National Environmental Policy Act and Permitting Services for the Mining Industry

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1 Imagine the result Imagine the result National Environmental Policy Act and Permitting Services for the Mining Industry INNOVATIVE, SUSTAINABLE AND GROUNDED SOLUTIONS

2 National Environmental Policy Act and Permitting Services Our Services ARCADIS has nearly four decades of NEPA experience and has prepared more than 200 NEPA documents in the past 20 years to comply with the specific requirements of federal, state and local agencies. Our accomplished technical advisors and resource discipline leaders draw upon their local and national experiences to steer the course of the project to account for agency and stakeholder concerns, while remaining focused on achieving compliance with NEPA. We use proven best practices, develop streamlined processes, and eliminate duplications to save our clients time. NEPA Services Comprehensive Impact Mitigation Analysis and Modeling Services Permitting Services Navigating the National Environmental Policy Act (NEPA) in the review and assessment of mine plans of operation is complex. Selecting the right experienced third-party consultant to support the NEPA process for a mining project is critical to project success. ARCADIS attributes their approach to successfully addressing NEPA and permitting activities. We integrate best science-based practices with sound and flexible project management in a collaborative setting to deliver practical alternatives and solutions that are appropriate for the project, the environment and all stakeholders. As a result, we have an established positive NEPA Document preparation - Categorical exclusions - Environmental Assessment (EA) - Finding of No Significant Impact (FONSI) - Environmental Impact Statement (EIS) - Programmatic EAs and EISs - Record of Decision (ROD) - Memorandum of Understanding (MOU) - Decision memorandum Scoping summaries/reports Public involvement, outreach and education Decision analysis and documentation Appeals/litigation support Water management Geotechnical (slope stability/ subsidence) Air quality Ecological Risk assessment (ecological and human health) Social/economic Noise/visual Cumulative impacts analysis Mitigation planning/monitoring Environmental, Social and Health Impact Assessment (ESHIA) Aquifer Protection Permit (APP)/ groundwater protection permit Audits Due diligence Clean Water Act 404/401 permitting Zoning Air permits Stormwater/water pollutant control/ NPDES Regulatory permitting compliance and training Plan of operations/project construction Basline studies/data gap analysis Section 7 Environmental Species Act consultation and permitting compliance record working with multiple federal agencies as well as the public and mining proponents. Section 106 National Historic Preservation Act consultation FOUR DECADES OF NEPA EXPERIENCE

3 NEPA Because ARCADIS has the depth of experience delivering services throughout the mine life cycle, we understand the need for NEPA projects to address all stakeholder needs, and yet be balanced and practical. ARCADIS appreciates the unique position of being a third-party consultant and the challenges that it presents. We have a positive performance record working with federal and state agencies to achieve stakeholder objectives throughout the U.S., and we have the advantage of local experts to respond quickly to client developments. Project Highlights Final Environmental Impact Statement (EIS) and Record of Decision (ROD) Upheld for Gold Mine Expansion Bureau of Land Management, Nevada ARCADIS prepared the EIS for the expansion of the existing gold quarry pit and associated facilities located on Bureau of Land Management (BLM) lands. The EIS assessed the potential environmental effects of expanding the open pit, leaching facilities, roads and waste rock disposal areas and determined the potential for successful reclamation. Key issues of the assessment included the possible effects on: groundwater as a result of pit dewatering, Maggie Creek and the Humboldt River from water discharge, aquatic resources and terrestrial wildlife in the area and land use (grazing), and conceivable successful reclamation. ARCADIS conducted a detailed analysis of the impact to the aquatic habitat and populations from pit water discharge to the area streams and from no discharge at mine closure. A small number of comments were received on the Draft EIS and an appeal of the Final EIS and ROD was successfully upheld. Timely Interim Water Management Environmental Assessment (EA) Bureau of Land Management, Nevada ARCADIS prepared an EA for the Mule Canyon Interim Water Management Plan at the Mule Canyon gold mine. Pit lakes created by mining were filling faster than anticipated and had the potential to discharge poor quality water. The purpose of the EA was to determine potential impacts associated with discharge if the plan was not approved (no action) and if approved, the construction of facilities to transport and evaporate excess pit lake water. The EA had to be completed in a timely manner to allow completion of potential construction of facilities in order to avoid discharges during the spring runoff period. ARCADIS reviewed the original pit filling rates and ultimate pit lake water elevations to verify the amount of water to be managed. Proposed disturbance areas were evaluated for potential impacts to soils, vegetation (including threatened, endangered [T&E], and sensitive species), wildlife, cultural resources and visual resources. The Final EA included alternative water management solutions such as pit berms, ditches and evaporation ponds. Conceptual Site Model (CSM) Designed to Calculate Fate and Transport of Selenium to Minimize Impacts and Address Mine Closure Bureau of Land Management, Idaho ARCADIS performed environmental baseline studies and prepared the EIS for the 1,320 acre expansion of the Blackfoot Bridge phosphate mine. The BLM was particularly focused on the impacts caused by the expansion to the wildlife habitat, T&E species, and surface and groundwater quality, as well as the reclamation requirements needed for closure. Because high levels of selenium are prevalent in the region, ARCADIS conducted extensive geochemical testing to conclude its fate and transport, as well as potential risks from exposure to livestock and wildlife. As part of the mine closure plan, ARCADIS recommended leaching selenium from specific overburden piles to backfill the pits. ARCADIS also recommended capping and reclaiming other overburden piles. Because of complex geologic conditions and CWA 303(d) listing of the Blackfoot River, ARCADIS developed a CSM to establish criteria for a cap/cover meeting regulatory requirements and minimizing potential environmental impacts. Also included in the EIS were alternative solutions for wetland and waters of the U.S. to satisfy the CWA 404(b)(1) requirements for wetlands and waters, and detailed mitigation plans were assembled for the selected alternative. Integration of Multiple Assessments Provides Comprehensive, Integrated Analysis of Waste Management United States Forest Service and Montana Department of Environmental Quality, Montana ARCADIS prepared an EIS for the Stillwater Platinum/ Palladium Mine in Montana. The project proposed to revise the mine s waste management operations to include construction of a new tailings impoundment and pipeline system, and expansion of the waste rock storage area. This analysis was tied to several previous NEPA and mine permitting documents, requiring integration of multiple assessments into a comprehensive, integrated analysis. ARCADIS completed the impact evaluation from water management programs during operations, closure and post-closure. Analyses included detailed modeling to assess potential impacts to groundwater and surface waters from nitrogen, which was introduced into these receiving bodies from the use of ammonium-nitrate containing blasting agents. The Draft EIS and Final EIS addressed key issues of water quality and quantity, tailings impoundment stability, air quality and effects on wildlife and fisheries.

4 Planning and Permitting Support Mine planning is aimed at optimizing the management and development of mineral resources. Mine plan development consists of related steps that systematically build upon one another. ARCADIS helps with these steps by assessing and documenting the pre-mining site characteristics. We assimilate all of the data to create a comprehensive mining work plan that keeps post-mining redevelopment/land reuse at the forefront. This approach not only minimizes the mine s environmental footprint but ensures enduring sustainability of our clients mining activity and safeguards their economic profitability. ARCADIS seamlessly transitions into implementing the mine plans and permitting. We support our clients at each phase of the process, delivering results, and we are there to assist with new planning and permitting throughout the remainder of the mine s lifecycle. Project Highlights Science of Mineralogy Addresses Stakeholder Concerns and Supports Sustainable Mine Expansion Plan Golden Queen Mining Co., California Golden Queen Mining Co. Inc. wants to develop a gold and silver, open pit, heap leach operation on its Soledad Mountain property. Detailed past, present, and future mine project site conditions had to be determined to prepare a mine development plan and obtain permitting. ARCADIS utilized CSMs to understand the existing site conditions and to predict the environmental fate and bioaccessibility of trace elements present in ore, waste rock, leached residues, and the process solution used in heap leach operations. The CSMs presented a complete understanding of arsenic, its chemical form, and environmental stability. The geochemical and mineralogical investigations aided in hazardous air pollutant modeling and groundwater protection evaluations. Using the science of mineralogy to develop a CSM for every phase of the project, ARCADIS defined the extent of environmental and human health impacts to be managed during the mineral extraction process. In turn, a sustainable mine expansion plan was developed that addressed all stakeholder concerns and was adaptable to pending new cyanide and mercury emissions regulations. Monitoring Burden Recommended Removed from Permit Renewal Confidential Clients, New Mexico ARCADIS prepared Title V permit renewal applications for two copper mining and processing operations. Permit renewal activities included the evaluation of emissions from power plants, open-pit mining, solvent extraction, copper and molybdenum concentration, and tailings impoundments. The applications included our applicability determinations for state and federal requirements, including NSPS, the GHG Tailoring Rule, and National Emission Standards for Hazardous Pollutants. At one facility s power plant, we identified an existing permit requirement not mandated by the regulations. In the renewal application, ARCADIS proposed that this unnecessary monitoring burden be removed from the renewal permit. Innovative Database Design Eliminates Data Gaps for Baseline Studies Donlin Gold, Alaska ARCADIS personnel have been integrally involved in natural resource studies for both the Donlin Gold property mine site and pipeline corridor since 1997, supporting the work for the eventual EIS that is expected to be prepared for the project. Through established relationships with the Alaska Natives and surrounding community, ARCADIS has designed and implements quality baseline and background studies. The goal is to develop an environmental evaluation document that integrates over ten years of baseline studies and analysis into a comprehensive, easy-to-understand, report. ARCADIS has developed an innovative regulatory and compliance database that integrates essential project specific information for operational staff to use in the field. The database eliminates gaps or overlaps in internal management practices and regulatory compliance. Because of our sustained involvement on the project through several phases of ownership and operating managers, we have been able to deliver consistent environmental baseline programs and manage the resultant data so our client can make informed project decisions. Close Coordination with Multiple Agencies Results in Timely Completion of Assessment Bureau of Land Management, Arizona ARCADIS was contracted to complete a comprehensive EA for water system and transmission line upgrades for the expansion of a copper mine. The project involved both the BLM and Arizona State Land Department and addressed a number of impact topics including seeps/springs and riparian areas, adjacent wilderness land, wild and scenic river designation, state unique waters, and visual impacts. ARCADIS completed field surveys for wetlands, T&E species, and raptors in proposed tailings and waste rock expansion areas in support of the EA. An associated baseline assessment was completed by ARCADIS to comply with Section 7 of the environmental statement assessment and a detailed project construction and operations plan was prepared. Close coordination with many state and federal agencies, was needed to ensure project timing and completeness.

5 About ARCADIS: ARCADIS is a leading international company providing consultancy, design, engineering and management services in infrastructure, water, environment and buildings. We enhance mobility, sustainability and quality of life by creating balance in the built and natural environments. ARCADIS develops, designs, implements, maintains and operates projects for companies and governments. With 22,000 employees and more than $3.3 billion in revenues, the company has an extensive global network supported by strong local market positions. ARCADIS supports UN-HABITAT with knowledge and expertise to improve the quality of life in rapidly growing cities around the world. ARCADIS U.S., Inc. 630 Plaza Drive Highlands Ranch, CO Together we can do a world of good V01

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