Public Issues Tracking Table - Tulsequah Chief Barge Transportation System - Project Certificate Amendment Application

Transcription

1 Issue 1 Substrate resuspension; juvenile dislodgement; habitat deterioration No data to support claim that ACB is safe for fish and fish habitat in shallow water at certain times of the year, with the potential impacts on substrate re-suspension, juvenile dislodgement and redd habitat deterioration. Section Effects on Mainstem Spawning and Rearing and Section Disturbance of Substrates, Vol. 2, discuss issues related to mainstem spawning and the suspension of sediments. Section Entrainment Of Small Fish Under The ACB In The Air Cushion, Vol. 2, addresses potential juvenile dislodgement as a result of ACB activity. Section , Stranding of Juveniles, Vol. 2, discusses issues related to wake and wave action from the ACB, which relate to potential juvenile dislodgement issues. Redfern is not aware of any air-cushion barge transportation system operating on a river that supports pacific salmon. As such, there is no data that explicitly quantifies the effect of this type of transportation system on a river similar to the Taku. Redfern is committed to: 1) Defining an operational procedure that avoids shallow areas where possible. 2) a monitoring program that will monitor the effects on fish where the barge transitions from land to water, including stranding from barge/tug wash pushing fish up onto shore. 3) Adjusting operations based on the results obtained in the monitoring program. This could include: (a) altering the path taken by the barge, (b) altering the speed of the barge to reduce the wake, (c) taking proactive measures to move fish from or keep fish out of areas of impact prior to the barge entering the area, and (d) using amphitrac rather than tug to draw less water. Issue 2 Effects on River Structure (channel morphology) There is insufficient information related to effects on river structure in light of daily hover barge passage This comment does not clearly define the information that is required from Redfern. The barge and tug will be slow moving and will not produce a large wake. As such, the barge is not expected to cause any significant change in river structure through bank erosion or channelization. No dredging or deliberate alteration of river morphology is proposed to support this operation. The Taku River is a very dynamic fluvial system that experiences flow ranging from 23 m 3 /s to over 3,000 m 3 /s with a mean annual discharge of approximately 388 m 3 /s. Wake size will be verified prior to operations commencing. Issue 3 Eulachon spawning Insufficient information on eulachon habitat, distribution and potential impacts Eulachon spawning occurs in the State of Alaska. The State of Alaska permitting process is addressing this concern. The majority of potential for impact will likely be avoided due to shut down of transportation operations in the spring while awaiting ice break up on the river and flows to return to sufficient levels for aquatic operations to begin. Additional studies were carried out in spring of 2008 to document timing of eulachon spawning and distribution upstream of larval fish. See Eulachon Distribution in the Taku River (Flory, 2008). Issue 4 Effects of air pressure on sensitive areas The down blast from the hover barge fans is glossed over, with the mean footprint of 1 psi cited rather than addressing the actual impacts that could be expected from having a large vehicles of this sort pass over sensitive areas exerting the pressure over a large area simultaneously Section of Vol. 2 describes what is known about the effect of an ACB working in sensitive areas. Because water does not compress, we know the pressure on the surface of the water does not cause an increase pressure on sensitive habitat or sensitive life stages of fish under the water. Information provided in section Noise of Vol. 1 indicates that underwater sound generated by hovercraft is considerably less than similar sized conventional vessels. On land the 1 psi over the entire area covered by the ACB is not likely to have any noticeable effect on the gravel cobble substrates it will travel over. Field trials during the commissioning phase will document the noise levels, and footprint of the ACB under maximum load, on varying types of substrate (mud, cobble, vegetation). (82636_dtab_TC_PUBLIC_Issue_Tracking_08Nov11_jc_v7.doc) 1 of 9

2 Issue 5 Increased predation of juveniles flushed out of gravel No attention given to impacts from increased predation from flushing salmon juveniles out of gravel. We assume the suggestion is that the ACB will force juvenile salmon to flee from the disturbance caused by the approaching air cushion barge, and by abandoning the protective shallows, will be subjected to increase predation in deeper water. The company s experience from operating a conventional barge during 2007 is that the shallowest section of water within Canada is that near the proposed barge landing area. The company commits to working closely with Fisheries and Oceans Canada to define the potential impacts within this area. Issue 6 Sedimentation Sediment suspension during incubation period. The barging is not expected to cause any noticeable sediment suspension above background levels in the fall to spring incubation period. When travelling on the ice there will be no increase in sediment levels. The report has addressed the issue of sedimentation during the open water period, early fall, and late spring when the air cushion barge is operating on the water. The wake produced by the slow moving air cushion barge and tug is not expected to cause any significant erosion or re-suspension of sediment. While there is only limited data available, Table 3-5, Total Suspended Sediments and Turbidity Data for the Taku River, Vol. 2 reported that the total suspended sediment recorded in the Taku River during the fall open water period the natural sediment load in the Taku River is ranges from 24 to 73 mg/l while the spring levels ranged from 19 to 280 mg/l. During commissioning, field tests to measure wave height under a range of vessel speeds will be conducted. The results of these tests will be used to develop or modify operational procedures to minimize wake in sensitive areas along the river. Issue 7 Disturbance of salmon eggs No information is provided about salmon egg/embryo disturbance in general. General disturbance to salmon egg/embryos as a result of the air cushion barge operation is not predicted. Section Pacific Salmon and Section Effects on Mainstem Spawning and Rearing, Vol. 2, includes information on salmon spawning areas. Maps showing fish habitat along the Taku River, based on current knowledge of habitat types, have been provided. Studies cited in the environmental assessment indicate that spawners using the mainstem of the Taku River tend to select habitats such as side-channels, back channels, sloughs and upwelling basins. The air cushion barge route will generally avoid these areas causing little to no disturbance to eggs and embryos. There may be disruption of some fish habitat in the shallow area near the barge landing facility. The company will work closely with Fisheries and Oceans Canada to define that potential effect. Issue 8 Mapping of salmon habitat adjacent to route Insufficient mapping of salmon habitat along and adjacent to the barge route; specifically juvenile habitat The environmental assessment report relied on the salmon spawning locations provided in Eiler, J.H., B.D. Nelson, and R.F. Bradshaw, 1992, as cited in Vol. 2. No specific habitat mapping was prepared for this environmental assessment. Juvenile salmon tend to stay in shallow, edge of river habitats or back-channels and sloughs which are located 10 s to 100s of meters away from the proposed route of the air cushion barge, as illustrated in Appendix C, Route Atlas, Vol. 1, except for the barge landing area. However, because there is no air cushion barge operating in areas similar to the Taku River, Redfern is committed to setting up a monitoring program to confirm whether juvenile fish are being negatively impacted at the barge landing facility. Corrective action, in consultation with Fisheries and Oceans Canada at the barge landing operations will be made if notable adverse effects are identified. A Fish Habitat Atlas has now been prepared and identifies salmon habitat along ACB route. (82636_dtab_TC_PUBLIC_Issue_Tracking_08Nov11_jc_v7.doc) 2 of 9

3 Issue 9 Thermal weakening of ice No information on thermal weakening of river ice prior to break-up The assumption is not clear. No mechanism has been identified that would cause thermal weakening of ice prior to break-up in Canadian waters. Issue 10 Impact on wildlife during winter Potential impact to wildlife using river ice as a travel corridor Section Terrestrial Mammals in Volume 2 of the EA provides a summary of the potential effects on wildlife that may use river ice as a travel corridor. A detailed assessment on the potential effects and the proposed monitoring and mitigation measures to reduce those effects is provided in Tulsequah Chief Mine ACB Transportation System - Detailed Wildlife Effects Assessments and Mitigation Measures February The detailed effects assessment provides supplementary information and detailed effects assessments on moose and wolf use of the area during the winter and the predicted effects. Mitigation measures to reduce the predicted effects are provided in the document Wildlife Management Plan - Wildlife Mitigation Policies and Procedures in May 2008 for review. Proposed monitoring programs to monitor winter wildlife use is provided in the document Wildlife Monitoring Program for review. Commitment #12 Issue 11 Ice formation and thickness Information on ice formation and thickness Ice breaking is not desirable for operations on the Taku River. When shelf ice is less than 3 inches thick, aquatic operations will be maintained in open mainstem channel and thin ice shelves forming along sides of channel or near gravel bars will be avoided. When shelf ice thickens, when it is greater than 3 inches thick, the route will traverse solid shelf ice and avoid open leads in the mainstem as much as possible to minimize ice breaking and maintain efficient operations. There may be periods of time when the company suspends operations in order to facilitate natural ice formation. Ice monitoring program was completed for 2008 breakup and will be continued throughout operations. Issue 12 Effects on overwintering juveniles/eggs under ice Little specific detail about ice formation, schedules, thickness and importance of ice cover to juveniles/eggs Section Effects on Ice Formation and Break Up, Vol. 2., discusses issues related to ice formation and ACB effect on ice thickness. Section 4.3.2, Winter Operations-Early November to Early April, Vol. 1, discusses ACB activities on the Taku River during the winter. Ice formation along the Taku River begins along the edges, slow moving shallows and gravel bars; the thalweg is the last area to freeze over. A few sections of the Taku River remain open year round due to groundwater upwelling; the ACB will avoid these areas where possible. It is important to note that there will be no attempt to create an ice road on the Taku; ice road activities, such as flooding the surface of the ice, will not be conducted. Given that spawning does not appear to occur near the barging route, effect on juveniles/eggs under ice would not be a significant concern, except perhaps in the area near the barge landing facility. With respect to the importance of ice cover to juveniles/eggs, trials in the spring of 2008 will be used to determine how best to operate the ACB during the period around spring break-up. One of the criteria for determining the optimal operational plan will include causing minimal disruption to the ice regime on the Taku River. Issue 13 Lack of No bathymetric data to back up channel depth assumptions on tidal flats Please refer to Appendix A Channel Depth Analysis of the Lower Taku River of Volume 1 for detailed bathymetry collected in June Note also that the results of this 2007 bathymetric study agreed well with the results of a similar study by Sandwell in (82636_dtab_TC_PUBLIC_Issue_Tracking_08Nov11_jc_v7.doc) 3 of 9

4 bathymetric data Issue 14 Potential cumulative effects of Big Bull and Polaris mines Cumulative effects of Big Bull and Polaris mine There are no plans to develop / operate either Big Bull or Polaris exploration properties during the timeframe that Tulsequah Chief mine is planned to operate. As there is no temporal overlap, no cumulative effects are predicted. Tulsequah Chief Mine Air Cushion Barge Transportation System Vol. 2 includes discussion regarding potential for cumulative effects associated with these exploration properties. Issue 15 Contamination of river water Impact on salmon habitat due to significant river water contamination that is likely to occur The source of significant river water contamination or its presumed likelihood is not identified in the question. No significant river contamination is predicted to occur. A Spill Prevention and Response Plan will be implemented to prevent and respond effectively to any spills. Commitment #10 Issue 16 ACB use elsewhere Where else has ACB been used successfully used Yukon River; England (Norfolk coastal tidal flats); Suriname; Abu Dhabi; Dead Sea. Issue 17 Maintain ice cover Icebreaking - how will ice cover be maintained Ice breaking is not desirable for operations on the Taku River. Route will follow ice / snow cover on shelf ice, over gravel bars, shallow stretches of river. Avoid, to extent possible, thin ice cover in mainstem, allowing it to freeze and remain frozen. Where open leads cannot be avoided, amphitrac will cross ahead of ACB, then winch ACB across lead and up onto thicker, or landfast ice. Commitments #4, #5 and #6 Issue 18 Dispersion of salmon due to pressure exerted on water and river bottom Daily passage of ACB will scatter salmon due to pressure exerted on water and river bottom The air cushion barge will displace water, similar to any other object in water. The displacement is related to the mass of the vessel, and is approximately 1240m 3 when fully loaded. The draught of the ACB when fully loaded on hover is 0.73m (2.4 feet). No additional pressure would be exerted on the river bottom as water cannot be compressed, and the barge hovers above the surface of the water that is not displaced. In channel depths less than about 0.73m (2.4 feet), the bottom of the flexible skirts will touch the river bottom; however, the route in Canada will follow the deepest part of the river channel during the aquatic season, avoiding areas that are shallow, other than where it comes ashore at the barge landing site. Some water spray will escape the spray skirt, but that is the extent of the effect of the air pressure exerted on the surface of the water. Spray only occurs at the skirt where the pressure differential exists. Air under the barge is relatively calm. Daily transit of the ACB may cause short term, temporary disturbance to migrating salmon, however this effect is unlikely to have any significant (long-term, permanent, widespread) effect on upstream or downstream migration. (82636_dtab_TC_PUBLIC_Issue_Tracking_08Nov11_jc_v7.doc) 4 of 9

5 Issue 19 Accident prevention and response Unclear on how accidents will be dealt with, clarify any landing sites in event of an accident Volume 2, Section 4.8 describes potential accidents and malfunction scenarios, and how these will be dealt with. In the unlikely event of a malfunction, the ACB would be taken off hover, and gradually set down and secured. If difficulties occur in Canadian waters every effort will be made to return the vessel to the barge landing area, depending on the specific circumstances of the situation. Commitment #10 Issue 20 Spill prevention and response & (3) Spill prevention and planning for project, including haul road Redfern is developing Spill Prevention and Response Plan for all aspects of the transportation system, including the haul road, barge landing area, and river/marine transportation components of the system. This plan will be implemented prior to commencement of operations. Spill Prevention and Response Planning is a normal part of most, if not all, industrial operations. Commitment #10 See also Site Spill Plan. Issue 21 Documented hovercraft impacts Resident (3) What impacts documented in an equivalent river system related to: -wake -icebreaking -salmon populations Studies have been carried out to determine effects of hovercraft in terms of wake, noise, and effects on fish stranding, as referenced in Volume 2, Section The design of the ACB is such that the speed, noise levels, and wake are much reduced from a hovercraft or conventional tugs. As such, the potential effects of the ACB are predicted to be insignificant, based on professional advice. Issue 22 Precautions during outburst floods Resident (3) Outburst floods on river - what precautions will be taken to ensure safe transport Increase in flow from either the annual freshet or outburst floods cause water levels in the river to rise gradually over several days and are not catastrophic events. Volume 2, Figure 3-5, illustrates the effect of outburst flood events on the Taku River hydrograph over a 3 to 4 day period. These floods are obvious on the Tulsequah River and will be monitored by staff at the mine. These staff will communicate any flood activity to transportation staff when it occurs. The company will regularly monitor the USGS water gauge operated at Canyon Island. Issue 23 Extension to 30-day public comment period Resident (3) & (4) Request for extension to public comment period The 30 day public comment period from September 17 to October 17 was set by the BC EAO. This is a standard Environmental Assessment process timeframe for the public review and comment of documents. The public comment period will not be extended. Issue 24 3 rd party endorsement Redcorp s recent System Update appears to lack the endorsement of Gartner Lee Preparation of the update document was done primarily in-house and therefore does not bear GLL logo, nor is it a report that would require endorsement. Any habitat reporting equipment design will have the endorsement of the appropriate professional. Issue 25 Concerns with conventional New concerns about Redcorp s proposed use of conventional barges and shallow draft tugs tug being pulled over, grounding, high This relates to conventional and not the applied for amendment. (82636_dtab_TC_PUBLIC_Issue_Tracking_08Nov11_jc_v7.doc) 5 of 9

6 barges and shallow draft tugs wakes and other recent problems; Redcorp s conventional barging operations have experienced significant problems to date. The impacts of the conventional barging should be fully analyzed, including effects on bottom substrate and salmon habitat and the ability to operate safely and respond to accidents Issue 26 Inappropriate equipment The tracked and wheeled tow vehicles are not designed for the use proposed by Redcorp. They have limited propulsion and The company will only be using the wheeled or tracked tow vehicles in a safe manner within their design parameters. steerage in moving water, thus their ability to operate as Redcorp proposes is in doubt. Issue 27 Accidents and spills The potential for accidents and spills is not addressed Refer to response for Issue 19. Commitment #10 Issue 28 Equipment capability There are a number of reasons to doubt that the vehicle can cross open leads as Redcorp proposes safely and without impacts to the ice cover No reasons provided to address. Overall equipment will be operated in a safe manner and appropriately in relation to potential environmental effects through consistent monitoring and adaptive management processes. Commitment #5 Issue 29 Effects from equipment from repeated operations The effect on sand bars, bottom substrate and ice from repeated travel by tracked and wheeled vehicles and the ACB for 8 years of mine operations is not addressed. This issue will be addressed by consistent monitoring, reporting, and adaptive management practices. Issue 30 Effects of anchors and The effects of the plough-like anchors and winching on ice cover and bottom substrate is not addressed There is not likely any effect to fish or fish habitat by winching or anchoring on ice cover. Dragging cables over bottom substrates is not planned. Tension will remain on cables when being fed out. (82636_dtab_TC_PUBLIC_Issue_Tracking_08Nov11_jc_v7.doc) 6 of 9

7 winching Issue 31 No detailed info on ice cover There is no detailed information on the ice cover. The ice cover in the Taku River is no like the North Slope or Yukon, where the ice is thick and relatively stable. Conversations with Taku property owners who have spent significant time on the Taku in winter indicate that the ice is full of holes, gaps, weak areas, flowing water and other conditions that could result in stuck vehicles, accidents and negative changes to the ice and snow cover Ice cover on the Taku River will be a dynamic element of the operation, both intra and inter-seasonal differences, as well as local differences will occur. Monitoring of ice conditions will be a consistent element of operations. Issue 32 Salmon and eulachon habitat info Detailed information based on field studies of salmon and eulachon habitat, channel width and depth in various conditions and ice cover not provided Salmon habitat maps; refer to Issue 3 re: eulachon. Eulachon report now available See Eulachon Distribution in the Taku River (Flory, 2008). Issue 33 Surface wakes Inadequate information on surface wakes; Taku River property owners have reported significant wakes up to 4 from Redcorp s two new tugs Larger wakes can occur in the very fast waters of the Canyon Island narrows upstream and away from any cabins. In the wider and slower portions of the river in Canada the wake effect is much less. The company will undertake wake monitoring and adaptive management primarily by reducing speed in specific locations. Issue 34 Hoverbarge impacts on substrate and salmon habitat Redcorp continues to ignore the potentially serious effects on bottom substrate and salmon habitat from underwater currents induced by the hoverbarge and the other vehicles Barge related scour assessment being currently being completed. Assessment of risk to fish and fish habitat added to Aquatic Risk Assessment Table. Recommendations for monitoring will accompany the assessment. See US Department of Interior Issue 16 and DFO Issue 33 for further information. Issue 35 Hoverbarge testing prior to operation Redcorp s plan relies on commissioning and testing to be done concurrent with operational use. Testing should be conducted prior to operational use and information gaps should be filled prior to any use of the hoverbarge The commissioning tests and other tests to demonstrate general operational parameters will be done prior to operations. See Transportation Update (August) Section 4. (82636_dtab_TC_PUBLIC_Issue_Tracking_08Nov11_jc_v7.doc) 7 of 9

8 system in the Taku. Issue 36 Details on monitoring plan, mitigation measures, ability to detect problems Redcorp s plan also relies largely on adaptive management and monitoring, rather than up front testing, researching and analysing. Few details of the monitoring plan, mitigation measures and the ability to promptly detect problems such as damage to salmon habitat is provided. A detailed Aquatic Effects Monitoring & Mitigation Plan has been developed and is currently being reviewed by the BCEAO Working Group s Fisheries Subcommittee For wildlife, a draft document Wildlife Management Plan - Wildlife Mitigation Policies and Procedures was provided in May 2008 for review and the document Wildlife Monitoring Program was provided in August 2008 for review. Commitments #11 & #12 Issue 37 Analysis of System Update The BC EAO is apparently treating this significantly modified new plan as a minor amendment to an existing plan. The System Update is a significant change from past proposals and a much more rigorous analysis is needed. This issue is not addressed to Redfern, therefore they will not be providing a response. Issue 38 Cumulative effects A cumulative effects analysis has still not been conducted. Refer to response to Issue 14. Cumulative Effects report to be provided at a later date. Issue 39 Comprehensive analysis The BC EAO appears to be focussing on only the hoverbarge route in BC, and is ignoring the Alaska side. This prevents a comprehensive analysis of the hoverbarge system s full effects. This issue is not addressed to Redfern, therefore they will not be providing a response. Issue 40 Monitoring of hoverbarge effects Redcorp states that the environmental monitor will not be a full time job and will be an audit function. This raises more questions about how Redcorp will It is probably most accurate to state that some aspects of the monitoring will be full time and some part-time, and that as time progresses and adaptive management strategies are put in place that the monitoring will become more auditing. The company anticipates that monitoring will be intensive, possibly even full time during the first few seasons. Monitoring efforts will be clarified through the Fisheries Working Group and Wildlife Working Group Commitments #11 & #12 (82636_dtab_TC_PUBLIC_Issue_Tracking_08Nov11_jc_v7.doc) 8 of 9

9 be able to properly monitor the hoverbarge system for environmental effects. Issue 41 Protection of juvenile salmon The use of snow grooming equipment and potential changes to the ice and snow cover from the various vehicles raise concerns to the insulating qualities of the snow and ice cover needed to protect juvenile salmon. Refer to response for Issue 12. Respondents: 1. David McKinnon, Borders. October 17, Don Weir, resident. October 12, Nan Love, resident. October 12, Wayne Merry, resident. October 14, Chris Zimmer, Borders. July 30, (82636_dtab_TC_PUBLIC_Issue_Tracking_08Nov11_jc_v7.doc) 9 of 9