Re: Teck Frontier Oil Sands Mine Project: Responses to Supplemental Information Requests (SIRs)

Transcription

1 Teck Resources Limited January 16, 2014 Métis Local 125 (Fort Chipewyan Métis) Attention: Fred Fraser (President) Re: Teck Frontier Oil Sands Mine Project: Responses to Supplemental Information Requests (SIRs) Dear Mr. Fraser: Teck is in receipt of your February 27, 2013 letter to the Canadian Environmental Assessment Agency (CEAA) regarding the Teck s responses to Round 1 SIRs. While the comments contained within the letter are directed to the regulator, Teck responds to your comments directly. We ve organized our response according to the numbered bullets in your February 27, 2013 letter. Traditional Use / Métis Rights and Practices 1. Teck will be undertaking detailed closure, conservation and reclamation (CC&R) planning for the Frontier Project and intends on consulting with the FCM and other potentially affected Aboriginal communities in the development of the plan. Although the response to ESRD/CEAA Round 1 SIR 3 specifies First Nation land uses, Teck notes that in our response, all of the examples of how traditional land use was considered in the CC&R plan apply to potentially affected Métis communities in the oil sands region (e.g., collection of native seed for revegetation stock, inclusion of key species traditionally hunted and harvested, salvaging known occurrences of rare species, etc.). Teck will engage the FCM in establishing criteria to determine reclamation success in conjunction with regulatory criteria. 2. Teck intends to consult with the Fort Chipewyan Métis (FCM) when developing an access management plan (AMP) for the Project. For additional details related to the planned development of the AMP, see the response to ESRD/CEAA Round 1 SIR 8.

2 3. Teck respects the difference between traditional land use (TLU) and traditional environmental knowledge (TEK). While the information provided by way of the Hermansen oral history project and FCFM territory wide Traditional Land Use and Occupancy Study (TLUOS) is valuable for Project planning purposes, Teck acknowledges that neither of these studies constitutes a Project specific assessment of potential effects to FCM. Teck recently met with the FCM and agreed to fund a Frontier Project specific TLU. Teck looks forward to working with the FCM to develop a work plan and budget for the TLU in the near future. Teck has been engaged in consultations with the FCM since The outcomes of consultation activities have informed and will continue to inform Project planning. Teck continues to undertake consultation activities in a manner that is responsive to community interests and needs and welcomes the opportunity to undertake additional consultations with the FCM to address outstanding concerns. Environmental Concerns 1. Teck has undertaken a cumulative effects assessment as part of the Frontier Project environmental impact assessment (EIA) and has provided additional information on cumulative effects in responses to Round 1 and Round 2 SIRs. Examples where Teck further explores and discusses cumulative effects include the responses to: ERCB Round 1 SIR 72 where Teck provides further justification for the spatial extent of their assessment for aquatic disciplines ESRD/CEAA Round 1 SIR 142 where Teck provides a summary of the cumulative effects (e.g., environmental costs of the Project) ESRD/CEAA Round 1 SIR 308 where Teck provides an assessment of cumulative effects for select disciplines for an alternate Base Case that does not include likely-to-be-approved developments ESRD/CEAA Round 1 SIR 309 where Teck provides further justification for the spatial extent of their assessment ESRD/CEAA Round 1 SIR 316 where Teck discusses the effects of the Project on rights identified by the FCM expressed during consultation with Teck ESRD/CEAA Round 1 SIR 317 where Teck provides western science based assessment conclusions (i.e., assignment of environmental consequence) to traditional land uses ESRD/CEAA Round 1 SIR 320 where Teck provides a summary of management and monitoring commitments from Volumes 4 to 8 of the Integrated Application ESRD/CEAA Round 2 SIRs 30, 72 and 73 where Teck provides further justification for the spatial extent of their assessment for aquatic disciplines ESRD/CEAA Round 2 SIR 138 where Teck provides further information on potential impacts of the Project to Métis and First Nations rights

3 ESRD/CEAA Round 2 SIR 184 where Teck provides further discussion on the contribution of natural disturbance to cumulative effects ESRD/CEAA Round 2 SIR 186 where Teck provides further discussion of the contribution of low impact seismic to cumulative effects ESRD/CEAA Round 2 SIR 187 where Teck provides a range of cumulative effects assessment conclusions associated with best-case and worst-case reclamation scenarios Teck welcomes the opportunity to meet with the FCM to specifically discuss cumulative effects and better understand how Teck can address these concerns. 2. Teck has undertaken an assessment of potential effects to water quality and quantity as part of the Frontier Project EIA and has provided additional information on effects to water in responses to Round 1 and Round 2 SIRs. For a discussion of specific concerns expressed by FCM that Teck has further explored through responses to Round 1 and Round 2 SIRs see the response to ESRD/CEAA Round 2 SIR 138. Teck welcomes the opportunity to meet with the FCM to specifically discuss effects to water quality and quantity and better understand how Teck can address these concerns. 3. The catchment for Big Lake (Oakley/Unnamed Lake 1) and Unnamed Creek 2 will be changed by Project activities. This is a result of the location of the oil sands resource at the toe of the Birch Mountains and need to have external disposal areas near the pit. The location of the pit and disposal areas controls the configuration of the water management system. These features, in conjunction with the natural drainage system require that Big Lake be used as a sedimentation pond during operations. Post closure, Teck plans to reclaim Big Lake and integrate it into the reconstructed watershed and natural drainage system. Teck welcomes the opportunity to discuss the water management plan for the Project in greater detail with the FCM. 4. As discussed in the Integrated Application and further clarified in the responses to: ERCB Round 1 SIR 54 fine tailings capture ESRD/CEAA Round 1 SIR 271 further details on the planned tailings management process ESRD/CEAA Round 1 SIR 470 viability and contingency for tailings management ESRD/CEAA Round 2 SIR 123 further details on the drying procedure for fluid fine tails Teck believes that the tailings management plan will function as designed; however Teck continues to monitor and evaluate advances in tailings management technologies to ensure that the technology most appropriate to Project conditions is employed. Teck is also engaged in tailings management and reclamation research through COSIA. Teck welcomes the opportunity to discuss tailings management and reclamation strategies in greater detail with the FCM.

4 5. For additional information and assessment conclusions on the effects of the Project in conjunction with operating, approved and planned developments on woodland caribou, see the responses to ESRD/CEAA Round 2 SIRs 91, 92, 93, 94, 95, 96, 97, 98 and 189. As discussed in the response to ESRD/CEAA Round 2 SIR 189c, considering disturbances from operating, approved and planned developments, and the not selfsustaining status of each boreal caribou herd in the vegetation and wildlife regional study area (RSA), cumulative effects on caribou are predicted to be of high magnitude and irreversible in the long-term, and therefore are considered to be of high environmental consequence. The Project s contribution to this effect is minimal as it is outside of defined caribou habitat ranges and use of the revised terrestrial local study area (LSA) appears to be minimal based on collar data and traditional knowledge made available to us. This conclusion aligns with the Joint Review Panel s Decision Report for the Jackpine Mine Expansion (Joint Review Panel 2013). As with the Frontier Project the Jackpine Mine Expansion is also outside of identified caribou habitat range. Teck is a member of COSIA which actively supports research programs and technology development such as the Landscape Ecological Assessment and Planning (LEAP) tool. LEAP will be used to prioritize and measure reclamation efforts throughout the southern Lower Athabasca Region with the goal of reducing forest fragmentation and reestablishing boreal caribou habitat (e.g. the Algar Caribou Habitat Restoration Program). Teck recognizes that caribou conservation is a national priority and as a member of COSIA, will continue to actively participate in discussions related to mitigation and offsets for caribou. For further details see the responses to ESRD/CEAA Round 2 SIRs 91 and 93. It is anticipated that learnings generated by LEAP as well as future research initiatives will inform reclamation planning for the Frontier Project. 6. Teck will be undertaking detailed CC&R planning for the Frontier Project and intends on consulting with the FCM and other potentially affected Aboriginal communities in the development of a detailed reclamation plan. As stated above, Teck has been consulting with the FCM since The outcomes of consultation activities have informed and will continue to inform Project planning. Teck welcomes the opportunity to undertake additional consultations with the FCM to better understand concerns regarding potential social, cultural and economic effects of the Frontier Project. Please do not hesitate to contact me if you d like any additional information or would like to meet to discuss any of the concerns raised in your February 2013 letter. Sincerely, Ian Mackenzie Director, External Affairs, Teck Energy Teck Resources Limited

5 Cc. Ora Campbell (Office Manager, FCM) Cynthia Bertolin (Sunrope Consulting) Janais Turuk (Teck) Carolyn Dunn (CEAA) References Joint Review Panel Report of the Joint Review Panel Shell Canada Energy Jackpine Mine Expansion Project, Application to Amend Approval 9756, Fort McMurray Area. Joint Review Panel Established by the Federal Minister of the Environment and the Energy Resources Conservation Board. Alberta Energy Regulator, Calgary, Alberta and the Canadian Environmental Assessment Agency, Ottawa, Ontario.