To whom it may concern,

Enclosed past this covering letter is a report for consideration by the Impact Assessment Agency of Canada with regard to the Draft Environmental Assessment Report for the James Bay Lithium Mine Project (henceforth ‘the Project’).

These recommendations were prepared by graduate students as part of coursework for the class ENVI5001 Environmental Assessment at Dalhousie University. All the authors have been trained in the governance, substantive components, and procedural components of federal impact assessment. We bring post-graduate degrees in environmental studies and sciences and cumulative decades of work experience in environmental consulting, research, and management, and lived experience in the resource industry and frontier communities. We have analyzed Valued Components and procedural elements associated with the EIS and Draft Environmental Assessment Report and raise concerns with the quality and scope of data collection and the feasibility and adequacy of proposed mitigation measures. We present in this covering letter a summary of our recommendations with a full analytical report to follow.

Summary of recommendations

Forest fires and cumulative forest fire effects

This section evaluates the James Bay Lithium Mines (JBLM) inclusion of forest fires within its environmental impact statement (EIS). JBLM conducted a detailed inclusion of forest fire impacts on various valued components. This includes positive and negative impacts on habitat, species, and the Eastmain Cree community. Furthermore, JBLM outlined hazards and mitigation strategies to be developed in the event of a wildfire. We make four recommendations regarding forest fire inclusion in the EIS.

• Forest Fire information consolidation into a single chapter to support the development of forest fire ERP for the final EPP.
• Fire brigade expectations: fire brigade is expected to respond to wildfires, structural fires, petroleum fires, and nuclear fires which require different training standards. JBLM must ensure first responders’ realistic training and emphasize evacuation strategies to ensure staff safety.
• 35m fire break perimeter insufficient in extreme fire conditions. The Impact Assessment Agency of Canada (IAAC) should require JBLM to come up with more robust strategies for fire management that go beyond training staff and relying on fire break infrastructure.
• JBLM does not include peatland fire impacts within their forest fire review. The IAAC should request more detailed information from JBLM on the predictions, impacts, and risks associated with peatland fires.

Surface water quantity and quality

• Surface water quality and quantity is an issue in open-pit mines, but the proponent does not put enough emphasis on these valued components and does not properly address effective methods to mitigate acid rock drainage and metal leaching. The proponent could refer to literature and employ new methods that are more efficient in mitigating acid rock drainage and metal leaching.
• The project struggles in projecting true impacts of mine effluents on the surface and groundwater quality of the surrounding areas of the mine and the Eastmain River watershed in general.
• Some recommendations would be to provide raw data for better understanding of the conditions and impacts, accumulated impacts of the James Bay Lithium Mine and the Rose Lithium-Tantalum Mining Project.

The remainder of the document reports on valued components and procedural aspects the EIS, each analysis, recommendations, and supporting citations. The full document may be cited as:

Westwood, A., Innocent, S., MacKellar, A. 2022. Submission on concerns and recommendations related to the proposed James Bay Lithium Mine project east of James Bay, Quebec. Prepared for the Impact Assessment Agency of Canada. 17pp.

All coauthors consent to the public release of our work. Dr. A. Westwood, as the principal investigator and course instructor, certifies the technical soundness of the analysis and recommendations herein.

Thank you for your consideration, and we hope our recommendations can support a project and impact assessment (IA) process which is more technically sound, just, and supports long-term environmental and economic prosperity in Quebec and for the Cree Nation Government.

Dr. Alana Westwood (on behalf of the coauthors),

Assistant Professor, School for Resource and Environmental Studies

Faculty of Management, Dalhousie University, K'jipuktuk (Halifax)

Direct inquiries to a.westwood@dal.ca (mailto:a.westwood@dal.ca)