thresholds and document the establishment of traditional use vegetation in the reclaimed landscape. Teck plans to co-create Reclamation Working Group(s) with potentially affected Indigenous groups to seek input to the Project’s reclamation plan and measures and targets to determine its success. It anticipates that species of traditional importance will be identified by Reclamation Working Group(s) and incorporated into reclamation planning as feasible. In addition, collaborative participation is planned in reclamation research both from a Project and regional perspective. Results of this research will be incorporated into future Project plans (see the response to JRP IR 6.9, Section 4.2).
Teck also commits to implement the following mitigation measures to reduce change in vegetation (see Volume 3, Appendix 17H, Section 17H.4 of the Project Update; response to JRP IRs 6.8 and 6.10):
Reclamation of the closure landscape will focus on generating a sustainable landscape that is designed to maximize diversity through the generation of landforms that include:
o topographic diversity and associated diversity in moisture regimes
o aspect diversity
o substrate diversity including both fine- and coarse- grained landforms
o mesotopography
Removal of existing linear disturbances that are currently fragmenting the landscape.
Mitigation to reduce effects on community diversity will focus on research results and strategies as summarized in:
o Guidelines for Reclamation to Forest Vegetation in the Athabasca Oil Sands Region (2nd Edition) (ESRD 2010)
o Guideline for Wetland Establishment on Reclaimed Oil Sands Leases (3rd Edition) (CEMA 2014)
o Oil Sands Marshes: A Knowledge Transfer (Charette et al. 2012)
o Best Management Practices for Conservation of Reclamation Materials in the Mineable Oil Sands Region of Alberta (MacKenzie 2011)
o Restoration and Reclamation of Boreal Ecosystems: Attaining Sustainable Development (Vitt and Bhatti 2012)
o Riparian Classification and Reclamation Guide, Revised Edition (Mihajlovich 2012)
Include peatlands in detailed CC&R planning should research results and recommendations prove to be feasible and appropriate.
Work with the governments of Alberta and Canada and look to their guidance on the development of a Conservation Agreement.
Plant additional species on the reclamation landscape, including those with traditional value, to supplement those recommended in provincial reclamation guidelines.
Mitigation for rare plant species will be achieved through avoidance whenever possible. In areas where avoidance is not possible, alternate mitigation strategies will be developed to promote conservation of these species and associated genetic diversity.
A weed management plan will be implemented throughout the life of the Project including during reclamation and at closure.
Develop and implement a program to salvage and relocate known occurrences of rare (vascular) plant species to areas outside of the Project area in consultation with Indigenous communities.
Incorporate species of traditional important as identified through the Reclamation Working Group(s) into reclamation planning, as feasible.
Engage Indigenous communities in preparing plans to harvest and collect seeds, and will invite community members to harvest and collect seeds of rare and culturally important species before disturbance, for use in reproducing the species and revegetation of the Project area.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures related to reclamation and evaluate monitoring results to determine if adaptations are warranted.
Historical Resources
Changes to historical resources within the Project disturbance area
None. Teck commits to implement the following mitigation measures regarding changes to historical resources within the Project disturbance area (see Volume 3, Appendix 17H, Section 17H.9 of the Project Update):
Historical resources sites in the PDA that Alberta Culture and Tourism (ACT) determines to have moderate to high heritage value will likely have requirements for further study. These might include some or all of the following:
o Additional shovel testing to identify site boundaries, areas of highest artifact density, activity areas and areas with unique or specialized artifacts.
o Archaeological excavation at sites with high interpretive potential.
o Mapping and documentation at specific sites.
Teck will phase the required supplemental historic resources impact assessment (HRIA) studies to ensure completion of all necessary studies in the PDA in advance of vegetation clearing in each development area.
Teck will also work collaboratively with local First Nation and Aboriginal communities on mitigation studies, in an effort to address local concerns and interests in relation to historical resources in the area.
Frontier Oil Sands Mine Project Appendix 10.12
Table 10.12-14: Potential Adverse Environmental Effect and Mitigation Table – Métis Nation of Alberta Region 1 (continued)
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Potential Adverse Effects Mitigation Proposed by Métis Nation of Alberta Region 1
Mitigation Teck Commits to Implement
Socio-economics
Change to housing needs None. Teck commits to implement the following mitigation measures regarding housing needs (see the response to JRP IR 5.14(a), Table 5.15a-1):
Provide on-site, lodge-based accommodations during construction and operations to reduce the Project’s effect on the resident population and associated effects on social infrastructure and housing in the region.
Offer lodge amenities and services – including individual rooms and shared spaces, the quality of the food services and free-time activities – that are competitive with other lodge accommodations in the region.
Change to social infrastructure needs
None. Teck commits to implement the following mitigation measures regarding social infrastructure needs (see the response to JRP IR 5.14(a), Table 5.15a-2):
Maintain explicit and enforced lodge, workplace and flight policies with regards to the use of alcohol, drugs and illegal activities.
Provide onsite security services, including controlled gates, check-in procedures, perimeter security fencing and lodge-based security officers on duty 24 hours.
Offer in-house security services to assist the Royal Canadian Mounted Police (RCMP) within, and sometimes outside, the Project lease boundaries (e.g., securing accident scenes and assisting with highway closures).
Develop and implement an emergency response plan which includes the required personnel, procedures and equipment resources (e.g., vehicles, fire response, medical response and rescue).
Develop required mitigation measures for areas adjacent to the Project area based on the FireSmart Wildfire Assessment System and implement in the emergency response plan.
Enter into mutual aid agreements with the Regional Municipality of Wood Buffalo (RMWB) and other oil sands companies that include:
o responding to motor vehicle accidents on Highway #63
o responding to forest fire threats to Fort McKay
o responding to regional spills
Participate in the management of regional emergencies at the RMWB’s Regional Emergency Operations Centre.
Make available onsite health services, including an on-site medical facility staffed by qualified health professionals providing 24-hour on-site primary, emergency and occupational health services.
Consider financial and in-kind contributions to the Northern Lights Health Foundation, where appropriate, to support the efforts of Alberta Health Services to meet the needs of Wood Buffalo residents. Recognizing some of the health concerns in the region Teck is prepared to make health promotion and disease prevention initiatives a focus of their community investment policy.
Provide helicopter or fixed-wing aircraft access via the on-site aerodrome for injured workers requiring rapid evacuation for off-site medical care.
Discuss with other industrial proponents near the Project options for coordinating on-site health facilities and resources.
Assess and support school events and education initiatives identified by rural schools in the study area, as appropriate.
Provide employees with access to the company’s confidential Employee and Family Assistance Plan, which provides support for families and individuals who might experience difficulty dealing with personal, family or work-life issues that can affect one’s health and well-being.
Consider support for community level initiatives including social groups providing assistance to those in need.
Continue providing direct support to community initiatives through its social investment programs.
Offer shift schedules that provide workers with sufficient time off to enjoy leisure activities in their home communities.
Make available onsite recreational opportunities and facilities.
Change to transportation needs
None. Teck commits to implement the following mitigation measures regarding transportation needs (see the response to JRP IR 5.14(a), Table 5.14a-3):
Construct and operate an aerodrome near the Project site.
Use on-site as well as regional lodge accommodations during both construction and operations to reduce worker commutes.
Use bus service for transporting construction and operations workers.
Limit private vehicles brought to the Project site.
Schedule truck traffic, including oversized loads, to off-peak hours.
Use an on-site concrete batch plant; and attempt to source aggregates from pits near to site.
Enforce lodge, workplace and flight policies with regards to the use of alcohol, drugs and illegal activities.
Work with the local RCMP to confirm communication on local effects.
Support the efforts of RMWB and Oil Sands Community Alliance (OSCA) to work with the provincial government to progress improvements to highway infrastructure in a timely way.
Keep responsible regional and provincial planners informed of the Project’s development plans and their timing.
Consult and cooperate with other operators regarding shift scheduling with a view to reduce overlap in commuter traffic.
Provide funding to assist in the maintenance and safety of applicable segments of Highway #63 from Fort McKay to Fort Chipewyan that are affected by the Project.
Change to municipal infrastructure needs None. Teck commits to implement the following mitigation measures regarding municipal infrastructure (see the response to JRP IR 5.14(a), Table 5.14a-4):
Provide water and sewer services for the different mining areas and the associated processing facilities and infrastructure, including on-site lodges.
Teck commits to implement the following mitigation measures regarding choice of fly-in/fly-out (FIFO) (see the response to JRP IR 5.14(a), Table 5.14a-6):
A FIFO lodge-based approach to construction and operations.
Ongoing monitoring of the operations FIFO model and revisiting the approach should local circumstances change.
Teck’s monitoring will take into consideration input received via its workers, contractors and ongoing local stakeholder and Indigenous engagement process. This would likely include feedback with respect to the social and economic effects of the FIFO model on individual workers, their families and communities.
Commitment to include Fort Chipewyan in a FIFO program.
Engage with potential employees living in Fort Chipewyan to discuss shift schedules and other travel and lodging logistics that influence their choice to work at the Project versus other opportunities.
Discuss with local communities the design of FIFO shifts that best benefit its employees and families while remaining logistically and financially feasible.
Remain open to engaging in broader, regional initiatives, for example through the OSCA and its study of the use of aerodromes in the region.
Change to employment, business and training opportunity needs
None. Teck commits to implement the following mitigation measures regarding employment, business and training opportunity needs (see the response to JRP IR 5.14(a), Table 5.14a-5):
Specific contractual commitments to Indigenous communities on employment, business and training opportunities will be made within Participation Agreements negotiated between Teck and the Indigenous community.
Prioritize recruiting residents from the region first, Alberta second, followed by the rest of Canada, then North America and then overseas countries.
Frontier Oil Sands Mine Project Appendix 10.12
Table 10.12-14: Potential Adverse Environmental Effect and Mitigation Table – Métis Nation of Alberta Region 1 (continued)
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Potential Adverse Effects Mitigation Proposed by Métis Nation of Alberta Region 1
Mitigation Teck Commits to Implement
Draw on various sources of labour in Canada that are traditionally under-represented in the labour market, including Indigenous people, immigrants and women.
Put in place a policy to hire local businesses and contractors that are competitive and able to meet the company’s needs is already in place.
Teck will consult with Indigenous communities regarding procurement and employment initiatives such as:
o Establishing mechanisms to enhance employment prospects of local residents, including preferential consideration.
o Using procurement processes that regard local ownership and prevalence of workers residing locally as positive criteria in goods and services vendor selection competitions.
o Establishing monitoring programs that measure local involvement, gather feedback and work with interested parties on how to improve results.
Implement Teck’s relevant charters, codes and policies, including its Indigenous Peoples Policy, when working with Indigenous peoples in seeking to develop lasting mutual benefits that respect Indigenous community’s values – including hiring, training and retention of Indigenous employees.
Utilize what Teck’s has learned to date from local Indigenous communities with which it is engaged for the Project to overcome oil sands specific challenges to Indigenous employment and procurement.
Consider work experience in lieu of a high school graduation for Indigenous peoples.
Work with the Fort McMurray Chamber of Commerce, the Northeastern Alberta Aboriginal Business Association (NAABA) and others to maximize contracting and employment opportunities in the region.
Offer a choice of worker turnaround cycles and opportunity to earn premium pay through overtime.
Continue to work with the Indigenous communities in the area and specifically with the communities of Fort McKay and Fort Chipewyan to develop Indigenous employment and business development program(s) guided by a commitment to: maximize opportunities for local Indigenous businesses to supply services and products in support of Project construction and operations; hire qualified Indigenous people from the communities surrounding the Project and support education, training and investment initiatives in local Indigenous communities, where appropriate.
Teck’s Indigenous community employment and business development program(s) will engage with Indigenous communities on establishing employment and procurement policies and procedures, as well as adaptive management mechanisms specific to Indigenous community employment and procurement.
Teck’s Indigenous community employment and business development program(s), as well as community-specific Participation Agreements will take into consideration input provided by local Indigenous communities, and will be guided by a commitment to: develop substantial opportunities for local Indigenous businesses to supply services and products in support of Project construction and operations; hire qualified Indigenous people from the communities surrounding the Project and support education, training and investment initiatives in local Indigenous communities, where appropriate.
Continuously monitor Teck’s local employment and procurement policies and programs, along with reporting the results of this monitoring as part of ongoing community consultation.
Teck has yet to determine the exact reporting and monitoring mechanisms for its local procurement and employment policies, but will engage with Indigenous communities on mechanisms and expects they will likely be similar to mechanisms used by Teck’s other operations. These might include:
o Total employment, attraction and retention rates, average salary levels and other general human resource data. Where possible, the data will be disaggregated at the local community level.
o Procurement activity, including examination of goods and services sourced from providers in local communities, value and length of contracts, types of goods and services provided and employment and enterprise effects associated with procurement.
o Additional potential mechanisms are identified in Teck’s draft socio-economic monitoring plan in response to JRP IR 5.15(a).
Continue supporting local labour force skills development, and work with communities, government and other industrial proponents on programs that assist community members overcome labour market barriers.
Change to culture
None.
Teck commits to implement the following mitigation measures regarding changes to culture (see the response to JRP IR 5.14(a), Tables 5-14a-6 and 5.14a-7):
Continue to expand Teck’s knowledge of, and engagement with, local stakeholders and Indigenous communities near the Project to confirm ongoing and growing participation in Project-related benefits, as well as the design of appropriate and effective mitigation measures to reduce any adverse effect. These efforts are envisioned to include capacity building support within Participation Agreements for Indigenous communities.
Provide cultural diversity awareness training to employees and contractors, focusing on respect for traditional land users as well as respect for Indigenous world views, customs and values.
Consider supportive workplace practices as Teck develops workplace policies and seek local Indigenous community input into cultural awareness programming to be provided at the Project site.
Carry out a review of Teck’s standard bereavement policy, including a review of policies from other fly in/fly out operations in Alberta, as operation specific policies are developed during future planning phases.
Continuing to provide cultural awareness training for all Project staff and contractors.
Considering key Indigenous access routes and access preferences in the Project’s draft Access Management Plan (AMP).
Considering cultural keystone species in the wildlife management and mitigation plan, FHCL and biodiversity management plan.
Incorporating and using Indigenous place names where applicable.
Supporting community-led projects to document Indigenous place names in their respective traditional territories.
Contributing to language retention programs and other programs that support retaining Indigenous culture, knowledge and practice (e.g., culture camps for youth).
Discuss with local communities the design of fly in/fly out shifts that best benefit its employees and families while remaining logistically and financially feasible.
Access
Change to access near the Project disturbance area
None. Teck has developed a draft access management plan (AMP) for the Project to facilitate access to or through Teck’s mineral surface lease to the extent possible while maintaining worker and public safety (see the response to JRP 4.5, Appendix 4.5). Teck has proposed next steps to Indigenous groups that would provide the opportunity for land users and community members to provide direct input into developing access mitigation measures. This input will refine the draft AMP.
Teck commits to implement the following mitigation measures to reduce potential effects on changes to access near the Project disturbance area (see Volume 3, Appendix 17H, Section 17H.8.2 of the Project Update) and the response to JRP IR 10.9):
All individuals wanting to gain access to or through lands being actively developed, which is generally Teck’s mineral surface lease (MSL), will be required to submit an access request.
Traditional land users will be granted temporary access to and through the PDA according to the policy and processes set out in the AMP.
Traditional land users will not have to meet worker site access requirements but will be escorted by someone who has permanent site access (i.e., a worker).
Access through, and to portions of the PDA not being actively developed will not require an access request form be submitted. Individuals will be required to contact the site’s security office and provide adequate notice about when they plan to be in the area, who will be present, and the intended activities and general location(s) as they relate to Teck leases. All individuals passing through the PDA will have to check in at the security office and will be escorted by a Teck worker. Teck understands that Aboriginal communities desire that the advance notice period.
Throughout the life of the mine, access to locations in the PDA by Aboriginal community members will be based on mine advance. For safety reasons, harvesting and use of firearms would not be permitted in areas being actively mined or within and around facilities associated with the mine.
The River Road will be maintained through operations and will provide access to the Fish Habitat Compensation Lake, aerodrome, and areas north of the PDA.
Frontier Oil Sands Mine Project Appendix 10.12
Table 10.12-14: Potential Adverse Environmental Effect and Mitigation Table – Métis Nation of Alberta Region 1 (continued)
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Potential Adverse Effects Mitigation Proposed by Métis Nation of Alberta Region 1
Mitigation Teck Commits to Implement
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Traditional Land Use
Change in availability of resources (wildlife, fish and vegetation), culturally important sites or areas for traditional activities and use of lands
None. Teck commits to implement the following mitigation measures to reduce changes in availability of resources (wildlife, fish and vegetation), culturally important sites or areas for traditional activities and use of lands (assessed in Volume 3, Section 17.6 of the Project Update) (see the response to JRP IR 4.6, Table 4.6-1):
Grant traditional land users temporary access to and through the PDA according to the policy and processes set out in the draft access management plan.
Implement measures to mitigate Project-related effects on wildlife through the wildlife monitoring and mitigation plan.
Engage Indigenous communities in the development of a biodiversity management plan.
Implement measures to mitigate Project-related effects on fish and fish habitat through the detailed fisheries offsetting plan.
Implement measures to reduce Project-related effects on vegetation through the conservation closure and reclamation plan and the reclamation monitoring plan.
Historical resources sites in the PDA that Alberta Culture and Tourism (ACT) determines to have moderate to high heritage value will meet the requirements of ACT and aim to meet the desires of Indigenous communities.
Teck commits to implement the following mitigation measures to reduce effects on the land use experience for traditional land users (see the response to JRP IR 4.6, Table 4.6-1):
Establish Participation Agreements with Indigenous communities.
Invite traditional users to harvest traditional plants before disturbance.
Support the planning and implementation of an excursion for Indigenous communities within the terrestrial local study area prior to Project-related disturbance to describe Indigenous values, access and to recommend mitigation to avoid or limit effects on Indigenous access values.
Provide cultural diversity awareness training to employees and contractors focusing on respect for Indigenous land users, traplines, cabins, trails and equipment, as well as respect for Indigenous world views, customs and values.
Compensate Indigenous trappers following industry-community standards and the Alberta Trappers Compensation Program.
Project personnel will be prohibited from fishing, hunting and trapping within the PDA during work rotations, which is when Teck’s policies’ can be enforced.
Project personnel will be prohibited from using personal recreation vehicles within the PDA.
Investigate with potentially affected Indigenous communities through the Reclamation Working Group the concept of incorporating cultural values into reclamation planning.
Supporting documentation of community-specific cultural heritage.
Teck has developed a Draft Traditional Land Use Mitigation, Monitoring and Adaptive Management Plan (see the response to JRP IR 4.6, Appendix 4.6). Teck will continue to seek input and engage with Indigenous groups, as well as regulators where appropriate, as part of finalizing this plan. Once finalized, Teck will continue to pursue collaborative engagement processes with Indigenous groups as outlined in the plan. Through these collaborative engagement processes Teck will aim to minimize and mitigate potential Project effects on traditional land use. Once finalized, the plan will include a communication management section, which will outline how findings of the program will be communicated to interested parties.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Notes:
NOx = oxides of nitrogen; SO2 = sulphur dioxide; PM2.5 = particulate matter
Frontier Oil Sands Mine Project Appendix 10.12
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8 Mikisew Cree First Nation
A summary of established or asserted Aboriginal and treaty rights, current use of lands and resources for
traditional purposes and cultural and physical heritage features as described by Mikisew Cree First Nation
(MCFN) is presented in Table 10.12-15.
Table 10.12-15: Mikisew Cree First Nation Rights, Land Uses and Cultural and Physical Heritage Features
Established or Asserted Aboriginal and Treaty Rights, Current Use of Lands and Resources for Traditional
Purposes Cultural and Physical Heritage Feature
Hunting for sustenance and livelihood, as well as for ancillary practices
Fishing for sustenance and livelihood, as well as for ancillary practices
Trapping for sustenance and livelihood, as well as for ancillary practices
Gathering for sustenance and livelihood, as well as for ancillary practices
Secure drinking water
Harvest of preferred animal, fish and plant species, water, and other resources important for medicinal, spiritual, sustenance, livelihood and cultural needs, in preferred locations at preferred times, in preferred quantities and quality, and by preferred methods
Quality and quantity of wildlife species required
Quality and quantity of aquatic species required
Quality and quantity of plants or other things gathered
Quality and quality, as the context requires, of air, water and ecosystems required to support the exercise of MCFN’s rights
Access areas for harvesting, by land and water, at preferred times, by preferred modes of transportation
Occupy the land in preferred locations, in preferred seasons, for preferred amounts of time and in preferred types of overnight structures
Experience all conditions in remoteness, solitude, safety and security.
Engage in, preserve, and enhance cultural and / or spiritual practice.
Maintain and teach Mikisew way of life free from disturbance or outside interference and with confidence.
Physical and cultural sites, including harvesting areas, cabins, traplines, the Athabasca River and its tributaries and the Peace-Athabasca Delta
Way of life, including: o Language o Identity o Sense of place o Knowledge transmission and continuity of
practice
Harvesting, including: o Subsistence and cultural use
Stewardship and governance
Potential adverse Project effects on MCFN’s established or asserted Aboriginal and treaty rights, current
use of lands and resources for traditional purposes or cultural and physical heritage are presented in
Table 10.12-16, along with mitigation proposed by MCFN in their Traditional Land Use studies (Candler et
al. 2013; 2015a), Indigenous Knowledge Study (Candler et al. 2015b) and CIA (Candler et al. 2015c), and
mitigation that Teck has committed to implement to reduce these potential effects.
As noted elsewhere in Teck’s filed submissions, Teck’s preferred approach to reaching agreement on an
appropriate scope of mitigation and management options regarding cultural impacts is to negotiate long-
term benefits and Participation Agreements with Indigenous communities. Teck will continue to pursue
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negotiation and consensus building efforts with MCFN and periodically update regulators on the progress
of those discussions.
Teck is committed to continuing discussions with MCFN and its members to determine how Project-
related and cumulative effects can best be addressed through mitigation and other measures. To that
end, Teck will work cooperatively with MCFN towards resolution of outstanding issues and concerns,
including discussion of the impacts, concerns and recommendations identified within the CIA.
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Table 10.12-16: Potential Adverse Environmental Effect and Mitigation Table – Mikisew Cree First Nation
Potential Adverse Effects Mitigation Proposed by Mikisew Cree First
Nation in TLU Study, IK study and CIA Mitigation Teck Commits to Implement
Hydrology and Water Quality
Changes in flows, water levels and open water areas
Reduce the Project footprint so that watersheds flowing directly into Lake Claire, and a reasonably buffer surrounding, remain unaffected. This would involve a reduction in the mine area and the overall footprint of the Project with the goal of substantially reducing risks to Buckton Creek, Lake Claire and Mikisew practice within WBNP, and to protect Mikisew confidence and sense of place in critical areas (Candler et al. 2015c, p.167).
The Athabasca River will satisfy the Project’s makeup water requirements, and an off-stream storage pond (OSSP) will supply the Project with water during periods when river water withdrawal is restricted (see the response to Joint Review Panel (JRP) Information Request (IR) 10.26, Appendix 10.26, Section 7.1).
Teck commits to implement the following mitigation measures to reduce changes in flows and water levels in receiving waterbodies (see the response to JRP IR 10.25, Appendix 10.25, Table 10.25-1):
Reduce changes to flows in Ronald Lake by using a flow splitter on the Redclay Creek diversion during operations.
Reduce changes to flows in Big Creek by using a flow splitter on the Big Creek diversion during operations.
Distribute muskeg drainage operations through the mine life, thereby avoiding a large increase in flows in the receiving waters.
Reduce effects of closed-circuit operations on flows and water levels in receiving waters by diverting natural watercourses that will not be disturbed by the mining operations around the mining area to receiving watercourses.
Reduce river-water withdrawal requirements from the Athabasca River by maximizing closed-circuit recycling of surface and groundwater where practical, and by storing sufficient amounts of water in an off-stream storage pond in the event of extended withdrawal restrictions from the Athabasca River.
Progressively construct and develop diversion systems, which helps limit the change in open-water areas during construction and operation by providing new drainage channels to replace the loss of natural watercourses and waterbodies.
Reduce changes to flows and water levels in receiving waters by developing a closure drainage layout that will limit changes in drainage areas contributing flows to the receiving watercourses relative to predevelopment conditions.
Design watercourses, waterbodies and wetlands during reclamation to attenuate floods.
Teck is committed to continue to consult meaningfully with, and engage, all potentially affected Indigenous groups at both a Project-specific and regional level to reduce and mitigate potential Project and cumulative effects on hydrology and surface water quality, including continuing discussions regarding hydrology and surface water quality concerns and is prepared to consider additional mitigation measures to address these concerns (see the response to JRP IR 10.25, Appendix 10.25).
Teck has developed a Draft Hydrology and Water Quality Mitigation, Monitoring and Adaptive Management Plan (see the response to JRP IR 10.25, Appendix 10.25). Once finalized, the plan will include a communication management section, which will outline how findings of the program will be communicated to interested parties.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Changes in sediment yields, concentrations and channel regimes (geomorphology)
Reduce the Project footprint so that watersheds flowing directly into Lake Claire, and a reasonably buffer surrounding, remain unaffected. This would involve a reduction in the mine area and the overall footprint of the Project with the goal of substantially reducing risks to Buckton Creek, Lake Claire and Mikisew practice within WBNP, and to protect Mikisew confidence and sense of place in critical areas (Candler et al. 2015c, p.167).
Teck commits to implement the following mitigation measures to limit release of Total Suspended Solids (TSS) (see the response to JRP IR 10.25, Appendix 10.25, Table 10.25-1):
Follow relevant regulatory guidelines, standards and best management practices during construction and operation to reduce the risk of increased sediment loadings to receiving watercourses.
Construct and operate sedimentation ponds to settle TSS where necessary.
Control sediment generation in diversion channels through revegetation of streambanks, overbank areas and berms as soon as possible after construction and by the use of channel armour (riprap), where required.
Direct muskeg and overburden drainage waters to polishing ponds equipped with oil-separation capability.
Reduce sediment yields from reclaimed surfaces by developing appropriate final topography and soil moisture conditions.
Resuspension of sediments from the bottom of polishing ponds, wetlands and pit lakes will be reduced through appropriate hydraulic design.
Reduce gullying and channel erosion by developing robust and sustainable reclamation drainage systems with built-in self-healing capability and robustness similar to natural drainage systems.
Teck commits to implement the following mitigation measures to reduce changes in flood flows and geomorphology downstream of the Project (see the response to JRP IR 10.25, Appendix 10.25, Table 10.25-1):
Limit changes in flood flows in receiving watercourses relative to predevelopment conditions. Mitigation measures listed for the “reduce changes in flows and water levels” above are relevant for mitigating flood flows.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Direct water emissions:
Muskeg drainage and overburden dewatering flows
Drainage from operating and reclaimed mine site
Basal water sands depressurization
Process-affected seepages from backfilled mine pits and tailings disposal areas
Reduce the Project footprint so that watersheds flowing directly into Lake Claire, and a reasonably buffer surrounding, remain unaffected. This would involve a reduction in the mine area and the overall footprint of the Project with the goal of substantially reducing risks to Buckton Creek, Lake Claire and Mikisew practice within WBNP, and to protect Mikisew confidence and sense of place in critical areas (Candler et al. 2015c, p.167).
Teck commits to implement the following mitigation measures to limit the release of ions, nutrients, metals, polycyclic aromatic hydrocarbons (PAHs) and other parameters during operations and closure and protect sediment quality in downstream watercourses and waterbodies (see the response to JRP IR 10.25, Appendix 10.25, Table 10.25-1):
Recycle process-affected waters and runoff within the Project disturbance area (PDA) in a closed-circuit system during operations.
Using a perimeter ditch and groundwater wells to capture and pump back seepages and runoff from the external tailings areas (ETAs) back into the tailings areas during operations.
Design the closure drainage system to capture seepage and runoff from ETAs, external disposal areas (EDAs) and the Frontier Project plant site and directing it to wetlands, pit lakes or constructed reclamation lakes during the mine closure management phase.
Use wetlands, constructed reclamation lakes and pit lakes during and after the decommissioning and closure phases to provide biological remediation and settling of particulate materials in reclamation waters before discharge.
Respond to spills using best management practices. Project activities will follow safety protocols designed to limit accidents and reduce effects if an accident should occur.
Teck commits to the following mitigation measures to manage depressurization water during preproduction (see Volume 1, Section 7.6.5 and 7.8.4 of the Project Update):
Teck plans to manage depressurization water during preproduction by storing approximately half of it in a storage pond at surface and reinjecting the remaining half into the BWS aquifer.
Teck is committed to continue to consult meaningfully with, and engage, all potentially affected Indigenous groups at both a Project-specific and regional level to reduce and mitigate potential Project and cumulative effects on hydrology and surface water quality, including continuing discussions regarding hydrology and surface water quality concerns and is prepared to consider additional mitigation measures to address these concerns (see the response to JRP IR 10.25, Appendix 10.25).
Teck has developed a Draft Hydrology and Water Quality Mitigation, Monitoring and Adaptive Management Plan (see the response to JRP IR 10.25, Appendix 10.25). Once finalized, the plan will include a communication management section, which will outline how findings of the program will be communicated to interested parties.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Pit lake releases None. Teck will leverage the knowledge gained through its other reclamation efforts, along with research through regional initiatives such as Canada’s Oil Sands Innovation Alliance (COSIA), to develop healthy, functional
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Potential Adverse Effects Mitigation Proposed by Mikisew Cree First
Nation in TLU Study, IK study and CIA Mitigation Teck Commits to Implement
ecosystems in the Project pit lakes (see the response to JRP IR 2.3).
Teck also commits to implement the following mitigation measures when designing closure drainage and pit lakes for hydrological sustainability and to promote effective passive treatment of process-affected waters and to support a viable aquatic ecosystem prior to release and to sequester tailings and other mine waste in the most appropriate location at mine closure (see the response to JRP IR 10.25, Appendix 10.25, Table 10.25-1):
Exclude tailings from pit lakes.
Do not release water from pit lakes until acceptable quality is achieved.
Maintain the water balance of the pit lakes with sufficient inflows to compensate for evaporative losses.
Manage the rate of Athabasca River water input to pit lakes as appropriate to confirm water quality filling targets are met and to comply with Athabasca river low flow restrictions.
Include wetlands reclamation lakes for treatment purposes in reclamation drainages to the pit lakes.
Teck is committed to continue to consult meaningfully with, and engage, all potentially affected Indigenous groups at both a Project-specific and regional level to reduce and mitigate potential Project and cumulative effects on hydrology and surface water quality, including continuing discussions regarding hydrology and surface water quality concerns and is prepared to consider additional mitigation measures to address these concerns (see the response to JRP IR 10.25, Appendix 10.25).
Teck has developed a Draft Hydrology and Water Quality Mitigation, Monitoring and Adaptive Management Plan (see the response to JRP IR 10.25, Appendix 10.25). Once finalized, the plan will include a communication management section, which will outline how findings of the program will be communicated to interested parties.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Changes in quality of groundwater and surface water downgradient of EDAs
Reduce the Project footprint so that watersheds flowing directly into Lake Claire, and a reasonabl[e] buffer surrounding, remain unaffected. This would involve a reduction in the mine area and the overall footprint of the Project with the goal of substantially reducing risks to Buckton Creek, Lake Claire and Mikisew practice within WBNP, and to protect Mikisew confidence and sense of place in critical areas (Candler et al. 2015c, p.167).
Teck commits to implement the following mitigation measures to maintain surface water quality in consideration of surface flows into and out of the Project area and groundwater discharge (see the response to JRP IR 10.25, Appendix 10.25, Table 10.25-1):
Groundwater and surface waters draining EDAs will be captured if monitoring data indicate that the drainage waters are unsuitable for release.
Teck is committed to continue to consult meaningfully with, and engage, all potentially affected Indigenous groups at both a Project-specific and regional level to reduce and mitigate potential Project and cumulative effects on hydrology and surface water quality, including continuing discussions regarding hydrology and surface water quality concerns and is prepared to consider additional mitigation measures to address these concerns (see the response to JRP IR 10.25, Appendix 10.25).
Teck has developed a Draft Hydrology and Water Quality Mitigation, Monitoring and Adaptive Management Plan (see the response to JRP IR 10.25, Appendix 10.25). Once finalized, the plan will include a communication management section, which will outline how findings of the program will be communicated to interested parties.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Air Quality and Odour
NOX emissions None. Teck commits to implement the following mitigation measures to reduce NOX emissions from combustion sources (see the response to JRP IR 3.18, Table 3.18-1):
Use natural gas as a fuel for the cogeneration plant and boilers and heaters.
Dry low NOX technology to reduce NOX emissions and increase cogeneration plant efficiency.
Boiler and heater technology that will meet provincial and federal government emission requirements.
Purchase Tier IV compliant haul trucks when they become available.
Optimize mine planning to reduce haul distances.
Develop and implement an anti-idling program for the mine fleet.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
SO2 emissions None. Teck commits to implement the following mitigation measures to reduce SO2 emissions from combustion sources (see the response to JRP IR 3.18, Table 3.18-1):
Use natural gas as a fuel for the cogeneration plant and boilers and heaters.
Use ultra-low sulphur diesel for the mine fleet.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
PM2.5 and dust emissions None. Teck commits to implement the following mitigation measures to reduce PM2.5 emissions from combustion sources (see the response to JRP IR 3.18, Table 3.18-1):
Use natural gas as a fuel for the cogeneration plant and boilers and heaters.
Boiler and heater technology that will meet provincial and national government emission requirements.
Purchase Tier IV compliant haul trucks when they become available.
Optimize mine planning to reduce haul distances.
Develop and implement an anti-idling program for the mine fleet.
Teck commits to implement the following mitigation measures to reduce fugitive dust emissions (see the response to JRP IR 3.18, Table 3.18-1):
Dust mitigation measures to be applied to onsite roads during construction include appropriate selection of road materials, limiting vehicle speeds, surface watering, progressive reclamation, temporary vegetation of disturbed land and retain natural vegetation as windbreaks.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Hydrocarbon and reduced sulphur emissions and secondary organic aerosol precursor emissions
None. Teck commits to implement the following mitigation measures to reduce fugitive plant emissions (see the response to JRP IR 3.18, Table 3.18-1):
Use floating roof tanks where appropriate and a vapour recovery system to condense and recover vapours from storage tanks and process areas.
Use dual solvent vapour recovery units to provide full redundancy.
Conduct a leak detection and repair (LDAR) program to identify leaking components and to prioritize associated repairs.
Teck commits to implement the following mitigation measures to reduce fugitive mine face emissions (see the response to JRP IR 3.18, Table 3.18-1):
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Mitigation not currently known.
Teck commits to implement the following mitigation measures to reduce fugitive tailings area emissions (see the response to JRP IR 3.18, Table 3.18-1):
Tailing solvent recovery unit to maintain losses to less than four volumes of solvent to 1,000 volumes of bitumen produced.
Teck commits to implement the following mitigation measures to reduce hydrocarbon and reduced sulphur emissions from combustion sources (see the response to JRP IR 3.18, Table 3.18-1):
Use natural gas as a fuel for the cogeneration plant and boilers and heaters.
Purchase Tier IV compliant haul trucks when they become available.
Optimize mine planning to reduce haul distances.
Develop and implement an anti-idling program for the mine fleet.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Odour None. Teck has developed a draft Odour Management and Response Plan (see the response to JRP IR 3.13, Appendix 3.13). The draft Plan. The Plan’s goals are mitigation, monitoring, participation in regional complaint process, and correlation of complaints to Project activities to determine response actions. The Plan will be finalized following consultation with Indigenous communities, regulators and stakeholders.
At any time during Project operation, nearby residences will be able to contact Teck if they are concerned that Project operations are causing odours. The contact will be documented, investigative action will be initiated to determine the potential source, and the caller will be notified. If a source can be identified, a review will be undertaken to implement corrective action to reduce the potential for future occurrences (ERCB Round 1 SIR 113a; Appendix 3.13).
Acoustics
Change in sound levels None. Teck has made an overall commitment to managing and promptly addressing all noise-related concerns (see Volume 3, Section 3.4.9.2, Project Update) and will develop a Noise Management Plan (see Volume 3, Section 3.4.9.1, Project Update).
Teck also commits to implement the following mitigation measures to reduce changes in sound levels (see Volume 3, Appendix 17H, Section 17H.5 of the Project Update and the response to JRP IR 1.3, Table 1.4-1):
Vehicles will be maintained in good working condition (e.g., mufflers will be maintained) and speed limits will be enforced.
Emergency alarms will be tested during daytime, where reasonably practical.
Acoustic performance of building wall construction will meet a minimum sound transmission class (STC) rating of 29, based on published data in the North American Insulation Manufacturers Association for a pre-engineered structure.
For outdoor equipment, the manufacturer incorporates mitigation in the equipment design to achieve the published sound power level.
Noise effects will be mitigated using various measures, including but not limited to the following:
o haul trucks exhaust silencer
o haul truck speed
o trip frequency (number of trips per daytime and nighttime period)
o route location or alignment
Ventilation openings (i.e., air intake and exhaust openings) will be fitted with appropriate acoustic silencers, louvers, or plenums, where applicable, to reduce outdoor sound transmission from indoor equipment.
Buildings housing indoor noise-generating equipment will be appropriately sealed to reduce noise.
Where practical, flanking path and penetrations from plumbing, heating ducts and electrical wire in the buildings will be properly insulated and covered to reduce noise.
Appropriate acoustical lagging will be installed to provide additional attenuation to the steel casing, where practical.
Vibration isolation pads, resilient mounts on equipment, resilient pipe support systems, and dampers will be installed where appropriate.
Teck will incorporate best management practices to reduce Project-related noise into Daily Operational Procedures, Long-Term Operational Procedures, design for low-noise facilities, and performance measurement as described in SPOG (2012) Best Practices Document, where appropriate (ERCB Round 1 SIR 116; Volume 3, Section 3.4.9.1 of the Project Update), including:
Daily Operational Procedures
Keeping compressor station doors and windows closed
Using belt dressing
Inspecting and repairing mufflers
Running fans slower at night (variable frequency drive [VFD])
Using vent silencers on buildings
Using soundproofing (insulation and lagging)
Troubleshooting transient noise
Minimizing flaring and venting
Considering gravel pack around compressor building skids
Developing noise check in daily reading sheets
Long-Term Operational Procedures
Responding quickly to noise concerns
Establishing baseline noise levels (in plant, at fence-line, or both) and resurvey to determine trends
Conducting regular assessment of noise control opportunities
Using best practical technology for noise control
Maintaining communication links with noise sensitive receptors and communities
Being aware of noise from contractors (e.g., service rigs) and developing processes to meet best practice expectations
Frontier Oil Sands Mine Project Appendix 10.12
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Scheduling work to create the least amount of noise effects on noise sensitive receptors and keeping those affected informed
Design for Low Noise Facilities
Considering low noise electric drives versus engine driven compressors
Designing cooler fans for low tip velocity
Orienting noise sources away from residents
Using acoustical pipe lagging
Installing VFDs on coolers
Performance Measurement
Conducting measurements and establishing baseline data
Using best practices as part of the company’s operating procedures
Visual
Change to visual environment None. Teck commits to implement the following mitigation measures to reduce changes to visual effects (see Volume 1, Section 8.3.6, Volume 3, Section 16.4.6, Volume 3, Section 18.10.4.2, Volume 3, Section 18.11.5.4 and Volume 3, Appendix 17H, Section 17H.7 of the Project Update):
Maintaining vegetated buffers between the Project and the Athabasca River as well as along Project transportation corridors to the extent feasible where safety concerns are not an issue.
Using construction materials that reduce contrast, limit visual attraction to Project features, and blending built structures into the natural surrounding environment.
Using construction materials, where practicable, that minimize light reflection, potentially reducing viewing distances of Project features
Reclamation techniques will be used that integrate closure plans with the surrounding landscape.
Teck will seek to develop closure plans that:
o Include integration and contouring of slopes that mimic natural topography.
o Focus on establishing a variety of vegetation communities.
o Avoid unnatural-looking breaks at development boundaries.
Planting a narrow band of white spruce along the edge of the river water intake (RWI) cofferdam and plant dogwood on the cofferdam, except in areas where tall vegetation would impede any maintenance or present safety concerns.
Completing reclamation in the RWI area to minimize erosion and slope instability.
Using lighting that minimizes light pollution.
At closure, infrastructure will be removed and the Project will be reclaimed using vegetation types similar, though not identical to existing conditions, creating a continuous vegetated landscape.
A lighting plan will be developed during future stages of engineering to avoid over-illumination. Lighting design will be part of future stages of engineering, and Teck will consult with interested Indigenous communities about lighting considerations.
Finish the Athabasca River Bridge with low-glare materials and plant vegetation buffers near the bridge. Teck also commits to clear minimal vegetation and to vegetate cleared areas.
Retain treed buffers around or near watercourses.
Fish and Fish Habitat
Change in productive fish habitat
None. Fish habitat of equivalent or higher productivity than that affected by the Project will be created through offsetting measures where prevention of adverse habitat alteration or loss (i.e., reduced habitat productivity or loss of productive habitat area) is not feasible (see the draft Detailed Fisheries Offsetting Plan, the response to JRP IR 2.1, Appendix 2.1).
Teck also commits to implement the following mitigation measures to avoid or reduce changes in fish habitat quantity or quality (see the response to JRP IR 2.1, Table 5):
To avoid or reduce sedimentation:
o Temporary and permanent erosion and sediment control measures for construction activities and disturbed areas.
o Stabilization and revegetation of disturbed areas.
o Isolation of instream work areas where they are required.
o Best management practices and regulatory guidelines for construction activities in and near watercourses/waterbodies for erosion and sediment control.
o Polishing ponds or other measures to reduce suspended sediment concentrations in discharge waters to avoid increases in sedimentation in the receiving environment.
o Appropriate design of constructed channels and ponds to reduce internal erosion and generation of suspended sediments.
o Appropriate design and construction of reclaimed landscape to reduce sediment yield.
To avoid or reduce changes to water quality:
o Passing muskeg drainage and overburden water through polishing ponds and drainage ditches to reduce changes in water temperatures and dissolved oxygen concentrations.
o Recycling of process affected waters during operations.
o Capture and recycling of ETA seepage and run off water during operations, and use of a passive seepage control system at closure.
o Use of wetlands, pit lakes and constructed reclamation lakes in the closure drainage system to provide biological remediation before release to the environment.
o Removal of organic material from fish habitat compensation lake (FHCL) area prior to flooding.
To avoid or reduce changes to habitat area:
o Diversion of watercourses around the PDA to return natural upslope water back to the diverted watercourse to preserve flows and avoid elimination of downstream habitats.
o Provision of a flow splitter on the diversion channel that will collect water from both upper Redclay Creek and Unnamed Creek 17 to appropriately apportion the flows in lower Redclay Creek and Unnamed Creek 17 to avoid flow changes in the Ronald Lake watershed.
o Operation of the RWI and Off Stream Storage Pond (OSSP) in compliance with the Lower Athabasca River Surface Water Quantity Management Framework.
o Design of the closure drainage channels and pit lakes to provide habitats capable of supporting aquatic ecosystems.
o Best management practices and regulatory guidelines to ensure construction and operation of the RWI, Athabasca River bridge and watercourse crossings associated with access roads do not interfere
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with fish passage and access to available habitats.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Change in fish abundance None. Teck commits to implement the following mitigation measures to avoid or reduce changes in fish abundance (see the response to JRP IR 2.1, Table 5):
Fish rescue operations to capture and relocate fish prior to habitat dewatering.
Screening of the RWI in compliance with regulatory guidelines to mitigate fish entrainment or impingement.
Best management practices and regulatory guidelines for scheduling construction activities in and near waterbodies/watercourse to avoid sensitive time periods in adjacent or downstream fish-bearing watercourses.
Education of Project personnel on sustainable fishing practices to support a Teck applied prohibition on their fishing in watercourses or waterbodies in the PDA to mitigate potential increases in recreational fishing pressure.
Access Management Plan for the PDA to limit access to fish bearing habitats to mitigate increased fishing pressure.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Change in fish and fish habitat diversity
None. Teck commits to implement the following mitigation measures to avoid or reduce changes in fish and fish habitat diversity (see the response to JRP IR 2.1, Table 5):
Several of the measures intended to avoid or mitigate effects to fish habitat and fish abundance also apply to fish and fish habitat diversity, in cases where they preserve fish and productive fish habitats or create new habitats, including:
o Diversions designed to preserve flows and avoid elimination of downstream habitats.
o Closure drainage channels and pit lakes designed to provide habitats capable of supporting aquatic ecosystems.
o Fish rescue operations.
o Screening of the RWI.
o Education and prohibition of Project personnel from fishing in the PDA.
o Access Management for the PDA to limit access to fish bearing habitats.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Wildlife
Change in wildlife habitat availability
None. Teck commits to implement the following mitigation measures to reduce direct habitat loss (see the response to JRP IR 7.14, Table 7.14-1):
Limit the size of the east side access road right-of-way (ROW) and temporary workspace to the extent practical.
Limit the Athabasca River bridge footprint in riparian areas.
Carry out progressive reclamation to reclaim disturbed wildlife habitat as portions of the mine footprint become available.
Develop a weed management plan.
Teck commits to implement the following mitigation measures to reduce indirect habitat loss (see the response to JRP IR 7.14, Table 7.14-1):
Implement strategies to reduce noise and light effects, including design considerations (e.g., Frontier Project plant site engineering and aerodrome operation within regulatory and safety constraints).
Limiting employee and contractor access to identified areas of high-quality habitat adjacent to Project footprint.
Teck commits to developing a Biodiversity Management Plan (BMP) with the underlying goal of optimizing reclamation during operations to reduce offsetting of residual environmental effects (see the response to JRP IR 7.15).
Teck has developed a Draft Wildlife Mitigation, Monitoring and Adaptive Management Plan (WMMP; see the response to JRP IR 7.14, Appendix 7.14). Teck has proposed steps to Indigenous groups that would provide the opportunity for land users and community members to provide direct input into developing wildlife mitigation measures. Input will refine this draft WMMP. Once finalized, the plan will include a communication management section, which will outline how findings of the program will be communicated to interested parties.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Change in wildlife landscape connectivity
None. Teck commits to implement the following mitigation measures to reduce change to landscape connectivity (see the response to JRP IR 7.14, Table 7.14-1):
Carry out progressive reclamation to restore habitat for movement as portions of the mine footprint become available.
To maintain connectivity between Birch Mountains and Athabasca River:
o Coordinate development activities with Canadian Natural Resources Limited (CNRL) who acquired the Pierre River Mine oil sands leases formerly held by Shell Canada Limited should CNRL reapply for and develop the Pierre River Mine project.
o Develop an integrated land management strategy for the Project in consultation with industry, the province, Indigenous communities, and stakeholders.
Provide wildlife passage under both sides of the Athabasca River bridge and river water intake bridge to Dalkin Island to allow north–south wildlife movement along river banks using crossing design considerations (e.g., bridge height and length) outlined in Clevenger and Huijser (2011) and GOA (2011).
Set up educational signage to limit human use of wildlife underpasses.
Evaluate wing fencing along the approach to crossing passages (at least 2.4 m high for large mammals as per GOA 2011) as part of the crossing structure design.
Provide appropriate walking substrate along the wildlife underpass.
Create vegetated buffers adjacent to wildlife underpasses to increase movement opportunities for a variety of species.
Provide coarse woody debris (e.g., stumps) along the wildlife underpass to provide cover and increase use by furbearers and other small mammals.
Teck has developed a Draft WMMP (see the response to JRP IR 7.14, Appendix 7.14). Teck has proposed steps to Indigenous groups that would provide the opportunity for land users and community members to provide direct input into developing wildlife mitigation measures. Input will refine this draft WMMP. Once finalized, the plan will include a communication management section, which will outline how findings of the program will be communicated to interested parties.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Frontier Oil Sands Mine Project Appendix 10.12
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Change in wildlife mortality risk
None. Teck commits to implement the following mitigation measures to reduce wildlife mortality risk resulting from vehicle–wildlife collisions (see the response to JRP IR 7.14, Table 7.14-1):
Implement fly-in/fly-out policy for workers to reduce vehicular traffic volume.
Erect wildlife cautionary signage on access roads.
Foster environmental awareness with speed restrictions on access roads report Project-related wildlife fatalities.
Provide vegetation maintenance at roadsides (vegetation will be trimmed regularly to discourage roadside foraging and prevent visual obstruction of wildlife).
Develop seed mixes for roadside reclamation from less palatable species to reduce wildlife attraction to road edges.
Design the road to maximize line of sight.
Remove road kill as soon as practical.
Teck commits to implement the following mitigation measures to reduce wildlife mortality risk resulting from wildlife interactions with equipment (see the response to JRP IR 7.14, Table 7.14-1):
Implement preconstruction surveys for active wildlife habitat features (e.g., nests, breeding wetlands) before starting early works.
Avoid vegetation clearing during the recommended May 1 to August 10 migratory bird-breeding period for the boreal ecozone per Environment Canada guidelines; note that in species at risk habitat, a more conservative breeding window of April 1 to August 31 might apply (Gregoire 2014, pers. comm.); complete nest surveys if clearing activities occur during the breeding window.
Conduct owl nest search if clearing is scheduled within the non-migratory breeding bird window, March 1 to April 15 (based on Enhanced Approval Process guidelines for barred owl, GOA 2013).
Reduce on disturbance of amphibian breeding and overwintering habitat (where possible).
Teck commits to implement the following mitigation measures to reduce wildlife mortality risk resulting from interactions with Infrastructure (see the response to JRP IR 7.14, Table 7.14-1):
Create fuel and chemical spill contingency and response plans.
Confirm adequate spill protection for all fuel storage facilities.
Monitor and maintain waste disposal sites, wastewater storage areas and runoff control structures to prevent surface water impacts.
During overburden dewatering, intermittently backslope the sides of drainage ditches to allow for wildlife crossings and to reduce the potential for entrapment.
Use visible markers, such as aviation spheres and spiral vibration dampeners to make transmission lines near waterfowl staging and potential stopover areas more visible to birds, and where possible, design transmission lines to match the height of surrounding trees to reduce wire strikes by birds.
Teck commits to implement the following mitigation measures to reduce wildlife mortality risk resulting from wildlife–human conflicts (see the response to JRP IR 7.14, Table 7.14-1):
Implement a food waste-management strategy to prevent attraction of nuisance wildlife.
Confirm wildlife is not harassed or fed (to prevent habituation).
Provide wildlife awareness training to Project staff and contractors to reduce disturbance and negative human/bear interactions.
Provide all field staff with bear-aware training courses, personal protective equipment (e.g., bear spray, bear bangers, air horns) and training on proper use of equipment.
Develop a nuisance wildlife mitigation and monitoring plan in cooperation with the regulators.
Teck commits to implement the following mitigation measures to reduce wildlife mortality risk resulting from increased hunter access (see the response to JRP IR 7.14, Table 7.14-1):
Implement deactivation plans for roads no longer in use.
Prohibit construction and operations personnel and contractors from hunting and trapping while working.
Disallow personal recreational vehicle use onsite.
Prohibit firearms on Project lands or at Project facilities.
Consider requesting a Directors Order to limit public access to the west side of the Athabasca River along Project roads.
Teck has developed a Draft WMMP (see the response to JRP IR 7.14, Appendix 7.14). Teck has proposed steps to Indigenous groups that would provide the opportunity for land users and community members to provide direct input into developing wildlife mitigation measures. Input will refine this draft WMMP. Once finalized, the plan will include a communication management section, which will outline how findings of the program will be communicated to interested parties.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Waterfowl
Change in bird mortality risk
None. Teck commits to implement the following mitigation measures to reduce migratory water bird mortality risk resulting from the use of ponds (see the response to JRP IR 7.10, Table 7.10-1):
Develop detailed construction and operational procedures and mitigation measures to reduce wildlife mortality during tailings area start-up.
Design the sides of wastewater ponds to reduce attractiveness to birds (e.g., using gravel for sides).
Clear trees and above-ground vegetation including shrubs, herbs and the ground layer prior to placement of tailings into tailings disposal areas.
Remove peat from tailings area prior to flooding.
Develop detailed construction and operational procedures and mitigation measures to reduce wildlife mortality during tailings area start-up.
Reduce attractiveness of tailings areas for birds by keeping the inner walls of the tailings dyke free of vegetation.
Keep slopes of tailings areas as steep as possible to reduce “black beach” areas.
Implement procedure for removing any peat mats that float to the surface of the tailings area.
Implement procedure for controlling floating bitumen mats.
Manage the use and operation of anthropogenic lighting around wastewater ponds and tailings areas.
Bird deterrent systems will be used to discourage birds from landing on wastewater ponds and tailings areas.
Teck commits to implement the following mitigation measure to reduce the potential for birds to land in ponds containing process-affected water (see the response to ESRD/CEAA Round 3 SIR 64):
Bird deterrent systems will be installed on all ponds associated with the Project that have process-affected water that could be detrimental to birds.
Teck commits to implement the following mitigation measures to maximize recovery efficiency should birds use ponds (see the response to JRP IR 7.10, Table 7.10-1):
Frontier Oil Sands Mine Project Appendix 10.12
Table 10.12-16: Potential Adverse Environmental Effect and Mitigation Table – Mikisew Cree First Nation (continued)
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Develop procedure for handling of any bird recovered from wastewater ponds or tailings areas.
Procedure will be in compliance with directions received from the local Alberta Fish and Wildlife office and/or the Alberta Environment and Parks (AEP) wildlife biologist.
Procedure will also be in compliance with directions from Environment and Climate Change Canada with respect to whooping cranes.
Teck commits to implement the following mitigation measures to reduce the potential for bird mortality risk resulting from interaction with transmission and distribution lines (see the response to JRP IR 7.10, Table 7.10-1):
Designing transmission and distribution lines, where possible, to match the height of surrounding trees to reduce wire strikes by birds.
Marking of transmission and distribution lines in areas near waterfowl staging and potential stopover areas.
Teck has developed a Draft Waterfowl Protection Plan (see the response to JRP IR 7.10, Appendix 7.10). Teck will continue to pursue collaborative engagement processes, as outlined in the WMMP for the Project as the primary mechanism in which it will engage with potentially affected Indigenous groups regarding the Waterfowl Protection Plan. Once finalized, the plan will include a communication management section, which will outline how findings of the program will be communicated to interested parties.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Bison
Change in bison habitat availability
MCFN members consider protection measures, including access management, limits on non-aboriginal hunting, and limits on industrial development to be critical for the future viability of the Ronald Lake herd and the practice of MCFN’s treaty right to hunt bison in preferred areas and using preferred means (Candler et al. 2015a, p. 70; Candler et al. 2015b, p. 40).
Teck commits to implement the following mitigation measures to reduce direct habitat loss (see the response to JRP IR 7.5, Table 7.5-1):
Limit the size of the east side access road right-of-way (ROW) and temporary workspace to the extent practical.
Limit the Athabasca Rive bridge footprint in riparian areas.
Carry out progressive reclamation to reclaim disturbed wildlife habitat as portions of the mine footprint become available.
Develop a weed management plan.
Teck commits to implement the following mitigation measures to reduce indirect habitat loss (see the response to JRP IR 7.5, Table 7.5-1):
Implement strategies to reduce noise and light effects, including design considerations (e.g., Frontier Project plant site engineering and aerodrome operation within regulatory and safety constraints).
Limiting employee and contractor access to identified areas of high-quality habitat adjacent to Project footprint.
Teck has developed a Draft Ronald Lake Bison Mitigation, Monitoring and Adaptive Management Plan (see the response to JRP IR 7.5, Appendix 7.5). Teck has proposed steps to Indigenous groups that would provide the opportunity for land users and community members to provide direct input into developing wildlife mitigation measures, including those specific to bison. Once finalized, the plan will include a communication management section, which will outline how findings of the program will be communicated to interested parties.
Teck will also work with the responsible authority to explore possible mitigations for which Teck does not have the authority to implement independently.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Change in bison landscape connectivity
MCFN members consider protection measures, including access management, limits on non-aboriginal hunting, and limits on industrial development to be critical for the future viability of the Ronald Lake herd and the practice of MCFN’s treaty right to hunt bison in preferred areas and using preferred means (Candler et al. 2015a, p. 70; Candler et al. 2015b, p. 40).
Teck commits to implement the following mitigation measures to reduce change to landscape connectivity (see the response to JRP IR 7.5, Table 7.5-1):
Carry out progressive reclamation to restore vegetated corridors as portions of the mine footprint become available.
To maintain connectivity between Birch Mountains and Athabasca River:
o Coordinate development activities with Canadian Natural Resources Limited (CNRL) who acquired the Pierre River Mine oil sands leases formerly held by Shell Canada Limited should CNRL reapply for and develop the Pierre River Mine project.
o Develop an integrated land management strategy for the Project in consultation with industry, Indigenous stakeholders and the Province.
Provide wildlife passage under both sides of the Athabasca River bridge and river water intake bridge to Dalkin Island to allow north–south wildlife movement along river banks using crossing design considerations (e.g., bridge height and length) outlined in Clevenger and Huijser (2011) and GOA (2011):
o Set up educational signage to limit human use of wildlife underpasses.
o Evaluate wing fencing along the approach to crossing passages (at least 2.4 m high for large mammals as per GOA 2011) as part of the crossing structure design.
o Provide appropriate walking substrate along the wildlife underpass.
o Create vegetated buffers adjacent to wildlife underpasses to increase movement opportunities for a variety of species.
Teck has developed a Draft Ronald Lake Bison Mitigation, Monitoring and Adaptive Management Plan (see the response to JRP IR 7.5, Appendix 7.5). Teck has proposed steps to Indigenous groups that would provide the opportunity for land users and community members to provide direct input into developing wildlife mitigation measures, including those specific to bison. Once finalized, the plan will include a communication management section, which will outline how findings of the program will be communicated to interested parties.
Teck will also work with the responsible authority to explore possible mitigations for which Teck does not have the authority to implement independently.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Change in bison mortality risk MCFN members consider protection measures, including access management, limits on non-aboriginal hunting, and limits on industrial development to be critical for the future viability of the Ronald Lake herd and the practice of MCFN’s treaty right to hunt bison in preferred areas and using preferred means (Candler et al. 2015a, p. 70; Candler et al. 2015b, p. 40).
Teck commits to implement the following mitigation measures to reduce bison mortality risk resulting from vehicle–bison collisions (see the response to JRP IR 7.5, Table 7.5-1):
Implement fly-in/fly-out policy for workers to reduce vehicular traffic volume.
Erect wildlife cautionary signage on access roads.
Foster environmental awareness with speed restrictions on access roads, report Project-related wildlife fatalities.
Provide vegetation maintenance at roadsides (vegetation will be trimmed regularly to discourage roadside foraging and prevent visual obstruction of wildlife).
Develop seed mixes for roadside reclamation from less palatable species to reduce wildlife attraction to road edges.
Design the road to maximize line of sight.
Teck commits to implement the following mitigation measures to reduce bison mortality risk resulting from bison-human interactions - interactions with infrastructure (see the response to JRP IR 7.5, Table 7.5-1):
Create fuel and chemical spill contingency and response plans.
Confirm adequate spill protection for all fuel storage facilities.
Frontier Oil Sands Mine Project Appendix 10.12
Table 10.12-16: Potential Adverse Environmental Effect and Mitigation Table – Mikisew Cree First Nation (continued)
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Potential Adverse Effects Mitigation Proposed by Mikisew Cree First
Nation in TLU Study, IK study and CIA Mitigation Teck Commits to Implement
Monitor and maintain waste disposal sites, wastewater storage areas and runoff control structures to prevent contamination of surface waters.
During overburden dewatering, intermittently backslope the sides of drainage ditches to allow for wildlife crossings and to reduce the potential for entrapment.
Teck commits to implement the following mitigation measures to reduce bison mortality risk resulting from hunter access (see the response to JRP IR 7.5, Table 7.5-1):
Construct predator access blocks to deter predator use (i.e., reduce line of sight) on linear features in the PDA that may leave core bison areas susceptible to predation.
Deactivate roads in the PDA no longer in use.
Implement employee / contractor policies to prohibit hunting within the Project area.
Reduce linear features in the closure landscape.
Reduce width of linear features in the closure landscape.
Teck commits to implement the following mitigation measures to reduce bison mortality risk resulting from disease transmission to the Ronald Lake bison herd (see the response to JRP IR 7.5, Table 7.5-1):
Implement progressive reclamation in the PDA to create suitable Ronald Lake bison habitat and reduce the potential of shifting habitat use northward.
Mitigations associated with reducing hunter and predator access.
Mitigations associated with reducing wildlife human conflict.
Mitigations associated with reducing indirect habitat loss.
Teck has developed a Draft Ronald Lake Bison Mitigation, Monitoring and Adaptive Management Plan (see the response to JRP IR 7.5, Appendix 7.5). Teck has proposed steps to Indigenous groups that would provide the opportunity for land users and community members to provide direct input into developing wildlife mitigation measures, including those specific to bison. Once finalized, the plan will include a communication management section, which will outline how findings of the program will be communicated to interested parties.
Teck will also work with the responsible authority to explore possible mitigations for which Teck does not have the authority to implement independently.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Vegetation
Change in vegetation None. Teck is committed to continue working with potentially affected Indigenous groups to refine the closure, conservation and reclamation (CC&R) plan through the life of the Project and to incorporate input from Indigenous groups on reclamation monitoring and thresholds and document the establishment of traditional use vegetation in the reclaimed landscape. Teck plans to co-create Reclamation Working Group(s) with potentially affected Indigenous groups to seek input to the Project’s reclamation plan and measures and targets to determine its success. It anticipates that species of traditional importance will be identified by Reclamation Working Group(s) and incorporated into reclamation planning as feasible. In addition, collaborative participation is planned in reclamation research both from a Project and regional perspective. Results of this research will be incorporated into future Project plans (see the response to JRP IR 6.9, Section 4.2).
Teck also commits to implement the following mitigation measures to reduce change in vegetation (see Volume 3, Appendix 17H, Section 17H.4 of the Project Update; response to JRP IRs 6.8 and 6.10):
Reclamation of the closure landscape will focus on generating a sustainable landscape that is designed to maximize diversity through the generation of landforms that include:
o topographic diversity and associated diversity in moisture regimes
o aspect diversity
o substrate diversity including both fine- and coarse- grained landforms
o mesotopography
Removal of existing linear disturbances that are currently fragmenting the landscape.
Mitigation to reduce effects on community diversity will focus on research results and strategies as summarized in:
o Guidelines for Reclamation to Forest Vegetation in the Athabasca Oil Sands Region (2nd Edition) (ESRD 2010)
o Guideline for Wetland Establishment on Reclaimed Oil Sands Leases (3rd Edition) (CEMA 2014)
o Oil Sands Marshes: A Knowledge Transfer (Charette et al. 2012)
o Best Management Practices for Conservation of Reclamation Materials in the Mineable Oil Sands Region of Alberta (MacKenzie 2011)
o Restoration and Reclamation of Boreal Ecosystems: Attaining Sustainable Development (Vitt and Bhatti 2012)
o Riparian Classification and Reclamation Guide, Revised Edition (Mihajlovich 2012)
Include peatlands in detailed CC&R planning should research results and recommendations prove to be feasible and appropriate.
Work with the governments of Alberta and Canada and look to their guidance on the development of a Conservation Agreement.
Plant additional species on the reclamation landscape, including those with traditional value, to supplement those recommended in provincial reclamation guidelines.
Mitigation for rare plant species will be achieved through avoidance whenever possible. In areas where avoidance is not possible, alternate mitigation strategies will be developed to promote conservation of these species and associated genetic diversity.
A weed management plan will be implemented throughout the life of the Project including during reclamation and at closure.
Develop and implement a program to salvage and relocate known occurrences of rare (vascular) plant species to areas outside of the Project area in consultation with Indigenous communities.
Incorporate species of traditional important as identified through the Reclamation Working Group(s) into reclamation planning, as feasible.
Engage Indigenous communities in preparing plans to harvest and collect seeds, and will invite community members to harvest and collect seeds of rare and culturally important species before disturbance, for use in reproducing the species and revegetation of the Project area.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures related to reclamation and evaluate monitoring results to determine if adaptations are warranted.
Historical Resources
Changes to historical resources within the Project disturbance area
None. Teck commits to implement the following mitigation measures regarding changes to historical resources within the Project disturbance area (see Volume 3, Appendix 17H, Section 17H.9 of the Project Update):
Historical resources sites in the PDA that Alberta Culture and Tourism (ACT) determines to have moderate to high heritage value will likely have requirements for further study. These might include some or all of the following:
Frontier Oil Sands Mine Project Appendix 10.12
Table 10.12-16: Potential Adverse Environmental Effect and Mitigation Table – Mikisew Cree First Nation (continued)
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o Additional shovel testing to identify site boundaries, areas of highest artifact density, activity areas and areas with unique or specialized artifacts.
o Archaeological excavation at sites with high interpretive potential.
o Mapping and documentation at specific sites.
Teck will phase the required supplemental historic resources impact assessment (HRIA) studies to ensure completion of all necessary studies in the PDA in advance of vegetation clearing in each development area.
Teck will also work collaboratively with local First Nation and Aboriginal communities on mitigation studies, in an effort to address local concerns and interests in relation to historical resources in the area.
Socio-economics
Change to housing needs None. Teck commits to implement the following mitigation measures regarding housing needs (see the response to JRP IR 5.14(a), Table 5.15a-1):
Provide on-site, lodge-based accommodations during construction and operations to reduce the Project’s effect on the resident population and associated effects on social infrastructure and housing in the region.
Offer lodge amenities and services – including individual rooms and shared spaces, the quality of the food services and free-time activities – that are competitive with other lodge accommodations in the region.
Change to social infrastructure needs
None.
Teck commits to implement the following mitigation measures regarding social infrastructure needs (see the response to JRP IR 5.14(a), Table 5.15a-2):
Maintain explicit and enforced lodge, workplace and flight policies with regards to the use of alcohol, drugs and illegal activities.
Provide onsite security services, including controlled gates, check-in procedures, perimeter security fencing and lodge-based security officers on duty 24 hours.
Offer in-house security services to assist the Royal Canadian Mounted Police (RCMP) within, and sometimes outside, the Project lease boundaries (e.g., securing accident scenes and assisting with highway closures).
Develop and implement an emergency response plan which includes the required personnel, procedures and equipment resources (e.g., vehicles, fire response, medical response and rescue).
Develop required mitigation measures for areas adjacent to the Project area based on the FireSmart Wildfire Assessment System and implement in the emergency response plan.
Enter into mutual aid agreements with the Regional Municipality of Wood Buffalo (RMWB) and other oil sands companies that include:
o responding to motor vehicle accidents on Highway #63
o responding to forest fire threats to Fort McKay
o responding to regional spills
Participate in the management of regional emergencies at the RMWB’s Regional Emergency Operations Centre.
Make available onsite health services, including an on-site medical facility staffed by qualified health professionals providing 24-hour on-site primary, emergency and occupational health services.
Consider financial and in-kind contributions to the Northern Lights Health Foundation, where appropriate, to support the efforts of Alberta Health Services to meet the needs of Wood Buffalo residents. Recognizing some of the health concerns in the region Teck is prepared to make health promotion and disease prevention initiatives a focus of their community investment policy.
Provide helicopter or fixed-wing aircraft access via the on-site aerodrome for injured workers requiring rapid evacuation for off-site medical care.
Discuss with other industrial proponents near the Project options for coordinating on-site health facilities and resources.
Assess and support school events and education initiatives identified by rural schools in the study area, as appropriate.
Provide employees with access to the company’s confidential Employee and Family Assistance Plan, which provides support for families and individuals who might experience difficulty dealing with personal, family or work-life issues that can affect one’s health and well-being.
Consider support for community level initiatives including social groups providing assistance to those in need.
Continue providing direct support to community initiatives through its social investment programs.
Offer shift schedules that provide workers with sufficient time off to enjoy leisure activities in their home communities.
Make available onsite recreational opportunities and facilities.
Change to transportation needs
None. Teck commits to implement the following mitigation measures regarding transportation needs (see the response to JRP IR 5.14(a), Table 5.14a-3):
Construct and operate an aerodrome near the Project site.
Use on-site as well as regional lodge accommodations during both construction and operations to reduce worker commutes.
Use bus service for transporting construction and operations workers.
Limit private vehicles brought to the Project site.
Schedule truck traffic, including oversized loads, to off-peak hours.
Use an on-site concrete batch plant; and attempt to source aggregates from pits near to site.
Enforce lodge, workplace and flight policies with regards to the use of alcohol, drugs and illegal activities.
Work with the local RCMP to confirm communication on local effects.
Support the efforts of RMWB and Oil Sands Community Alliance (OSCA) to work with the provincial government to progress improvements to highway infrastructure in a timely way.
Keep responsible regional and provincial planners informed of the Project’s development plans and their timing.
Consult and cooperate with other operators regarding shift scheduling with a view to reduce overlap in commuter traffic.
Provide funding to assist in the maintenance and safety of applicable segments of Highway #63 from Fort McKay to Fort Chipewyan that are affected by the Project.
Change to municipal infrastructure needs
None. Teck commits to implement the following mitigation measures regarding municipal infrastructure (see the response to JRP IR 5.14(a), Table 5.14a-4):
Provide water and sewer services for the different mining areas and the associated processing facilities and infrastructure, including on-site lodges.
Teck commits to implement the following mitigation measures regarding choice of fly-in/fly-out (FIFO) (see the response to JRP IR 5.14(a), Table 5.14a-6):
A FIFO lodge-based approach to construction and operations.
Ongoing monitoring of the operations FIFO model and revisiting the approach should local circumstances change.
Teck’s monitoring will take into consideration input received via its workers, contractors and ongoing local stakeholder and Indigenous engagement process. This would likely include feedback with respect to the social and economic effects of the FIFO model on individual workers, their families and communities.
Commitment to include Fort Chipewyan in a FIFO program.
Engage with potential employees living in Fort Chipewyan to discuss shift schedules and other travel and lodging logistics that influence their choice to work at the Project versus other opportunities.
Frontier Oil Sands Mine Project Appendix 10.12
Table 10.12-16: Potential Adverse Environmental Effect and Mitigation Table – Mikisew Cree First Nation (continued)
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Discuss with local communities the design of FIFO shifts that best benefit its employees and families while remaining logistically and financially feasible.
Remain open to engaging in broader, regional initiatives, for example through the OSCA and its study of the use of aerodromes in the region.
Change to employment, business and training opportunity needs
None.
Teck commits to implement the following mitigation measures regarding employment, business and training opportunity needs (see the response to JRP IR 5.14(a), Table 5.14a-5):
Specific contractual commitments to Indigenous communities on employment, business and training opportunities will be made within Participation Agreements negotiated between Teck and the Indigenous community.
Prioritize recruiting residents from the region first, Alberta second, followed by the rest of Canada, then North America and then overseas countries.
Draw on various sources of labour in Canada that are traditionally under-represented in the labour market, including Indigenous people, immigrants and women.
Put in place a policy to hire local businesses and contractors that are competitive and able to meet the company’s needs is already in place.
Teck will consult with Indigenous communities regarding procurement and employment initiatives such as:
o Establishing mechanisms to enhance employment prospects of local residents, including preferential consideration.
o Using procurement processes that regard local ownership and prevalence of workers residing locally as positive criteria in goods and services vendor selection competitions.
o Establishing monitoring programs that measure local involvement, gather feedback and work with interested parties on how to improve results.
Implement Teck’s relevant charters, codes and policies, including its Indigenous Peoples Policy, when working with Indigenous peoples in seeking to develop lasting mutual benefits that respect Indigenous community’s values – including hiring, training and retention of Indigenous employees.
Utilize what Teck’s has learned to date from local Indigenous communities with which it is engaged for the Project to overcome oil sands specific challenges to Indigenous employment and procurement.
Consider work experience in lieu of a high school graduation for Indigenous peoples.
Work with the Fort McMurray Chamber of Commerce, the Northeastern Alberta Aboriginal Business Association (NAABA) and others to maximize contracting and employment opportunities in the region.
Offer a choice of worker turnaround cycles and opportunity to earn premium pay through overtime.
Continue to work with the Indigenous communities in the area and specifically with the communities of Fort McKay and Fort Chipewyan to develop Indigenous employment and business development program(s) guided by a commitment to: maximize opportunities for local Indigenous businesses to supply services and products in support of Project construction and operations; hire qualified Indigenous people from the communities surrounding the Project and support education, training and investment initiatives in local Indigenous communities, where appropriate.
Teck’s Indigenous community employment and business development program(s) will engage with Indigenous communities on establishing employment and procurement policies and procedures, as well as adaptive management mechanisms specific to Indigenous community employment and procurement.
Teck’s Indigenous community employment and business development program(s), as well as community-specific Participation Agreements will take into consideration input provided by local Indigenous communities, and will be guided by a commitment to: develop substantial opportunities for local Indigenous businesses to supply services and products in support of Project construction and operations; hire qualified Indigenous people from the communities surrounding the Project and support education, training and investment initiatives in local Indigenous communities, where appropriate.
Continuously monitor Teck’s local employment and procurement policies and programs, along with reporting the results of this monitoring as part of ongoing community consultation.
Teck has yet to determine the exact reporting and monitoring mechanisms for its local procurement and employment policies, but will engage with Indigenous communities on mechanisms and expects they will likely be similar to mechanisms used by Teck’s other operations. These might include:
o Total employment, attraction and retention rates, average salary levels and other general human resource data. Where possible, the data will be disaggregated at the local community level.
o Procurement activity, including examination of goods and services sourced from providers in local communities, value and length of contracts, types of goods and services provided and employment and enterprise effects associated with procurement.
o Additional potential mechanisms are identified in Teck’s draft socio-economic monitoring plan in response to JRP IR 5.15(a).
Continue supporting local labour force skills development, and work with communities, government and other industrial proponents on programs that assist community members overcome labour market barriers.
Change to culture Establish cumulative rights-based ecological and cultural thresholds in the regional study area with clear triggers where Project design modifications and other Project related management responses would be required (Candler et al. 2014c, p. 168).
Teck commits to implement the following mitigation measures regarding changes to culture (see the response to JRP IR 5.14(a), Tables 5-14a-6 and 5.14a-7):
Continue to expand Teck’s knowledge of, and engagement with, local stakeholders and Indigenous communities near the Project to confirm ongoing and growing participation in Project-related benefits, as well as the design of appropriate and effective mitigation measures to reduce any adverse effect. These efforts are envisioned to include capacity building support within Participation Agreements for Indigenous communities.
Provide cultural diversity awareness training to employees and contractors, focusing on respect for traditional land users as well as respect for Indigenous world views, customs and values.
Consider supportive workplace practices as Teck develops workplace policies and seek local Indigenous community input into cultural awareness programming to be provided at the Project site.
Carry out a review of Teck’s standard bereavement policy, including a review of policies from other fly in/fly out operations in Alberta, as operation specific policies are developed during future planning phases.
Continuing to provide cultural awareness training for all Project staff and contractors.
Considering key Indigenous access routes and access preferences in the Project’s draft Access Management Plan (AMP).
Considering cultural keystone species in the wildlife management and mitigation plan, FHCL and biodiversity management plan.
Incorporating and using Indigenous place names where applicable.
Supporting community-led projects to document Indigenous place names in their respective traditional territories.
Contributing to language retention programs and other programs that support retaining Indigenous culture, knowledge and practice (e.g., culture camps for youth).
Discuss with local communities the design of fly in/fly out shifts that best benefit its employees and families while remaining logistically and financially feasible.
Access
Change to access near the Project disturbance area
MCFN members consider protection measures, including access management, limits on non-aboriginal hunting, and limits on industrial development to be critical for the future viability of the Ronald Lake herd and the practice of MCFN’s treaty right to hunt bison in preferred areas and using preferred means (Candler et al. 2015a, p. 70; Candler et al. 2015b, p. 40).
Teck has developed a draft access management plan (AMP) for the Project to facilitate access to or through Teck’s mineral surface lease to the extent possible while maintaining worker and public safety (see the response to JRP 4.5, Appendix 4.5). Teck has proposed next steps to Indigenous groups that would provide the opportunity for land users and community members to provide direct input into developing access mitigation measures. This input will refine the draft AMP.
Teck commits to implement the following mitigation measures to reduce potential effects on changes to access near the Project disturbance area (see Volume 3, Appendix 17H, Section 17H.8.2 of the Project Update) and the response to JRP IR 10.9):
All individuals wanting to gain access to or through lands being actively developed, which is generally Teck’s mineral surface lease (MSL), will be required to submit an access request.
Traditional land users will be granted temporary access to and through the PDA according to the policy and processes set out in the AMP.
Traditional land users will not have to meet worker site access requirements but will be escorted by someone who has permanent site access (i.e., a worker).
Frontier Oil Sands Mine Project Appendix 10.12
Table 10.12-16: Potential Adverse Environmental Effect and Mitigation Table – Mikisew Cree First Nation (continued)
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Access through, and to portions of the PDA not being actively developed will not require an access request form be submitted. Individuals will be required to contact the site’s security office and provide adequate notice about when they plan to be in the area, who will be present, and the intended activities and general location(s) as they relate to Teck leases. All individuals passing through the PDA will have to check in at the security office and will be escorted by a Teck worker. Teck understands that Aboriginal communities desire that the advance notice period.
Throughout the life of the mine, access to locations in the PDA by Aboriginal community members will be based on mine advance. For safety reasons, harvesting and use of firearms would not be permitted in areas being actively mined or within and around facilities associated with the mine.
The River Road will be maintained through operations and will provide access to the Fish Habitat Compensation Lake, aerodrome, and areas north of the PDA.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Traditional Land Use
Change in availability of resources (wildlife, fish and vegetation), culturally important sites or areas for traditional activities and use of lands
MCFN members consider protection measures, including access management, limits on non-aboriginal hunting, and limits on industrial development to be critical for the future viability of the Ronald Lake herd and the practice of MCFN’s treaty right to hunt bison in preferred areas and using preferred means (Candler et al. 2015a, p. 70; Candler et al. 2015b, p. 40).
Teck commits to implement the following mitigation measures to reduce changes in availability of resources (wildlife, fish and vegetation), culturally important sites or areas for traditional activities and use of lands (assessed in Volume 3, Section 17.6 of the Project Update) (see the response to JRP IR 4.6, Table 4.6-1):
Grant traditional land users temporary access to and through the PDA according to the policy and processes set out in the draft access management plan.
Implement measures to mitigate Project-related effects on wildlife through the wildlife monitoring and mitigation plan.
Engage Indigenous communities in the development of a biodiversity management plan.
Implement measures to mitigate Project-related effects on fish and fish habitat through the detailed fisheries offsetting plan.
Implement measures to reduce Project-related effects on vegetation through the conservation closure and reclamation plan and the reclamation monitoring plan.
Historical resources sites in the PDA that Alberta Culture and Tourism (ACT) determines to have moderate to high heritage value will meet the requirements of ACT and aim to meet the desires of Indigenous communities.
Teck commits to implement the following mitigation measures to reduce effects on the land use experience for traditional land users (see the response to JRP IR 4.6, Table 4.6-1):
Establish Participation Agreements with Indigenous communities.
Invite traditional users to harvest traditional plants before disturbance.
Support the planning and implementation of an excursion for Indigenous communities within the terrestrial local study area prior to Project-related disturbance to describe Indigenous values, access and to recommend mitigation to avoid or limit effects on Indigenous access values.
Provide cultural diversity awareness training to employees and contractors focusing on respect for Indigenous land users, traplines, cabins, trails and equipment, as well as respect for Indigenous world views, customs and values.
Compensate Indigenous trappers following industry-community standards and the Alberta Trappers Compensation Program.
Project personnel will be prohibited from fishing, hunting and trapping within the PDA during work rotations, which is when Teck’s policies’ can be enforced.
Project personnel will be prohibited from using personal recreation vehicles within the PDA.
Investigate with potentially affected Indigenous communities through the Reclamation Working Group the concept of incorporating cultural values into reclamation planning.
Supporting documentation of community-specific cultural heritage.
Teck has developed a Draft Traditional Land Use Mitigation, Monitoring and Adaptive Management Plan (see the response to JRP IR 4.6, Appendix 4.6). Teck will continue to seek input and engage with Indigenous groups, as well as regulators where appropriate, as part of finalizing this plan. Once finalized, Teck will continue to pursue collaborative engagement processes with Indigenous groups as outlined in the plan. Through these collaborative engagement processes Teck will aim to minimize and mitigate potential Project effects on traditional land use. Once finalized, the plan will include a communication management section, which will outline how findings of the program will be communicated to interested parties.
Teck also commits to implement an adaptive management program to monitor the effectiveness of the mitigation measures and evaluate monitoring results to determine if adaptations are warranted.
Notes:
NOx = oxides of nitrogen; SO2 = sulphur dioxide; PM2.5 = particulate matter
Frontier Oil Sands Mine Project Appendix 10.12
Teck Resources Limited Page 103
February 2018
9 References
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Candler, C. Malone, M. and the Firelight Group Research Cooperative with the Mikisew Cree First Nation.
2015a. Addendum to the Mikisew Cree First Nation Indigenous Knowledge and Use Report and
Assessment for Teck Resources Limited’s Proposed Frontier Oil Sands Mine Project. May 28,
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Candler, C., Leech, S., Whittaker, C., and the Firelight Group with Mikisew Cree First Nation. 2015b.
Sakâw Mostos (Wood Bison): Mikisew Cree First Nation Indigenous Knowledge Study. April 10,
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9.1 Personal Communications
Gregoire, P. 2014. Canadian Wildlife Service, Environment Canada. Personal communication regarding nesting periods of migratory bird species at risk. Received August 20, 2014.