Ministry review of the Côté Gold Project Environmental Assessment

This Review is subject to the provisions of Ontario Regulation 616/98 which sets out a deadline for the completion of this document. The deadline for the completion of the Review was May 15, 2015 and was extended to February 15, 2016 to address comments received. This paragraph and the giving of the Notice of Completion are the notices required by subsection 7(3) of the Environmental Assessment Act.

The Review documents the ministry’s evaluation of the environmental assessment and takes the comments of the government agencies, the public and Aboriginal communities into consideration.

Executive summary

Who

Iamgold Corporation (Iamgold)

What

Ministry Review of an Environmental Assessment (EA) for the proposed undertaking which includes:

• The construction, operation and eventual rehabilitation of an open pit gold mine
• Iamgold is seeking approval to produce approximately 60,000 tonnes per day of ore production over a period of 15 years (Project)

The major proposed project components include:

• An open pit, approximately 210 hectares (ha) in area, with a depth of approximately 550 metres
• Mine rock area for approximately 20 million tonnes (Mt) of overburden and 850 Mt of mine rock
• Ore processing plant
• Tailings management area covering an area of approximately 840 ha to provide capacity for the storage of approximately 261 Mt of tailings over the expected Project life
• Water management facilities including drainage works, pipelines, water management ponds and watercourse realignments
• Support facilities and infrastructure including but not limited to administrative buildings, accommodations, explosive facilities, and water and waste management facilities
• Transportation infrastructure for the Project site, including a realignment of two kilometres (km) of the existing Eacom forestry road and a new 8.5 km main access road
• A new 230 kilovolt (kV) transmission line (approximately 120 km in length) connected to the existing Hydro One network in Timmins
• The decommissioning, closure and post-closure of the mine and mine related infrastructure

See Figures 1 and 2 for Project location and Project site layout.

When

EA timelines

EA submitted: February 20, 2015
EA comment period (7 weeks): February 20 - April 10, 2015
Review comment period (5 weeks): March 14 - April 29, 2016

Proposed project timelines

Construction: There is currently no projected start date. It will be determined following the completion of a feasibility study (scheduled in 2017), economic feasibility (global gold market), and issuance of applicable federal and provincial legislative approvals.

Operation: Projected to be 15 years.

Closure and Rehabilitation: Expected to take 2 years, with passive reclamation occurring over several decades thereafter.

Where

The proposed open pit gold mine is located in Chester and Neville Townships in the District of Sudbury, in Northeastern Ontario. It is approximately 20 km southwest of Gogama, 130 km southwest of Timmins, and 200 km northwest of Sudbury. See Figure 1 for Project site location.

Why

The purpose of the undertaking is to produce gold for sale and provide a return on investment to shareholders of Iamgold by constructing and operating the mine. The underlying rationale for the Project is strong global demand for gold and the local and regional need in Northeastern Ontario for economic development.

Conclusions

The Review concludes that the EA was prepared in accordance with the approved Terms of Reference.

Iamgold has provided adequate information in the EA, together with additional supporting documentation that assesses potential environmental effects of the proposed undertaking.

However, ministry staff and Iamgold continue to engage on EA technical comments specific to surface water and groundwater. Ongoing discussions to resolve technical matters, together with proposed conditions of approval and proponent commitments should ensure that the environment remains protected as a result of the Project.

Public record locations

The public record for this environmental assessment can be reviewed during normal business hours at the following ministry office:

Ministry of the Environment and Climate Change
Environmental Approvals Branch
135 St. Clair Avenue West, 1^st Floor
Toronto, Ontario
Phone: 416-314-8001 / 1-800-461-6290
Fax: 416-314-8452

The Review and Notice of Completion are also available at the following locations:

Iamgold Corporation
3 Mesomikenda Lake Road
P.O. Box 100
Gogama, Ontario P0M 1W0
Phone: 705-269-0010

Gogama Public Library
3 Low Avenue
P.O. Box 238
Gogama, Ontario P0M 1W0
Phone: 705-894-2448

Greater Sudbury Public Library
74 Mackenzie Street
Sudbury, Ontario P3C 4X8
Phone: 705-673-1155

Timmins Public Library
320 Second Avenue
Timmins, Ontario P4N 8A4
Phone: 705-360-2623

Iamgold Corporation
401 Bay Street, Suite 3200
P.O. Box 153
Toronto, Ontario M5H 2Y4
Phone: 416-360-4710

Making a submission?

A five-week public review period ending April 29, 2016 will follow publication of this Review. During this time, any interested parties can make submissions about the proposed undertaking, the environmental assessment or this Review. Should you wish to make a submission, please send it to:

Director
Environmental Approvals Branch
Ministry of the Environment and Climate Change
135 St. Clair Avenue West, 1^st Floor
Toronto, Ontario M4V 1P5
Fax: 416-314-8452

Re: Côté Gold Project Environmental Assessment

Attention: Cindy Batista, Special Project Officer

Under the Freedom of Information and Protection of Privacy Act and the Environmental Assessment Act, unless otherwise stated in the submission, any personal information such as name, address, telephone number and property location included in all submissions become part of the public record files for this matter and can be released if requested.

Environmental assessment process

Environmental Assessment (EA) is a proponent driven planning process designed to incorporate the consideration of the environment into decision-making by assessing the effects of an undertaking on the environment. In Ontario, the Environmental Assessment Act (EAA) sets out the general contents for the preparation of an EA, as well as the Ministry of the Environment and Climate Change’s (ministry) evaluation process. For proponents and undertakings subject to the EAA, approval is required before the undertaking can proceed.

Proponents address a wide range of potential effects on the natural, social, cultural and economic environments to ensure the protection, conservation and wise management of the environment. An EA determines, on the basis of environmental effects, if an undertaking should proceed, and if so, how environmental effects can be managed.

EAs may identify a problem or opportunity, consider alternative ways of addressing the problem or opportunity, evaluate the environmental effects of the alternatives and select a preferred undertaking from the alternatives. The proponent must consider actions to avoid, reduce and mitigate potential environmental effects. In preparing the EA, the proponent completes various studies and consults with interested stakeholders including government agencies, the public and affected Aboriginal communities to evaluate the alternatives and determine the preferred undertaking. Once the undertaking is approved, the proponent is required to monitor the undertaking to demonstrate compliance with standards, regulations and the EAA approval.

1.1 Terms of reference

Preparing an EA is a two-step application to the Minister of the Environment and Climate Change (Minister). The first step requires the proponent to prepare and submit a Terms of Reference (ToR) to the ministry for review and approval. The ToR is the work plan or framework for how the EA will be prepared.

On January 14, 2014, the Minister approved Iamgold Corporation’s (Iamgold/proponent) ToR for the proposed Côté Gold Project (Project). The ToR established the framework for the preparation of the EA, including how Iamgold would assess alternatives, evaluate potential environmental effects (both positive and negative) and consult with the public and Aboriginal communities during the preparation of the EA. The ToR provided an initial Project description, rationale for the undertaking and description of the environment, which were further elaborated in the EA. The ToR also established Iamgold’s intention to develop a monitoring framework.

1.2 Environmental assessment

Once the ToR is approved by the Minister, the proponent can proceed to the second step of the EA process and carry out the EA. The EA must be prepared in accordance with the approved ToR and the requirements of the EAA. Once the proponent has carried out the EA, including consultation, the EA is submitted to the ministry for review and approval.

In addition to provincial EA requirements, the proposed Project was also subject to the federal Canadian Environmental Assessment Act, 2012. To fulfill the requirements of both provincial and federal EA processes, Iamgold prepared one EA report, which is known federally as an Environmental Impact Statement. The review of the EA was conducted in a coordinated manner amongst the federal and provincial governments. Approval from both the provincial Minister of the Environment and Climate Change and federal Minister of the Environment and Climate Change will be required for the undertaking to proceed.

On February 20, 2015, Iamgold submitted its EA titled "Final Environmental Assessment Report (Amended Environmental Impact Statement) Côté Gold Project". Iamgold is seeking approval for the proposed gold mine and associated facilities and infrastructure. The EA comment period ended on April 10, 2015.

The EA was circulated for review to a Government Review Team (GRT) which included the Ministries of Transportation; Tourism, Culture and Sport; and, Natural Resources and Forestry. The GRT, as well as federal, provincial and local agencies, reviewed the EA to ensure the information and conclusions of the EA were valid, based on their agencies’ mandates. The EA was also circulated to interested members of the public and potentially affected or interested Aboriginal communities for an opportunity to review and comment on the EA. All comments received by the ministry are considered by the Minister before a decision is made about the undertaking.

1.3 Ministry review

The EAA requires the ministry to prepare a review of the EA, known as the Ministry Review (Review). The Review is the ministry’s evaluation of the EA. The purpose of the Review is to determine if the EA has been prepared in accordance with the approved ToR and meets the requirements of the EAA, and whether the evaluation in the EA is sufficient to allow the Minister to make a decision about the proposed undertaking.

The Review outlines whether the information contained in the EA supports the recommendations and conclusions for the selection of the proposed undertaking. Ministry staff, with input from the GRT, evaluates the technical merits of the proposed undertaking, including the anticipated environmental effects and the proposed mitigation measures. The Review also provides an overview and analysis of the key public, agency and Aboriginal community comments on the EA and the proposed undertaking.

The Minister considers the conclusion of the Review when making a decision; however, the Review itself is not the EA decision-making mechanism. The Minister’s decision will be made following the end of the five-week Review comment period. The Minister’s decision is subject to the approval of the Lieutenant Governor in Council.

The Review comment period allows the GRT, the public and Aboriginal communities to see how their concerns with the EA and the proposed undertaking have been considered. During the Review comment period, anyone can submit comments on the EA, the undertaking and the Review. Additionally, anyone can request that the Minister refer the EA, or any matter relating to the EA, to the Ontario Environmental Review Tribunal for a hearing if they believe that there are significant outstanding environmental effects that the EA has not addressed. Requests for a hearing can only be made during this comment period. The Minister will consider all requests and determine if a hearing is necessary.

A Notice of Completion of the Review was published in the Sudbury Star, Timmins Daily Press, Timmins Times, and Sudbury le Voyageur indicating that this Review has been completed and is available for a five-week comment period from March 14, 2016 to April 29, 2016. Copies of the Review have been placed in the same public record locations where the EA was available and copies have been distributed to the GRT members and potentially affected or interested Aboriginal communities, including those who submitted comments. Members of the public who submitted comments during the EA comment period also received copies of the Review.

The proposed undertaking

Background

The Project is located in Chester and Neville Townships in the District of Sudbury, in Northeastern Ontario, approximately 20 kilometres (km) southwest of Gogama, 130 km southwest of Timmins, and 200 km northwest of Sudbury (Figure 1). The Project site and related facilities will be located on private, patented lands owned either fully or jointly by Iamgold.

Gogama is the nearest community to the Project site. Gogama is located on Highway 144, between Sudbury (to the south) and Timmins (to the north) and is located on Lake Minisinakwa, which is 22 km northeast from the Project site. According to the 2001 Census, Gogama has a population of 277.

Mineral exploration of the Project site has been conducted since 2009 by Trelawney Mining and Exploration Inc. (Trelawney) until Iamgold acquired the company in 2012. Trelawney had been exploring the property with the objective of developing an open pit gold mine and processing plant.

The proposed Project site comprises an area dominated by soil and till over bedrock in a relatively flat landscape. The area is mainly characterized by small hills, forests, lakes and rivers. The Project site is located on two main subwatersheds, the Mollie River system and the Mesomikenda River system. Additionally, the intercontinental watershed divide is located south of the Project site, with the nearest boundary located southwest and more than 3.5 km from the proposed open pit location.

There are no Areas of Natural and Scientific Interest, Provincially Significant Wetlands, Wildlife Concentration Areas or other provincially designated Natural Heritage Areas within the Project’s local study area. There are no National Parks, regional parks, or ecological reserves located in either the Project’s regional or local study areas. Three Provincial Parks are located within the regional study area: the Biscotasi Lake/Spanish River Provincial Park (approximately 13 km southwest of the Project site), Mississagi River Provincial Park (immediately south of the Project site) and La Motte Provincial Park (8 km northeast of Gogama). Biscotasi Lake has an associated Enhanced Management Area to the southwest. A conservation reserve (Akonesi Chain of Lakes Complex) is located just north of Gogama.

Six water wells are located within a 15 km radius of the Project site. Two of the wells are located on Iamgold property, one is indicated as a domestic well approximately 5 km northeast of the Project site and the remaining three wells are indicated as public supply wells between 8 and 11 km southeast of the Project site.

The area provides habitat for two species listed as Endangered or Threatened under the Endangered Species Act, including the Little Brown Myotis Bat and Eastern Whip-poor-will.

Description of proposed undertaking

The purpose of the undertaking is to construct, operate, close and eventually rehabilitate a new open pit gold mine to produce gold for market.

The Project site layout proposes to place the required mine-related facilities in close proximity to the gold deposit, to the extent practicable (Figure 2). Open pit mining operation is planned to occur at a rate of approximately 60,000 tonnes per day (over the lifespan of the mine). Overburden, mine rock and low grade ore stripped from the open pit would be stored in stockpiles near the open pit. Mining operations would be supported by development of an explosives manufacturing and storage facility.

For ore processing, Iamgold proposes to use an ore processing plant which will combine gravity separation and cyanidation for gold recovery, followed by in-plant cyanide recycling and destruction. Waste from ore processing, known as tailings, are to be stored in a constructed tailings management facility (TMF). Water for plant operations would consist of water recycled from the TMF, augmented by open pit dewatering, as well as runoff collected from the various stockpile areas, with a seasonal need for fresh water make-up (from Mesomikenda Lake). It is also proposed that excess treated water from the TMF site be discharged into the downstream end of Bagsverd Creek, which connects to Neville Lake, once all provincial and federal effluent discharge criteria is met.

As part of the proposed development of the open pit, Côté Lake (estimated volume of 463,000 cubic metres) will be drained and a total of 7.9 km of watercourse realignments are necessary. Portions of Three Duck Lakes, Chester Lake, Clam Lake and the Mollie River system will be dammed or require realignment to allow for the safe development and operation of the open pit. It is currently planned that Bagsverd Creek will also be realigned to allow development of the TMF.

The following will be developed on the Project site: maintenance garage, a fuel and lube facility, a warehouse, an administration complex, a construction and operations accommodations complex, an explosives manufacturing and storage facility, an aggregate plant and pit, fuel storage facilities, potable and process water treatment facilities and domestic and industrial solid waste handling facilities. These facilities would be supported by related on-site access roads, pipelines and power infrastructure.

Potable water will be extracted primarily from groundwater resources. Domestic sewage produced onsite is proposed to be treated using a package sewage treatment plant or equivalent. Nonhazardous solid wastes will likely be deposited in the existing nearby Ministry of Natural Resources and Forestry (MNRF) landfill. Hazardous solid and liquid waste would be hauled off site by licensed contractors to licensed storage facilities. Opportunities to recycle some of the hazardous waste, such as used oil, will be investigated by Iamgold.

Initial construction power will be provided by the existing transmission line connection to the Provincial electrical grid, supported by diesel power generator(s) (less than 5 megawatts required). Permanent power will be provided through a dedicated connection to a proposed new 230 kilovolt transmission line, originating from a substation located within the City of Timmins. The corridor is proposed to extend 120 km in length.

If EAA approval is granted, the Project will be completed in accordance with the terms and provisions outlined in the EA as well as proposed conditions of approval; and, will include the Project components outlined above. In addition, Iamgold must still obtain all other legislative approvals it may require for the undertaking.

Figure 1: Map showing the location of the Côté Gold Project in relation to nearby highways and municipalities.

Figure 2: Site map showing the layout of the Côté Gold Project and its facilities in relation to infrastructure and topographical features.

Results of the ministry review

The Review provides the analysis of the EA. The Review is not intended to summarize the EA, nor present the information found in the EA. For information on the decision making process, refer to the EA itself. The EA and supporting documentation outlines the EA planning process and demonstrates how the proponent has selected the preferred undertaking and made the final decision.

3.1 Conformance with ToR and EAA

3.1.1 Ministry analysis

The ministry coordinated an analysis of the EA with the GRT which, in part, looked at whether the requirements of the ToR have been met. The ministry has concluded the EA followed the framework outlined in the ToR. In addition the EA has satisfied the requirements of the EAA; however, ministry staff and Iamgold continue to engage on outstanding technical comments relating to surface water and groundwater.

Appendix A summarizes this analysis and identifies how the ToR requirements have been addressed in the EA.

3.1.2 Consultation

One of the key requirements of the EAA is pre-submission consultation completed during the preparation of the EA. This consultation is the responsibility of the proponent and must be taken prior to the submission of the EA and in accordance with the consultation plan outlined in the ToR. Once the EA is submitted to the ministry, additional ministry driven consultation occurs during the EA comment period. The GRT, the public and potentially affected and interested Aboriginal communities are provided with the opportunity to review the EA and to submit comments to the ministry on whether the requirements of the ToR have been met, on the EA itself and on the proposed undertaking. Iamgold may also continue consulting with stakeholders after submission of the EA in order to respond to any additional questions or issues.

A summary of the consultation that was conducted during the EA process is provided in the remainder of this Section below.

All comments received by the ministry during the EA comment period were forwarded to Iamgold for a response. A summary of key issues raised can be found in Sections 3.2.1 and 3.3.1 of this Review. All the comments received along with Iamgold’s responses and, where applicable, supplemental information are included in Appendix B. Iamgold also provided Errata to the EA, containing changes made to the original report based on comments received, along with an updated Commitments Registry, which was originally found in Appendix Y of the EA which has been updated based on comments received. The Errata and Commitments Registry are found in Appendix C and are considered part of the EA. The Errata and Commitments Registry contain important commitments and changes related to Project that, should the EA be approved, Iamgold will be required to fulfill; to emphasize this importance, the ministry may include a condition of EA approval to ensure the proponent makes the changes contained in the Errata and fulfills and reports on the commitments in the Registry.

The ministry is satisfied with the level of consultation undertaken by Iamgold and the documentation of consultation provided in the EA report and supporting documentation. The EA adequately describes the consultation that was undertaken and the outcomes of the various consultation activities. Iamgold’s consultation activities are described in Section 4 of the EA and in Appendix D (Record of Consultation).

Government review team

During the preparation of the EA, Iamgold sought input from members of the GRT including provincial ministries, federal departments and municipal agencies. This outreach was to identify: those regulatory and government agencies that may have a potential interest in or mandate related to the proposed undertaking; any approvals or permit requirements administered under their respective jurisdictional authorities; and, any potential concerns about the proposed undertaking.

Iamgold consulted the GRT through a variety of means including telephone calls, written and electronic correspondence and formal meetings. A summary of the consultation process carried out during the preparation of the EA with members of the GRT, the comments received and Iamgold’s responses to them can be found in Section 4 and Appendix Z of the EA.

A draft version of the EA was made available to the GRT for review during a 30-day comment period between June 13, 2014 and July 13, 2014. Following formal submission of the EA to the ministry, GRT members from various agencies were provided copies of the EA for their review during the seven-week comment period, which began February 20, 2015 and ended April 10, 2015. All comments received were forwarded by the ministry to Iamgold for a response. As well, comments received during the federal EA process were provided by the Canadian Environmental Assessment Agency (CEAA) to Iamgold for a response. Comments from the GRT, public and Aboriginal communities and Iamgold’s responses, along with supplemental information where applicable, can be found in Appendix B. A summary of key issues raised can also be found in Sections 3.2.1 and 3.3.1 of this Review.

Public consultation

Members of the public, which includes the general public, communities, local organizations, interest groups and property owners, were provided with several opportunities to participate and provide input during the preparation of the EA. Iamgold also established and maintained a contact list and carried out consultation with members of the public in a variety of ways, including: holding 13 public open houses; direct written correspondence; newspaper notifications of EA milestones and consultation opportunities; hosting site tours; and, posting information and materials to a Project website.

The objective of public consultation was to inform and seek input from interested members of the public on the EA process and the proposed undertaking. A detailed summary of the public consultation process carried out during the preparation of the EA, the comments received and Iamgold’s responses to them can be found in Chapter 4 and Appendix D of the EA.

A draft version of the EA was made available to the public for review and comments during a 30-day comment period between June 13, 2014 and July 13, 2014. Members of the public were also provided with an opportunity to review and comment on the EA during the seven-week inspection period that commenced with the formal submission of the EA on February 20, 2015. The inspection period was coordinated by the ministry and members of the public were asked to provide any comments directly to the ministry for consideration.

During the formal comment period on the EA, comments from two stakeholders were received by the ministry. As with the comments received from the GRT, the ministry forwarded all public comments to Iamgold for a response. The stakeholder comments received and Iamgold’s responses can be found in Appendix B.

Aboriginal community consultation

In addition to public consultation, the EAA requires that Aboriginal communities within the surrounding area of the proposed undertaking be consulted with during the pre-submission period. Aboriginal communities have special land and treaty rights that need to be considered.

During preparation of the EA, Iamgold sought advice from the federal and provincial governments to identify potentially affected Aboriginal communities. These communities were provided opportunities to participate throughout the EA process and were consulted and engaged to different degrees depending on the province’s preliminary assessment of the extent to which the Project could potentially impact their Aboriginal or treaty rights.

Iamgold focused its consultation efforts on those potentially affected and interested communities:

• Mattagami First Nation (represented by Wabun Tribal Council)
• Flying Post First Nation (represented by Wabun Tribal Council)
• Métis Nation of Ontario – Region 3
• Brunswick House First Nation
• Matachewan First Nation
• Beaverhouse First Nation
• Missanabie Cree First Nation
• Serpent River First Nation
• M’Chigeeng First Nation

In addition to the communities listed above, on March 23, 2015, the ministry sent Taykwa Tagamou Nation a letter, including a map of the Project site, informing the community of Iamgold’S EA for the proposed undertaking. The ministry made a decision to notify Taykwa Tagamou Nation of the Project as a result of receiving Taykwa Tagamou Nation’s Engagement Protocol, which included traditional maps that differed in the Crown’s previous understanding of the nature of their asserted or established Aboriginal and Treaty Rights. The proposed transmission line corridor from Timmins appears to transect the southernmost part of Taykwa Tagamou Nation’s new traditional map. Taykwa Tagamou Nation did not respond to the ministry’s letter or repeated calls and e-mails to confirm receipt of the letter.

The Aboriginal communities were consulted throughout the preparation of the EA, beginning at the ToR preparation, through a number of different methods. Consultation by Iamgold began during the expository stages before the commencement of the EA process through informal meetings and discussions, site tours, distribution of newsletters, and retaining a person to act as a liaison between Aboriginal communities and Iamgold. The proponent’s discussions with Aboriginal groups included topics such as: the incorporation of traditional land use and traditional knowledge into the EA; employment and training opportunities; fish and wildlife effects; environmental management; and, possible impacts to water resources.

Chapter 4 of the EA provides a summary of the Aboriginal consultation and Appendix D of the EA provides the detailed Record of Aboriginal consultation for the EA. Appendix B of this Review includes a document titled "Aboriginal Engagement in the Iamgold Côté Gold Environmental Assessment" from Iamgold in response to ministry comments that also provides consolidated information about Aboriginal engagement relating to Aboriginal peoples’ use of the land in and around the Project area, mitigation measures, including a number of commitments made to Aboriginal communities.

A number of Aboriginal communities accepted the opportunity to be part of the draft review of the EA, including: Wabun Tribal Council (representing Flying Post First Nation and Mattagami First Nation), Brunswick House First Nation, and the Métis Nation of Ontario. In response to comments raised in the review, the draft EA was amended prior to the submission of the final EA to the ministry.

Iamgold provided financial and technical support to the Métis Nation of Ontario and Wabun Tribal Council to ensure a traditional knowledge/traditional land use (TK/TLU) study would be included in the EA. Wabun Tribal Council’s TK/TLU was completed prior to Iamgold’s submission of the final EA to the ministry and its finding were included in the EA report. The Métis Nation of Ontario’s TK/TLU was submitted to Iamgold and the ministry during the final EA comment period and therefore, its findings were not included in the EA report.

Wabun Tribal Council TK/TLU provided traditional knowledge and land use information including maps of sensitive areas in the region that are popular for the exercise of traditional land and resources uses. The TK/TLU also described a number of traditional land uses in and around the mine site, including: fishing, trapping; plant harvesting; hunting; and netting (e.g. blueberry patches); a waterfowl hunting route; a waterfowl hunting site; a travel route; and, a traditional canoe route.

The Métis Nation of Ontario’s TK/TLU study states that the Project is within their identified traditional harvesting territory. The Métis Nation of Ontario also identified that, historically and currently, traditional land and resource uses occur throughout the local and regional study areas of the Project. Important traditional land and resources include: hunting; trapping; fishing; harvesting edible and medicinal plants; cultural sites; and, interests’ incidental to these uses such as land and seasonal cabins. The Métis Nation of Ontario also identified recreational activities such as cottages and several natural resource-based commercial activities that may occur within or beyond the Project’s regional study area.

During the seven-week inspection period on the final EA, the Métis Nation of Ontario and Wabun Tribal Council independently provided comments on the proposed undertaking to the ministry. These comments were sent to Iamgold for a response. These comments and Iamgold’s responses can be found in Appendix B of this document.

Upon the request of Wabun Tribal Council, staff from this ministry and Canadian Environmental Assessment Agency met with Wabun Tribal Council and their consultants in June 2015 to discuss the Project, and their concerns with the EA. Their concerns included: inadequate baseline data; lack of confidence in prediction of effects; impacts on Treaty and Aboriginal rights; future monitoring plans; no start date for Project construction; and, EA conditions of approval not being shared with First Nations.

In August 2015, staff from the province and CEAA met with Métis Nation of Ontario, their consultants and legal counsel to discuss its concerns with Iamgold’s EA and the Project. Métis Nation of Ontario raised concerns about the findings of its TK/TLU study not being considered in the EA, impacts to access on quality sites and impacts to traditional plants and wildlife species. Métis Nation of Ontario also expressed concerns with impacts on Treaty and Aboriginal rights and no start date for Project construction.

Iamgold did respond to the concerns raised by Wabun Tribal Council and Métis Nation of Ontario in their submissions to the ministry on the EA. Iamgold responses, which can be found in Appendix B, demonstrates in detail how during the EA, the proponent considered and assessed impacts on Treaty and Aboriginal rights and how the proposed mitigation measures will avoid or minimize potential impacts.

Aside from outstanding technical comments relating to surface water and groundwater concerns, the ministry is satisfied that the EA and the additional supporting documentation had sufficient baseline data to satisfactorily predict Project effects and the mitigation of those effects on the environment.

Iamgold made a commitment that should additional information become available that was not already assessed in the EA, Iamgold will review and consider the potential effects and develop and implement necessary mitigation measures, as appropriate, and consult with the Aboriginal communities.

Iamgold has also made a number of commitments to work with Aboriginal communities on mitigation and monitoring of socio-economic, environmental effects, and potential effects relating to impacts on Treaty and Aboriginal rights. Please see the Commitments Registry in Appendix C of this Review for all commitments made by Iamgold during the EA, as result of comments received from Wabun Tribal Council, Métis Nation of Ontario and other Aboriginal communities.

On September 4, 2015, the ministry formally responded to Wabun Tribal Council’s specific concern about the ministry not sharing draft conditions of approval with First Nation communities. The letter stated that conditions proposed by ministry staff are recommendations for the Minister’s consideration only and may not necessarily be included in the Notice of Approval. This Review, however, does speak to proposed conditions of approval that are being considered. The Review comment period provides Wabun Tribal Council and other Aboriginal communities to provide input on what ministry staff are contemplating on bringing forward to the Minister as proposed conditions for the EA.

On February 7, 2016, MOECC received a letter from Métis Nation of Ontario stating that all land uses and associated project effects identified in their TK/TLU study together with the concerns identified in their correspondence to the ministry have been adequately considered and addressed by Iamgold. Métis Nation of Ontario is supportive of a positive EA decision by our ministry.

Although Métis Nation of Ontario have confirmed their support for the EA, Section 3.3.1 still summarizes key concerns that include concerns raised by Métis Nation of Ontario, as some of their concerns were also shared by Wabun Tribal Council and the ministry. For all comments from Wabun Tribal Council and Métis Nation of Ontario, including Iamgold responses, please see Appendix B.

Ministry conclusions on the consultation program

Overall, the ministry is satisfied that Iamgold appropriately carried out the consultation plan that was outlined in the approved ToR. The ministry believes that the level of consultation undertaken by Iamgold with the public, Aboriginal communities and government agencies was done in accordance with Section 5.1 of the EAA; the directions and advice contained within the ministry of the Environment and Climate Change’s “Code of Practice: Consultation in Ontario’s Environmental Assessment Process,” and the consultation commitments made in the approved Côté Gold Project ToR.

The EA documents the consultation methods that were undertaken by Iamgold to engage government reviewers, Aboriginal communities and members of the public during the development of the EA. The EA discusses the concerns raised and how they were addressed or will be addressed if the EA is approved.

Should the EA be approved, Iamgold has committed to continued consultation with interested members of the public, government agencies and Aboriginal groups.

3.1.3 Conclusion

The ministry is satisfied that consultation carried out meets the requirements of the EAA and is in accordance with the approved ToR.

3.2 EA process

EA is a planning process that requires a proponent to identify an existing problem or opportunity, consider alternative ways of addressing the problem or opportunity, evaluate the environmental effects of those alternatives against select criteria and then select a preferred alternative. In general, Iamgold followed a logical and transparent decision making process which was outlined in the EA. Below is a summary of Iamgold’s methodology, including the study areas used and the methodology for assessing alternatives and environmental effects. Refer to Appendix A of this Review for the ministry’s analysis of how the EA met the requirements of the EAA and the approved ToR.

The EA process was initiated by Iamgold on May 19, 2014 with the publication of a Notice of Commencement of an EA for a proposed open pit gold mine with related processing facilities and infrastructure. Pursuant to the ToR, the purpose of the EA process was to complete a comparative analysis of ‘alternatives to’ the Project itself as well as ‘alternative methods’ of carrying out the Project. The EA process also involved identifying the potential environmental effects, both positive and negative, and their projected level of significance after applying mitigation measures.

Alternatives assessment

In accordance with the Côté Gold Project ToR and as found in Chapter 7 and Appendix U of the EA, Iamgold assessed both alternatives to and alternative methods. Iamgold conducted a high level comparison of three alternatives to the undertaking, including constructing the Project in the near term, delaying the Project until circumstances are more favourable, and abandoning the Project. The alternatives were screened using a number of criteria related to the natural environment: land use and resource management; social, cultural and economic considerations; and, Aboriginal uses. Iamgold’s analysis concluded that not proceeding until economic conditions and financing are favourable is the preferred alternative since it would best meet the intended Project purpose. Abandoning the Project was argued to produce fewer positive effects, particularly economic effects, compared to proceeding with the Project as planned.

Following the selection of the preferred alternative to, Iamgold compared alternative methods for developing various components of the Project, with typically three to four alternative methods assessed per component. The advantages and disadvantages of each alternative method were assessed using a methodology of performance objectives, criteria and indicators. The following six performance objectives were used: cost-effectiveness; technical applicability and/or system integrity and reliability; ability to service the site effectively; effects to the physical and biological environments; effects to the human environment, including Aboriginal and treaty rights, cultural heritage resources (including archaeological, built heritage and cultural heritage landscape resources) and traditional land use; and, amenability to reclamation.

Iamgold developed criteria for each of the six performance objectives. For example, the effects to the physical and biologic environments objective contained criteria such as effects on air quality and climate and effects on fish and aquatic habitat, among others. Each criterion then had one or more indicators. For instance, the air quality criteria included attainment or maintenance of air quality point of impingement standards, or scientifically defensible alternatives and emission rates of greenhouse gases. For each indicator, advantages and disadvantages were presented. This methodology was used to assess the advantages and disadvantages of each alternative method and select the preferred alternative methods for each mining component.

The alternatives assessment identified preferred methods and locations for mining, mine water management, mine rock and overburden management, ore processing plant, process effluent treatment, tailings management facility, water supply, water discharge, watercourse realignments, site infrastructure positioning, aggregate supply, solid waste management and domestic sewage treatment, power supply and routing and mine closure.

Evaluation of environmental effects

The evaluation of potential environmental effects that the Project may cause, assuming the Project is implemented, were assessed in Chapters 9, 10 and 11 of the EA. In accordance with the ToR, the methodology for the effects evaluation involved using a number of important physical, biological and human environment components to be studied, referred to in the EA as effects assessment indicators. The EA then selected study areas to describe the geographic extent of the potential environmental effects, provided predictions of potential impacts to those effects assessment indicators, identified mitigation measures to minimize or avoid those impacts, and concluded an evaluation of the significance of the residual impacts post-mitigation.

The effects assessment indicators were identified based on their particular ecological, scientific, resource, socio-economic, cultural, health, aesthetic or spiritual importance, and their potential to be adversely affected by the Project. The assessment captured the full breadth of the environment and included representative components of: air; noise; surface water and groundwater; vegetation and rare plants; wildlife (including ungulates, birds, amphibians and fish); species at risk; species of concern; socio-economic activities (including forestry, hunting and trapping, fishing, and recreation and agriculture); transportation; human health; demographics; and, cultural heritage resources.

For each effects assessment indicator, the EA identified potential effects the Project may cause and whether each effect would cause negative or positive impacts. Possible mitigation measures were proposed for each effects assessment indicator. The residual (post mitigation) negative effect was then identified in terms of how the effect was expected to be minimized or avoided.

Residual effects were described according to five assessment criteria: magnitude, geographic extent, duration, frequency and reversibility. A qualitative rating from level I to level III was assigned for each residual adverse effect. A level I rating refers to a negligible or limited potential to contribute to an overall significant effect. A level III rating is indicative of a high potential to contribute to an overall significant environmental effect, post-mitigation. Level II represents an intermediate condition. A decision tree was developed to visually display the level of significance (i.e., significant or not significant) for each combination of the five assessment criteria.

The EA concluded that the Project will not result in significant negative effects after the application of mitigation measures, such as emissions controls, treatment systems, compensations for impacts, equipment selection, and facility design. However, the Ministry will continue to assess the proposed mitigation measures in light of the fact that ministry staff and Iamgold continue to work on addressing outstanding comments relating to surface water and groundwater.

3.2.1 Key issues

Key issues regarding the EA process completed by Iamgold for the Cote Gold Project were gathered during the pre-submission consultation and the EA review comment period. These submissions and Iamgold responses can be found in Appendix B.

Through the review of the final EA, staff from the ministry determined whether or not Iamgold followed the EA process, and have incorporated the commitments in the approved ToR into the final EA that was submitted for review and a decision. No significant GRT, public or Aboriginal comments were received on the final EA regarding the EA process. Ministry staff has concluded that there are no issues with the Iamgold’s EA planning process for the proposed Project.

3.2.2 Conclusion

Overall, the ministry, in consultation with the GRT, is satisfied with the proponent’s decision making process. The ministry believes that Iamgold has conducted the EA in a logical and transparent manner, and has made a clear effort to consult and involve interested stakeholders and Aboriginal communities in the EA process.

The EA explains the rationale behind the Project and the need for the EA process. Iamgold has presented a reasonable range of alternative methods to the undertaking and has evaluated them in a defined study area that took into consideration the EAA’s broad definition of the environment.

The EA provides a description of the potentially affected environment in the study area and identifies potential effects that may result from the undertaking that may impact the environment. The EA discusses the likelihood and significance of these impacts as well as possible mitigation measures to accordingly reduce or increase their effect, depending on whether the effect is negative or positive.

The ministry is satisfied that the EA was completed in accordance with the approved ToR and meets the general legislative requirements of the EAA.

3.3 Proposed undertaking

The proposed undertaking is described in Chapter 5 of the EA (see also Section 2 of this Review) and was evaluated based on the anticipated net impacts of each alternative and the advantages and disadvantages to the environment. A broad definition of the environment was used to evaluate the potential effects of the proposed undertaking. The proposed undertaking is to construct, operate and eventual rehabilitation of an open pit gold mine to produce approximately 60,000 tonnes per day of ore production over a period of 15 years.

3.3.1 Key issues

Key issues regarding the EA Report and the proposed undertaking were gathered during the consultation and the EA review comment period. Key comments submitted by GRT, and Aboriginal communities are summarized below. All comments and Iamgold’s responses, including additional information the proponent submitted to support responses, can be found in Appendix B. Key comments and concerns are outlined below.

In response to the comments received during the pre-submission consultation and the EA review, Iamgold provided an Errata and Commitments Registry, in part, to address concerns that have been raised. The Errata and Commitments Registry are included in Appendix C of this Review.

Pipeline connection and alignment

MNRF commented on the EA not having specific details about the pipeline connection and alignment from the TMF to the discharge location (approximately 3 to 4 km). This information was requested to understand the potential environmental impacts on fish, vegetation and wildlife and to ensure that appropriate mitigation measures are in place.

Iamgold explained that the design details of the Project with respect to the pipeline alignment and connection was not advanced enough that would allow this level of detail in the EA report. Iamgold has committed to engage MNRF during the detailed planning phase of the Project for the discharging pipe alignment.

The ministry may consider a condition of approval to require Iamgold to prepare a report, prior to obtaining legislative approvals or prior to construction that will describe the pipeline alignment from the TMF to the effluent discharge location.

Transmission line crossing at Mesomikenda Lake

MNRF staff commented on the EA not having specific details about the transmission line crossing at Mesomikenda Lake. Concern is that the lack of specific details of the crossing, social and environmental impacts (e.g. public access, visual, aviation, natural resources) cannot be appropriately assessed in the EA. MNRF also expressed concern with the location selected for the crossing of the transmission line and recommended that Iamgold consider crossing the transmission line further south. MNRF believes that this would result in reduced environmental impacts because the crossing across the lake further south is shorter and there is a pre-existing transmission line crossing.

Iamgold responded by stating that it will comply with all relevant legislative requirements for the proposed transmission line crossing and is open to consider minor optimizations. Iamgold also stated that it will provide MNRF details on all water crossings, as required during the permitting phase of the Project.

The ministry may consider a condition of approval that will require Iamgold to engage MNRF in determining the final location regarding the transmission line crossing at Mesomikenda Lake prior to construction.

Surface water

Ministry staff commented that there is insufficient information presented in the EA for the ministry to evaluate the magnitude and spatial extent of aquatic environmental effects from the effluent discharge. The information in the EA does not clearly demonstrate that the preferred alternative for effluent discharge location/design and the level of effluent treatment (i.e. proposed maximum concentration limits) would minimize the mixing zone size and result in the least potential for adverse aquatic effects, including toxicity. This information is necessary to understand the effects that will or may be caused to the environment and to show that the discharge of mine effluent will be consistent with Ontario’s water management policies and water quality objectives.

From February 2015 to December 2015, Iamgold made several attempts to address ministry concerns by submitting supporting documentation regarding surface water; however, the responses to date have not provided sufficient information. The additional information requests by the ministry is required to better understand the potential aquatic environmental effects that may result from effluent discharge. This information will offer certainty that proposed mitigation measures in the EA and supporting documentation are designed to appropriately address effluent discharge impacts.

Iamgold has agreed to continue to engage with the ministry on technical matters relevant to the EA with respect to the surface water comments, which may include, prior to EA approval, the submission of additional supporting information. For a complete record and detailed responses of the ministry surface water comments and Iamgold responses, including additional supporting information, please see Appendix B.

Groundwater

Ministry staff commented on the potential for acid generation as a result of the Project. Specifically, the EA did not provide details of a comprehensive monitoring program that would identify potential acid-generation (PAG) material prior to deposition.

Iamgold responded by stating that the modelling undertaken for the Project showed that a small percentage of PAG rock is well distributed throughout the volume of the waste rock, which is composed predominantly of high neutralization potential, non-PAG rock. Ministry staff recognized that while predictions made during the EA may prove to be accurate regarding PAG material distribution and PAG material handling, procedures must be in place to confirm predictions, ensure PAG material is mixed sufficiently to mitigate acid rock drainage/metal leaching conditions and describe what actions will be taken in the event that conditions are not anticipated.

While the ministry recommended that a detailed waste rock contingency plan be required, Iamgold is of the opinion that an adaptive management approach is more appropriate and practicable. The ministry concurred that the intentions of the recommended contingency plan could be captured in an adaptive management plan.

Ministry staff is proposing a condition that will require Iamgold to develop and provide details of a waste rock adaptive management approach with trigger mechanisms based on geological inspections, seepage monitoring, groundwater monitoring and geochemical monitoring that will be place in the event that predictions regarding PAG material distribution and/or potential for acid rock drainage/metal leaching conditions are more severe than expected.

Ministry staff raised concerns about no sensitivity analysis being completed on the 3D hydrogeological model for the open pit and mine rock area. This information will help to show the appropriateness of the conceptual groundwater model and the numerical model construction, and provide bounds for seepage volumes into the open pit.

Iamgold did provide additional sensitivity analysis; however, the additional information did not help to define more conclusive model realizations of an upper bound of what could reasonably be expected or a worst case scenario. Therefore, the ministry is proposing a condition that a more robust hydrogeological model sensitivity analysis be required in applications associated with the provincial permits.

Ministry staff commented on the EA not including the first 20 weeks of humidity cell test (HCT) data not being incorporated in the water quality predictions. The concern is associated with capturing the total potential effect of the material being tested. Iamgold did respond in December 2015 stating that the inclusion of the first 20 weeks of HCT into the water quality assessment would not be representative of the weathering rates expected from the Project mine rock. HCTs were ongoing at the time of submission of the final EA, but monitoring during weeks 20 through 34 demonstrated that the release rates continued to decline or stabilized over time. Therefore, Iamgold states that the release rates utilized in the EA are sufficient and revision of these rates is not required.

Ministry staff cannot confirm, at this time, whether Iamgold’s method is conservative and is requesting updated field cell and HCT results and additional water quality model simulations with associated results and analysis be provided.

Iamgold has agreed to continue to engage with the ministry on technical matters relevant to the EA with respect to the groundwater comments summarized above. For a complete record and detailed responses of the ministry groundwater comments and Iamgold responses, including additional supporting information, please see Appendix B.

No start date for project construction

Both Wabun Tribal Council and Métis Nation of Ontario expressed concerns with the EA report not having clear start dates for Project construction. Given this uncertainty with the anticipated timelines for Project construction, there is a greater potential for substantial variation in the EA’s baseline conditions used to predict environmental and socio-economic impacts. Wabun Tribal Council and Métis Nation of Ontario are concerned that the environmental and socio-economic conditions surrounding the Project could change and it is possible that the EA did not account for these changes. Such changes could include new environmental effects (e.g. new habitat developed), new alternatives that need to be considered (e.g. preferred corridors could have been impeded and new ones must be identified), or new consultation requirements (e.g. newly developed infrastructure projects in proximity).

Iamgold has committed to continue to monitor various aspects of the environment between EA completion and start of Project construction. This information will be used to support future legislative processes and future monitoring plans. Iamgold also committed to continue working with Wabun Tribal Council, Métis Nation of Ontario and other potentially affected Aboriginal communities on socio-economic conditions related to the Project.

The ministry recognizes Wabun Tribal Council and Métis Nation of Ontario’s concern about the predictions of Project effects on the environment, as described currently in the EA, may vary should there be a considerable lapse of time between EA approval and Project implementation. To address this concern, the ministry may consider a condition of approval to require Iamgold to notify the ministry prior to Project implementation and document changes, if any, that have occurred and that could affect how the Project is described in the EA. The notification would help to determine if additional EA work may be required prior to Project implementation. The ministry may also include an expiration date for the EA approval to ensure that the Project is built within a reasonable timeframe.

Aboriginal peoples’ use and traditional rights

Ministry staff requested clarification from Iamgold on how the EA report and its supporting documentation (i.e. TK/TLU studies) was used to determine Project impacts on traditional use and Aboriginal and/or Treaty Rights. In response, Iamgold provided additional information and referred to specific sections of the EA report and supporting documents for how it considered Project impacts on Aboriginal peoples. However, a ministry staff review of Iamgold responses resulted in further questions about the need for clearer documentation in order for Aboriginal communities to understand how the Project will impact their use and rights. Transparent and clear documentation would enable Aboriginal peoples to have meaningful input on the proposed undertaking and the EA report.

In order to achieve this, ministry staff requested a standalone document that would describe Iamgold’s analysis of how Aboriginal traditional uses of the land and/or Treaty Rights were considered in the EA. Ministry staff requested that this document analyze all pieces of information to determine use and potential impacts on Aboriginal rights by drawing linkages between the EA report and its appendices. Ministry staff also requested that the document demonstrate how the TK/TLU prepared by both Wabun Tribal Council and Métis Nation of Ontario were considered in determining use and impact.

In December 2015, in response to ministry comments above, Iamgold submitted a document entitled "Aboriginal Engagement in the Iamgold Côté Gold Environmental Assessment" aimed at better describing impacts on Aboriginal peoples’ use of land in and around the Project site area. This document better described the assessment of Project impacts and described the mitigation measures for potential effects to Aboriginal communities’ ability to exercise their Aboriginal and/or Treaty Rights.

Ministry staff review of the document demonstrated that it was effective in better describing how the Project would impact traditional use and Aboriginal and/or Treaty rights (e.g. maps overlaid with proposed Project footprint, Project study areas and TK/TLU study areas). The document also included mitigation measures and commitments by Iamgold to continue engagement with Aboriginal communities for specific concerns relating to watercourse realignments and draining of Côté Lake, traditional knowledge and land use, and commitments to engage and consult Aboriginal communities on monitoring plans. It is the ministry’s understanding that commitments made by Iamgold to address potential impacts have been shared with Wabun Tribal Council and the Métis Nation of Ontario. All commitments made in the EA and during the EA process can be found in Appendix C of this report.

The "Aboriginal Engagement in the Iamgold Côté Gold Environmental Assessment" document can be found in Appendix B of this Review and is included as supporting documentation to the EA.

Current use of lands and resources for traditional purposes

Wabun Tribal Council expressed concern that Iamgold’s effects analysis for current use of lands and resources for traditional purposes was overgeneralized, as it did not consider the new portion of the transmission line alignment and its potential impacts on habitat fragmentation and access increases. Wabun Tribal Council also expressed concern that Iamgold’s analysis does not provide support that impacts to lands and resources can be remediated to support the EA conclusions.

The Métis Nation of Ontario also expressed concern about potential impacts to current use of lands and resources for traditional purposes and concern that the EA did not consider their TK/TLU report findings. Additionally, the Métis Nation of Ontario expressed concern regarding the direct loss of and restriction of access to quality sites, and impacts on traditional plants and wildlife species.

Iamgold stated that the effects analysis presented in the EA adequately considered available information on current use of lands and resources for traditional purposes. The EA does acknowledge that the proposed transmission line corridor will result in habitat fragmentation; however, Iamgold has committed to monitor the success of re-vegetation plans during the decommission stage of the Project. Iamgold responded, upon review of the Métis Nation of Ontario TK/TLU report that the EA analysis does not predict significant negative effects on Métis’ current use of lands and resources that cannot be appropriately mitigated.

Aside from outstanding technical comments relating to surface water and groundwater concerns, the ministry is satisfied that the EA and the additional supporting documentation had sufficient baseline data to satisfactorily predict Project effects and the mitigation of those effects on the environment.

Iamgold has committed to continue to engage Aboriginal communities on the development of monitoring programs that meets their needs and priorities with respect to concerns with Project impacts on the natural environment, such as, concerns relating to watercourse realignments, draining of Côté Lake, and impacts on use of lands, and impacts on resources for traditional purposes throughout the Project life-cycle.

The Métis Nation of Ontario has confirmed to the ministry that the concerns summarized above have been adequately considered and addressed by Iamgold and is now supportive of a positive EA decision.

The ministry is considering a condition of approval to require Iamgold to meet all commitments contained in Iamgold’s updated Commitments Table in Appendix C of this Review.

Federal agencies

During the review of this EA, the Canadian Environmental Assessment Agency (CEAA) also requested information from Iamgold regarding their review of the Iamgold’s Amended Environmental Impact Statement report. CEAA’s information requests to Iamgold covered a range of issues, some of which were shared by the GRT, which included: air quality; groundwater and surface water; aquatic habitats; migratory birds; terrestrial landscapes; and, Aboriginal treaty rights and traditional land uses. For more information about the CEAA’s information requests and the federal EA process for this Project, please refer to the CEAA website on the Project.

3.3.2 Conclusion

Iamgold has provided responses to all comments received, including those not detailed above. All comments and Iamgold’s responses are located in Appendix B of this Review.

Ministry staff are satisfied that Iamgold has met the requirements of the ToR. and EAA for the components of the EA raised in Section 3.3.1 above, as well as those raised in Appendix B.

As a result of the comments received, Iamgold has made a number of commitments, including committing to respond to Ministry concerns, any future comments that may arise, or through future approval applications to address any outstanding concerns with the proposed undertaking. Iamgold’s updated Commitments Registry Table and Errata to the EA can be found in Appendix C of this Review.

The ministry will continue to work with Iamgold on resolving technical comments relating to surface water and groundwater to ensure the project will be designed and operated to comply with the ministry’s standards and that the environmental effects of the proposed undertaking can be managed through the commitments made in the EA, through conditions of approval, or through additional work that must be carried out by Iamgold in support of future approval and permit applications, if the EA is approved.

During the final review period and prior to forwarding a recommendation to the Minister about this EA, conditions specific to the undertaking may be proposed to ensure the environment remains protected. Aside from standard EA conditions, below is a preliminary list of potential conditions that may be recommended to further support the commitments made in the EA and the purpose of the EA.

Project-specific conditions:

1. Post final EA incorporating changes cited in the Errata on Iamgold’s website.
2. Meet all commitments contained in Iamgold’s updated Commitments Table in Appendix C of this Review.
3. Iamgold will prepare a report for MNRF review, prior to obtaining approvals that describes the pipeline alignment from the TMF to the effluent discharge location including water crossing information.
4. Iamgold will engage MNRF in determining the final location of the transmission line crossing at Mesomikenda Lake.
5. Prior to Project construction, Iamgold shall prepare and submit a waste rock adaptive management approach that outlines Iamgold’s strategy to ensure that waste material defined as PAG, based on geochemical monitoring, will ultimately be randomly distributed in the waste rock area during construction, operations and closure phases.
6. A more robust hydrogeological model sensitivity analysis will be required in applications for associated provincial permits that will look at hydraulic conductivity for each model layer separately and across a wider range of values that will be more representative of field test results.
7. During the provincial permitting phase and to the satisfaction of the ministry, Iamgold will collect additional geological and hydrogeological field data and carry out improved modelling to adequately characterize seepage pathways from the TMF and develop more robust mitigation measures, a visual inspection program, a seepage monitoring program, a groundwater monitoring program, and a TMF seepage contingency plan including trigger mechanisms.
8. Updated field cell tests and HCT results shall be provided in support of applications for associated provincial permits and/or in the closure plan submission, including a discussion of the applicability of the HCT results. HCT results shall be used to develop additional loading rate estimates including a realistic upper bound of what could be expected and a worst case scenario, with these estimates used to provide additional water quality model simulations and associated analyses.
9. Iamgold shall notify the ministry prior to Project implementation and document changes, if any, that have occurred and that could affect how the Project is described in the EA. The notification would help to determine if additional EA work may be required prior to Project implementation.
10. An expiration date for the EA approval to ensure that the Project is built within a reasonable timeframe.

Summary of the ministry review

The Review has explained the ministry’s analysis of Iamgold’s EA for the construction, operation, and eventual rehabilitation of the Project.

The Review concludes that the EA was prepared in accordance with the approved Terms of Reference. Iamgold has provided adequate information in the EA, together with additional supporting documentation that assesses potential environmental effects of the proposed undertaking. However, ministry staff and Iamgold continue to engage on EA technical comments specific to surface water and groundwater. Ongoing discussions to resolve technical matters, together with proposed conditions of approval and proponent commitments should ensure that the environment remains protected as a result of the Project.

The Review concludes that the EA has assessed and evaluated alternative methods to arrive at the preferred undertaking, assessed the potential environmental effects of the alternative methods and the proposed undertaking, and provides a description of mitigation and monitoring measures to address the potential negative environmental effects of the proposed undertaking.

The ministry is satisfied that Iamgold provided sufficient opportunities for the GRT, stakeholders and Aboriginal communities to comment during the development of the EA. Concerns raised by the GRT, Aboriginal communities and stakeholders have been addressed by Iamgold or a commitment has been made to continue to addressing them during the EA process or through additional work that will be completed as part of EA approval and future approval processes.

To ensure the environment remains protected, during the final review period and prior to forwarding a recommendation to the Minister about this EA, the ministry may consider conditions of approval specific to consultation, commitments during Project design, completion of the environmental management plan, or finalization of the monitoring and contingency planning for the proposed undertaking.

What happens now?

The Review will be made available for a five-week comment period. During this time, all interested parties, including the public, the GRT and Aboriginal communities can submit comments to the ministry about the proposed undertaking, the EA and/or the ministry Review. At this time, anyone may request that the Minister refer either all or part of the EA to the Environmental Review Tribunal for a hearing if they believe that their concerns have not been sufficiently addressed.

At the end of the Review comment period, ministry staff will make a recommendation to the Minister concerning whether the EA has been prepared in accordance with the ToR and the requirements of the EAA and whether the proposed undertaking should be approved. When making a decision, the Minister will consider the purpose of the EAA, the ToR, the EA, the Review, the comments submitted during the EA and the Review comment periods and any other matters the Minister may consider relevant.

The Minister will make one of the following decisions:

• Give approval to proceed with the undertaking
• Give approval to proceed with the undertaking subject to conditions
• Refuse to give approval to proceed with the undertaking

Prior to making that decision, the Minister may also refer either part of or the entire EA to mediation or refer either part of or the entire EA to the Environmental Review Tribunal for a decision.

If the Minister approves, approves with conditions or refuses to give approval to the undertaking, the Lieutenant Governor in Council must concur with the decision.

5.1 Additional approvals required

If EAA approval is granted, Iamgold will require other legislative approvals to design, construct and operate this undertaking. Chapter 2 of the EA outlines additional provincial and federal approvals that may be required. These provincial approvals may include:

• Permits to Take Water (under the Ontario Water Resources Act) for taking of water greater than 50,000 litres per day
• Environmental Compliance Approvals (under the Environmental Protection Act) for the construction and operation of treatment facilities and associated releases to the environment
• Various Work Permits for Construction (under the Lakes & Rivers Improvement Act/Public Lands Act) for various work/construction on Crown land
• Lakes and Rivers Improvement Act Permit (Lakes and Rivers Improvement Act) for the construction of a dam
• Forest Resource Licence (Cutting Permit) (under the Crown Forest Sustainability Act) for clearing of Crown merchantable timber
• Aggregate Permit (Aggregate Resource Act)
• Land Use Permit (under the Public Lands Act)
• Endangered Species Permit (under the Endangered Species Act) for management of activities related to SAR
• Leave to Construct (under the Ontario Energy Board Act) for the construction of a transmission line
• Clearance Letter (Heritage Act) to confirm that appropriate archaeological studies and mitigation, if required, have been completed for the Project
• Highway Encroachment/Entrance (Public Transportation and Highway Improvement Act) for the construction of a transmission line or access road within provincial highway right of way
• Closure Plan (under the Mining Act) for mine construction/production and eventual decommissioning at mine closure, including financial assurance

These approvals cannot be issued until approval under the EAA is granted.

The Project may also require the following federal approvals:

• Approval by Fisheries and Oceans Canada under subsection 35(2) b. of the Fisheries Act for undertaking an activity that results in serious harm to fish that are part of a commercial, recreational or Aboriginal fishery, or to fish that support such fishery
• Approval from Environment Canada, with support from Fisheries and Oceans Canada under regulatory amendment to Schedule 2 of the Metal Mining Effluent Regulations, related to the placement of deleterious waste rock or tailings in fish-frequented water bodies
• The ‘opt-in’ provision for approval of work in a non-scheduled waterway found in Section 4 (1) of the Navigation Protection Act
• License for an explosives factory (under the Explosives Act) to operate an on-site facility for the purpose of supplying explosives for use in open pit operations
• Aeronautical obstruction clearance required by Transport Canada for marking and lighting of structures that could interfere with aeronautical navigation
• Land-use clearance required by Nav Canada for the construction of tall structures, use of cranes, high-voltage equipment and blasting

5.2 Modifying or amending the proposed undertaking

The EA Code of Practice identifies a process to address minor and major changes to the undertaking if approval is granted. Any proposed change to the undertaking would have to be considered in the context of the EAA and any environmental assessment requirements met before any change to the undertaking can be implemented.

Appendices

Appendix A: Environmental Assessment Act requirements

Appendix B: Submissions received during initial comment period, proponent responses and supplemental information

Contents are available in hard copy at the public record locations listed in this Review.

Appendix C: Errata and commitments table

Contents are available in hard copy at the public record locations listed in this Review.