Ministry of the Environment, Conservation and Parks Ministère de l’Environnement, de la Protection de la nature et des Parcs

September 10, 2021 Sent by Email

Debra Sikora, Panel Chair Joint Review Panel Marathon Palladium Project

Dear Ms. Sikora:

On behalf of the federal-provincial Government Review Team for the proposed Marathon Palladium Project, please find enclosed a table of suggested areas for the Joint Review Panel to view during its September 2021 visit of the Project site and surrounding area, as requested in the site visit announcement (CIAR #919).

Sincerely,

Ian Lindsay Federal Participation Coordinator Impact Assessment Agency of Canada

Carolyn Lee Provincial Coordinator Ministry of the Environment, Conservation and Parks

Enclosure

c: Environment and Climate Change Canada Fisheries and Oceans Canada Health Canada Employment and Social Development Canada Ministry of Northern Development, Mines, Natural Resources and Forestry

<Original signed by>

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Marathon Palladium Project - 09/2021 Site Visit: Government Reviewers' Suggestions to Joint Review Panel

Ministry/Department/Agency Location/Area/Feature Rationale

Environment and Climate Change Canada

General Comment It is recommended that the Panel and the Panel Secretariat

capture by video key locations during their helicopter and

ground tour of the project site, and that this video be made

available on the public registry

Environment and Climate Change Canada

Footprint of components of the Project (permanent and temporary)

To support the understanding of potential cumulative

impacts

Environment and Climate Change Canada

Areas in and around the Project (Site Study Area and Local Study Area)

Observe the current state of landscape connectivity in and

around the project site from a wildlife habitat

availability/connectivity perspective

Environment and Climate Change Canada

Open pits, ore stockpiles, processing facility, waste rock stockpiles and tailings impoundment areas

Undertake a comprehensive aerial tour of the lands where

mine features will be located to get a sense of the scale of

the Project and topography at the proposed site

Environment and Climate Change Canada

Mine Rock Storage Area and Stream 103

Observe the slope in and around the Mine Rock Storage Area and consider potential challenges associated with anchoring the mine rock waste at the proposed site

Visit Stream 103 to verify it is a cold water stream and, once

verified, consider potential challenges associated with

maintaining this cold water feature

Employment and Social Development Canada

Valard Construction Camp (as known as Temporary Construction Camp) and site

Under IR2-6 (Canadian Impact Assessment Registry / CIAR #752): “Socio-economic – Labour market and employee accommodations,” and the associated Proponent’s response

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for the future Accommodation Complex

(CIAR #757), the Joint Review Panel requested information on:

1. Housing options the Proponent is proposing to construct and/or operate as part of the Project;

2. Worse-case scenario assessment of Project’s effects on infrastructure and town services, assuming that motels, hotels and rental units are not available; and,

3. Technically and economically feasible measures that the Proponent will use to mitigate the effect on housing from the transient workforce, recognizing that a 100-person accommodation complex is not sufficient to eliminate the residual effect.

The Proponent’s response can be summarized, at a high-level, as follows:

1. No new accommodations are proposed during site preparation and construction phases of the Project; instead, the Valard Construction Camp will be used to accommodate the workforce.

a. It currently houses approx. 350 persons, but can be expanded to accommodate 700 workers, and already has sewer, water, hydro service, commercial kitchen, recreation, maintenance, and management facilities.

b. The camp is currently used to house workforce constructing another industrial project (East-West Transmission Line Project), which is scheduled to complete in Q1 2022, and thus would be available to the Proponent for their Project.

c. During operations of the mine, the Proponent estimated that 15% of the workforce would require additional accommodation (i.e. 60 transient workers),

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which would happen at the Accommodations Complex (with the potential to be expanded to 180).

2. Worse-case scenario assessment of Project’s effects on infrastructure and town services, assuming that motels, hotels and rental units are not available

a. The proponent provided a conservative estimate of peak workforce at 870 workers during construction, with an average of 360 workers to be on site per day. b. The worst-case scenario assumes that 100% of construction workers and 50% of operations workers will be transient, representing 106 workers who would need accommodations during operations (based on an average of 212 workers per rotation). The response asserts that “if the Accommodations Complex is built with 180 rooms, it will be more than sufficient to house the operations workforce.” c. The Proponent notes that the worst-case scenario is highly unlikely, and that they will take “mitigation and enhancement measures” to encourage local employment, such as training opportunities and supporting initiatives to train local youth and members of Indigenous groups. d. The Proponent also notes that construction and operation employees’ use of local health and emergency, recreation, transportation, water, sewage, and waste services and infrastructure will be reduced because they will all live at the Valard Work Camp or Accommodations Complex, and not in the “Regional Study Area” (RSA).

3. Technically and economically feasible measures that the Proponent will use to mitigate the effect on housing from

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the transient workforce, recognizing that the 100-person accommodation complex is not sufficient to eliminate the residual effect.

a. The Proponent repeats that 350 persons can be accommodated at the Valard Construction Camp, up to 700 assuming modification, and that an additional Accommodations Complex will be built to house approximately 60 workers, assuming a design that allows for 180 rooms; b. The Proponent notes that the accommodations strategy is flexible and can be adjusted as more information about the nature and size of the workforce during each phase becomes available; and c. The Proponent also states commitment to providing accommodations for all workers who do not live in the RSA.

Following review of the site visit announcement and 2011 Site Visit Summary, it is unclear whether the Joint Review Panel will be inspecting the Valard Construction Camp and Accommodation Complex.

Given the Joint Panel’s information request, and the subsequent assertions made in the Proponent’s Response, the Joint Panel may want to consider adding inspections of the Valard Construction Camp and land relating to a future Accommodations Complex to the list of areas or features that the Panel should consider visiting during the tour.

Fisheries and Oceans Canada

Streams 1-3 and 6 DFO suggests that the JRP requests to see an aerial view of all waterbodies and watercourses that may be affected by the project

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Hare Lake and the Stream 5 downstream of Hare Lake Figures 2-3, 2-4, 2-5, 2-7 and 2-8 (included below) provide a

good reference of the areas. Figure 5-1 (also included) displays the areas being affected, and Figure 5-2 (also included) provides a good reference as to the fisheries resources observed in those waterbodies. Together, the aerial overview and reference maps should help put these aspects of the impact assessment in context and ultimately aid the JRPs review.Figures 2-3 – 2-8 are from the November 2020 document “Marathon Palladium Project – Aquatic Environmental Baseline Report Update” (136843E.pdf (iaac-aeic.gc.ca))

Figures 5-1 and 5-2 are from the March 2021 EIS

Addendum Appendix D6: “Fish and Fish Habitat Offsetting

Plan Update” (139029E.pdf (iaac-aeic.gc.ca))

Health Canada Proposed Rail loadout route/facility in the Town of Marathon

Health Canada recommends that the Joint Review Panel

visit the proposed rail loadout route and facility in the Town

of Marathon. Multiple human receptors appear to be located

close to the area, which may be impacted by project-related

air emissions and noise (Figure 2, Receptor and Zoning

Plan, Appendix D2, PDF p. 53)

Health Canada Traditional Land and Resource Use (TLRU) and other areas in the vicinity of the Site Study Area (SSA)

Health Canada recommends that the Joint Review Panel visit the general vicinity of the SSA. Indigenous and non-Indigenous visitors may access areas within/near the project site for TLRU purposes (such as hunting, trapping, fishing and harvesting plants). Town Entrance Park and Picnic Area also appears to be partially located within the SSA. Therefore, Traditional Land and Resource Users and visitors

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may be potentially impacted by contaminated air, water and country foods as well as noise

For more details, please refer to Health Canada comment

(HC-01) in CIAR #905

Ministry of the Environment, Conservation and Parks

Proposed Process Solids Management Facility, Cell 1, Water Management Pond, Stormwater Management Pond

View pre-development conditions (stream 106)

Ministry of the Environment, Conservation and Parks;

Ministry of Northern Development, Mines, Natural Resources and Forestry

Hare Lake Surface water receiver of treated mine wastewater

Gain an understanding of existing habitat and Hare Lake’s importance/influence on aquatic and terrestrial populations when altered

Ministry of the Environment, Conservation and Parks;

Ministry of Northern Development, Mines, Natural Resources and Forestry

Slope from proposed pit to Pic River

Concerns have been raised about the topography from

proposed pit

Gain an understanding of proximity/height/weight of the mine

rock piles to the Pic River (which has an active shoreline)

Gain understanding of the water catchment around this area as it influences Stream 2 and 3, and the stability of the remnant streams and slope to the Pic River, particularly at mine closure

Ministry of the Environment, Conservation and Parks;

Pic River Not proposed receiver but of significance to local Indigenous

communities

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Ministry of Northern Development, Mines, Natural Resources and Forestry

Gain understanding of existing habitat and the Pic River’s importance/influence on aquatic and terrestrial populations when altered

Ministry of the Environment, Conservation and Parks;

Ministry of Northern Development, Mines, Natural Resources and Forestry

Stream 101, 102, 103 and 106 predicted impact areas

Several onsite streams are predicted to have significant

impacts to flow. Chance to observe baseline appearance of

the streams.

Understand existing habitat of these streams and their importance/influence on aquatic and terrestrial populations when altered

Ministry of Northern Development, Mines, Natural Resources and Forestry

Tailings effluent pipeline and discharge location

Gain understanding of effluent interaction with the aquatic environment and potential impacts in the event of a spill

Ministry of Northern Development, Mines, Natural Resources and Forestry

Proposed greenfield 115kv transmission line corridor

Gain understanding of potential disturbance to greenfield area

Ministry of Northern Development, Mines, Natural Resources and Forestry

Camp 19 access road Gain understanding of the condition of Camp 19 road, vegetation that will be cleared, and areas that will no longer be accessible by the public

MARATHON PALLADIUM PROJECT – AQUATIC ENVIRONMENT BASELINE REPORT UPDATE Previous Characterization of Existing Conditions

Ref. 20-2722 13 November 2020 2.6

Figure 2-3: Subwatershed 101 aquatic sampling stations

MARATHON PALLADIUM PROJECT – AQUATIC ENVIRONMENT BASELINE REPORT UPDATE Previous Characterization of Existing Conditions

Ref. 20-2722 13 November 2020 2.8

composition. Stations L8, L14 and L15 were classified as having fair water quality

Figure 2-4: Subwatershed 102 aquatic sampling stations

MARATHON PALLADIUM PROJECT – AQUATIC ENVIRONMENT BASELINE REPORT UPDATE Previous Characterization of Existing Conditions

Ref. 20-2722 13 November 2020 2.11

Figure 2-5: Subwatershed 103 aquatic sampling stations

MARATHON PALLADIUM PROJECT – AQUATIC ENVIRONMENT BASELINE REPORT UPDATE Previous Characterization of Existing Conditions

Ref. 20-2722 13 November 2020 2.15

Figure 2-7: Subwatershed 105 aquatic sampling stations

MARATHON PALLADIUM PROJECT – AQUATIC ENVIRONMENT BASELINE REPORT UPDATE Previous Characterization of Existing Conditions

Ref. 20-2722 13 November 2020 2.19

Figure 2-8: Subwatershed 106 aquatic sampling stations

PRELIMINARY FISH HABITAT OFFSET STRATEGY / COMPENSATION PLAN Description of Fish and Fish Habitat

Ref. 20-2722 March 2021 5.3

Figure 5-1: Summary of Fish Sampling Locations in the Project Area

PRELIMINARY FISH HABITAT OFFSET STRATEGY / COMPENSATION PLAN Description of Fish and Fish Habitat

Ref. 20-2722 March 2021 5.4

Figure 5.2: Fish Distribution in the Project Area