Environmental Assessment Office

Collected Public Comments for Kemess Underground Project

January 11, 2017 to February 10, 2017

Comments will be available on this page until February 24, 2017 and after this date all posted comments will be available through the EAO electronic Project Information Centre (ePIC) application.

February 10, 2017

Christopher Gall - Vancouver, British Columbia

submission from Metis BC Nationsubmission from Metis BC Nation

Gavin C. Dirom - Vancouver, British Columbia

On behalf of the Association for Mineral Exploration (AME), I wish to extend our support for AuRico Metals Inc.'s proposed Kemess Underground Mine Project (or the "Project") located in north central British Columbia. Through construction, production to closure, the Kemess Underground Mine Project has the potential to provide important regional and provincial economic benefits to the citizens of British Columbia for at least 13 years. And like many mines, the mine life may be extended if more ore is discovered.

The proposed mine represents a capital cost of $603 million over the five-year construction and commissioning period, and will utilize existing, dormant infrastructure from previous, nearby mining operations. Employment will peak at almost 600 employees during the construction phase of the mine. During the operations phase of mining, the mine will employ an estimated 400 in mining activities, with at least another 100 employed in administration and support activities. And as was the case in the previous mining operations at Kemess South, it is anticipated that 40% of all mine employees will be from local communities in northern BC.

The Kemess Underground Mine Project is expected to generate over $230 million in tax revenues through all phases of development and mining, including provincial and federal corporate taxes and the BC Mineral Tax. This tax revenue helps pay for health care, education and other critical services that support a higher standard of living in British Columbia for everyone.

Following the initial mineral discovery, the best indicator of success for both mineral explorers is the construction and development of new mines. In the modern world, AME believes that sound environmental assessment and reasonable mitigation of impacts supports the responsible development of society's mineral resources. Mineral explorers and developers in BC understand there will always be some impacts when developing such rare and valuable mineral deposits into safe, productive mines and that these need to be reviewed and considered appropriately.

We believe that AuRico Metals has carefully considered the environmental and social impacts and designed a Project with significant input from First Nations and communities that will create enhanced benefits for all with minimal risk and impact to other identified and important values. For example, AuRico Metals will use existing disturbance to further reduce the environmental footprint of the Kemess Underground Mine Project.

We are hopeful that with your favourable decision to enable the Kemess Underground Mine Project to proceed, the provincial and federal governments will continue to work diligently with industry to help address and balance the rights, interests and concerns of local Aboriginal peoples with the rights and interests of our members and the general public.

AME is pleased to fully support the Kemess Underground Mine Project, and the work that has been completed by AuRico Metals Inc. to ensure it is constructed, operated and closed in a responsible manner.

February 9, 2017

Personal Information Withheld - Nelson, British Columbia


Personal Information Withheld - Victoria, British Columbia

The Ministry of Energy and Mines (MEM) has reviewed the Canadian Environmental Assessment Agency (CEAA) document 'Potential conditions under the Canadian Environmental Assessment Act, 2012' in relation to the Kemess Underground Environmental Assessment project.

MEM has provided these comments directly to the CEAA via email and through the online comment forum hosted by the BC Environmental Assessment Office.

MEM has reviewed the potential CEAA Conditions and respectively requests that the following conditions be removed or revised as they overlap and/or duplicate already existing regulations under the BC Mines Act. The specific conditions that MEM is concerned with include:

Conditions 3.1 and 3.2
An erosion and sedimentation control plan will be a mandatory requirement of the BC Mines Act permitting process and will encompass all activities that take place on the mine site boundaries.
In addition, the wording appears to be duplicative of regulations already enforced by BC FLNRO, we suggest that they be consulted prior to finalizing the condition.

Conditions 3.3.1, 3.3.2 and 3.3.3
Should the water leaving the mine site not meet MMER guidelines during any phase of mine life, sufficient enforcement tools are at the disposal of the federal authorities. However, the mine design aspects contained within these conditions are already strongly regulated through the BC Mines Act through all stages of life of mine. This includes management of mine waste (waste rock and tailings), contact and non-contact water management and water treatment.

Condition 3.4
As with the conditions above, the design, installation and maintenance of the decline plugs that will result in the direction of subsurface seepage towards East Cirque Creek is already regulated through the BC Mines Act.

Condition 3.5

The amount and timing of TSF effluent discharge to Attichika Creek will be regulated through both the BC Mines Act and Environmental Management Act.

Condition 3.6
As with Condition 3.3.2 and 3.3.3, the management of mine site contact and non-contact water is already regulated under the BC Mines Act.

Condition 6.4
This condition is inconsistent with how mine sites are regulated in BC. Firearm use on the mine site will be generally prohibited as a permit condition under the BC Mines Act.

Condition 6.5
The use of native species or non-persistent agronomic species in progressive reclamation is already regulated under the BC Mines Act and will be included as a standard permit condition.

February 7, 2017

Personal Information Withheld

My only comments relate to the following:

(Definitions 1.20) The term Qualified professional should be defined in the document – not just Qualified individual.

(Section 2.1) The proponent should be required to utilize Qualified professional (QPs) for disciplines for which accredited professional bodies exist. As members of an accredited professional body, 'qualified professionals' are bound by the rules and code of conduct of their organization, such as practicing only within their area of expertise, and performing task using professional standard of care and due diligence. Without professional designation, it is difficult to verify the qualification of individuals, or even to agree on what the appropriate level of experience would be for the particular task in question; or to determine whether the opinions and advice provided by the individuals are objective and unfettered.

(Section 3.2) The Proponent shall conduct in-stream construction activities only during regional timing windows identified … unless a work window variance is requested, and is granted by an Habitat Officer.

(Section 3.7.5) I recommend that the proponent be required to monitor the use of the lower Attichika Creek migration corridor by bull trout at the discharge location, and be required to make changes to the discharge diffuser design, or discharge volume or timing, if bull trout spawning migration is shown to be negatively affected by the effluent discharge.

(Section 8.2) ..give the environmental monitor the authority to stop Designated Project activities that do not comply with the conditions set out in this document, or any other relevant permits or approvals.

Thank you

AuRico Metals - Toronto, Ontario

Letter from Aurico Metals

Table - Review of Draft Conditions under CEAA 2012 submitted by AuRico Metals

January 24, 2017

Cliff Sampare/O'Yea - Gitxsan Traditional Territorys, British Columbia

Comments on Provincial Documents

Ni'Gyep House Group members be clearly consulted accordingly

  • need to meet with other impacted Nations. Priority HIGH
  • need to include Gitxsan Land Use Plan
  • need Reclamation on Old Kemess Pit
  • water usage & disposal methods
  • fish compensation a must on new/old roads
  • capacity funding doe's not meet actual requirements
  • identify disposed water that flows directly into our territory creeks & rivers
  • Partnership agreements
  • Employment opportunity's
  • Revenue transformation

Comments on Federal Documents

  • insure salmon spawning grounds are protected within SUSTAT/MAKENZIE REGION
  • our traditional culture & heritage protected.
  • insure project is safe & sustainable for all
  • additional unforeseen cost within region; health, other services
  • Partnership agreements