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Quebec, July 14, 2020

Ms. Gail Amyot
Galaxy Lithium (Canada) Inc.
2000 Peel Street, Suite 720
Montreal, Quebec  H3A 2W5

SUBJECT:   James Bay Lithium Mine Project – Responses to the second request for information (Part 1) dated March 27, 2020

Dear Ms. Amyot:

On June 18, 2020, the Joint Assessment Committee (the Committee) received the answers to the Part 1 of the second information request sent on March 27, 2020, regarding the above-mentioned project. The answers are included in the following document:

WSP, 2020. James Bay Lithium Mine Project. Answers to second information request (first part) received from the Impact Assessment Agency of Canada as part of the environmental review of the project. Report for Galaxy Lithium (Canada) Inc. 106 pages and appendices.

The Committee compared the information request to the responses. This exercise helped determine that the information provided is incomplete (see Appendix A).

As mentioned in its response document and during discussions with the Committee, Galaxy Lithium Inc. (GLI) plans to optimize its mine site development plan in fall 2020, in order to respond to certain concerns of the Committee. This optimization will result in modifications to the expected effects on certain project components and valued components (VCs) under review.

In collaboration with experts, the Committee decided to continue its technical analysis only on the project's components and VCs that do not appear to be affected by the planned optimization of the development plan and those for which all the information matched:

  • Accidents and malfunctions
  • Current use of lands and resources for traditional purposes (partial continuation of the analysis)
  • Socio-economic aspects of Indigenous peoples
  • Cree rights (partial continuation of the analysis)

The Committee could submit an additional information request to explain certain aspects and help it complete the analysis of these components. Only a partial continuation of the analysis is possible for aspects with components that could be affected by the optimization of the development plan.

Next steps

Once the optimization of the mine site development plan is complete, GLI must submit the following to the Committee:

  • An updated description of the project's components and activities, including the new mine site development plan.
  • A summary of the Indigenous consultations on this new plan, the comments received and GLI's response to these comments.
  • A detailed impact reassessment of the project's affected components and VCs, including a review of the mitigation measures, as required. The information must be clear and match the titles and subtitles used in the environmental impact statement.
  • The missing information for aspects of the second information request that do not match (Appendix A). This information must take into account the optimization of the development plan.
  • An updated table of the assessment of residual effects.
  • An updated table of mitigation measures.

The federal timelines will resume when the Committee has received all the information requested in this letter and the second part of the second information request dated July 8, 2020. The Committee is continuing its technical analysis of the above-mentioned project components and VCs. It should be noted that the Committee may submit another information request to explain certain aspects regarding the optimization of the project and the reassessment of its effects.

If you need further information or would like to discuss the requirements of the information request and information that does not match, please contact Véronique Lalande by phone at 418-455-4116 or by email at veronique.lalande@canada.ca

John Paul Murdoch
Co-Chair, Joint Assessment Committee
Cree Nation Government

Benoît Dubreuil
Co-Chair, Joint Assessment Committee
Impact Assessment Agency of Canada

c.c. [by email]:       Brian Craik, Cree Nation Government
Kelly LeBlanc, Cree Nation Government
Véronique Lalande, Impact Assessment Agency of Canada
Elisabeth Gill, Impact Assessment Agency of Canada
Isabelle Vézina, Health Canada
Camille Ouellet-Dallaire, Natural Resources Canada
Annaïg Kervella, Fisheries and Oceans Canada
Caroline Chartier, Environment and Climate Change Canada
Catherine Gaudette, Transports Canada


APPENDIX A

NON-MATCHING RESPONSES TO THE FIRST PART OF THE JOINT ASSESSMENT COMMITTEE'S SECOND INFORMATION REQUEST DATED MARCH 27, 2020

The Joint Committee is of the view that the questions below were not answered or that the answers provided did not match the expected information. It is recommended that you refer to the information request dated March 27, 2020, for more context.

Note 1: Matching the responses with the information request is not intended to be an exercise in validating the quality of the responses.

Note 2: If optimizing the development plan changes the responses submitted on June 18, 2020, including those that matched, the Proponent must provide the Committee with the revised responses when submitting other documents related to this optimization.

Question CCE-3

Hydrogeology, water management, infrastructure

The Proponent must consider the optimization of the current mine site development plan and its repercussions in its review of water management infrastructure and in the water balance of the project.

Question CCE-7

Wetlands, cumulative effects assessment for each avian species at risk

The Proponent must present an analysis of the cumulative environmental effects for each bird species at risk, considering the population and distribution objectives identified in the recovery strategies, when available. The Proponent must consider how the residual effects could merge with effects of the reasonable foreseeable projects given the reference condition of the species. This reference condition must take into account the current situation and integrate the impacts of past and current projects. In its analysis, the Proponent must consider that a minor residual effect on a species could result in a significant cumulative effect.

Question CCE-18

Human health, toxicological risk assessment, validation and toxicological follow-up

A) The Proponent must provide an outline of an environmental monitoring and follow-up program for air, water (watercourses CE2 and CE3) and traditional food (plants and meats), based on human health protection criteria to validate assumptions in the toxicological risk assessments.

Question CCE-19

Human health, noise impacts, sensitive receptors in the human environment

B) The Proponent must consider the optimization of the current mine site development plan in its noise modelling update. The Proponent must present the results of the new noise modelling study on a map indicating equal-loudness contours and land use by the Cree communities, including all representative human receptors. In addition, as explained in its response to comment 2, the Proponent plans to consider sleep disturbance, interference with speech comprehension and noise complaints in the impact assessment of noise on human health, in addition to the percentage of persons highly annoyed (%HA).

Question CCE-20

Human health, noise impacts, consideration of the noise impacts of explosions on human health

A) The Proponent must consider the optimization of the current mine site development plan in the impact assessment of noise from explosions on human health. In addition, as specified its response to comment 2, the Proponent plans to consider sleep disturbance, interference with speech comprehension and noise complaints in the impact assessment of noise on human health, in addition to the percentage of persons highly annoyed (%HA).

Question CCE-22

Human health, air quality, air quality impact assessment in view of air quality modelling updates

The Proponent must consider the optimization of the current mine site development plan in the air quality modelling. It must present its updated impact assessment on air quality for each phase of the project, including the impact of project-related transportation activities on human health.

Question CCE-37

Indigenous issues, land and resource use, joint work table on caribou

D) The Proponent must indicate how often meetings are held by the "Joint work table on caribou" during the life of the project and whether reports will be published after these meetings. If it is not currently possible for the Proponent to provide details on its follow-up measure, explain why.

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