Eskay Creek Revitalization Project

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Attachment Nisga'a Lisims Government - Comments on the Initial Project Description

  • Eskay Creek Revitalization Project
  • Author: Administrator on behalf of Nisga'a Lisims Government
  • Reference number: 21
  • Submitted: 2021-11-22
  • Project phase: Planning
  • Participation notice: Public Notice - Public Comments Invited on a Summary of the Initial Project Description
  • Please see the attached submission.
  • Attachment included
  • September 8, 2021 David Grace, Project Assessment Director Environmental Assessment Office PO Box 9426 Stn. Prov. Govt. Victoria, BC., V8W 9V1 Dear Mr. Grace: Re: Proposed Eskay Creek Revitalization Project We write in response to your letter dated August 3, 2021 concerning the above-noted file and the Initial Project Description (“IPD”) and Engagement Plan for the Eskay Creek Revitalization Project (“Eskay Creek”), submitted by Skeena Resources Limited (the “Applicant”) per Section 11 of the Environmental Assessment Act (2018). Based on the information provided, Nisga’a Lisims Government (“NLG”) has the following comments on the IPD and the Engagement Plan: General Comments  The IPD incorrectly assumes at page 60 that there will be no impacts from the proposed project on Nisga’a Treaty interests even though trucking of concentrate (and possibly other dangerous materials) will take place within the Nass Area and the Nass Wildlife Area. Additionally, it is difficult to determine the extent to which there may be additional impacts to Nisga’a Treaty interests as a result of shipping the ore from the Stewart area once unloaded from the trucks that have delivered it there. Given this potential for impacts to Nisga’a Treaty interests, it is the Nisga’a Nation’s view that the proposed project must undergo the assessments required under paragraphs 8(e) and 8(f) of Chapter 10 – Environmental Protection and Assessment of the Nisga’a Final Agreement (the “Treaty”).  Given the above, the IPD and the Engagement Plan fail to adequately describe the Nisga’a Nation’s Treaty interests that may be impacted and they do not set out in sufficient detail how the proponent intends to ...
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Attachment Crown-Indigenous Relations and Northern Affairs Canada - Federal Authority Advice Record for the Eskay Creek Revitalization Project

  • Eskay Creek Revitalization Project
  • Author: Administrator on behalf of Crown-Indigenous Relations and Northern Affairs Canada
  • Reference number: 17
  • Submitted: 2021-10-07
  • Please see the attached submission.
  • Attachment included
  • GCDOCS # 96975187 Federal Authority Advice Record Form Eskay Creek Revitalization Project – Skeena Resources Ltd. Please submit the form to: EskayCreek@iaac-aeic.gc.ca Agency File: 005791 Registry Reference No.: 82839 Department/Agency Crown Indigenous Relations and Northern Affairs Canada Lead IA Contact James Neary Manager, Major Projects Management Office Full Address 25 Eddy Street, 6th Floor Gatineau, Quebec K1A 0H4 Canada Mail Stop 25E-14, Floor 6 Email james.neary@canada.ca aadnc.majorprojectsecretariatgeneralinbox.aandc@canada.ca Telephone 613-355-7285 Alternate Departmental Contact Mikayla Boule 873-355-5057 1. Is it probable that your department or agency may be required to exercise a power or perform a duty or function related to the Project to enable it to proceed? If yes, specify the Act of Parliament and that power, duty or function. Not probable. 2. Is your department or agency in possession of specialist or expert information or knowledge that may be relevant to the conduct of an impact assessment of the Project? Specify as appropriate. Crown-Indigenous Relations and Northern Affairs Canada is in possession of specialist or expert information or knowledge that may benefit impact assessment or regulatory processes and may hold information relevant to the Application and/or to Crown consultation related to the proposed Eskay Creek Revitalization Project in the three (3) distinct areas listed below. a) Existing Modern Treaties, self-government agreements and other constructive arrangements between Canada and Indigenous partners: interpretation of treaty provisions, implementation of consultation obligations specified in each ...
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Attachment U.S. Environmental Protection Agency, Region 10 Comments on the Initial Project Description and Request for Substitution

  • Eskay Creek Revitalization Project
  • Author: Administrator on behalf of United States Environmental Protection Agency (EPA)
  • Reference number: 16
  • Submitted: 2021-10-01
  • Participation notice: Public Notice - Public Comments Invited on a Summary of the Initial Project Description
  • Please see the attached submission.
  • Attachment included
  • UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 10 1200 Sixth Avenue, Suite 155 Seattle, WA 98101-3188 REGIONAL ADMINISTRATOR’S DIVISION September 28, 2021 Regina Wright Director, Pacific and Yukon Region Impact Assessment Agency of Canada 757 West Hastings Street, Suite 210A Vancouver, B.C. V6C 3M2 Dear Ms. Wright: This letter provides the U.S. Environmental Protection Agency’s comments on the proposed Eskay Creek Revitalization Project (Project) in response to the Impact Assessment Agency of Canada’s (IAAC) August 18, 2021 letter to the EPA. The Project is a proposed open pit gold and silver mine and processing facility located approximately 53 miles northwest of Stewart, British Columbia (BC). The Project is in the transboundary Unuk River watershed, approximately 25 miles from the BC–Alaska border. Your letter requested EPA’s input on Federal-Provincial coordination for the Project and on the potential issues that should be addressed in a federal impact assessment, should a federal assessment be required. Federal-Provincial Coordination IAAC is seeking comment on BC’s request to substitute the provincial environmental assessment process in place of the federal impact assessment process. While the BC environmental assessment could consider impacts outside of BC, it is our understanding that the management of transboundary effects is ultimately an area of Canadian Federal jurisdiction and responsibility. Therefore, we request that IAAC conduct a federal impact assessment for this Project, in a coordinated manner with BC, to ensure that transboundary effects are fully considered. We encourage IAAC and BC to coordinate their processes to the extent ...
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Attachment Eskay Comments on Behalf of SkeenaWild Conservation Trust, Northern Confluence Initiative, and Salmon Beyond Borders

  • Eskay Creek Revitalization Project
  • Author: SW, NC, SBB submitted by Jill Weitz
  • Reference number: 15
  • Submitted: 2021-09-29 - 8:22 PM
  • Project phase: Planning
  • Participation notice: Public Notice - Public Comments Invited on a Summary of the Initial Project Description
  • Our collaborative comments are attached for your consideration. 
  • Attachment included
  • 1 Impact Assessment Agency of Canada September 29, 2021 On Behalf of SkeenaWild Conservation Trust (Terrace, BC), Northern Confluence Initiative (Smithers, BC), Salmon Beyond Borders (AK-BC) Re: Eskay Creek Revitalization Project To Whom It May Concern, We value nature, fresh water and healthy ecosystems. We are part of a network that is working to promote changes to British Columbia’s mineral development laws and mining practices to ensure they are environmentally sound, do not pollute waters, respect community decisions, and account for the costs to clean up toxic mine waste sites. We appreciate the opportunity to submit comments regarding the Eskay Creek Revitalization Project as groups who are from the northwest. We are concerned that this project will add to the cumulative effects of the region and impact transboundary waters. We have responded to a handful of the guiding questions for your consideration at this planning phase and provided a detailed appendix to the main body of this letter containing further comments regarding the Scope of Assessment, Project Design Considerations, and Potential Impacts and Environmental Monitoring at the end of this document. What is your interest in the Eskay Creek Revitalization Project? Those of us who submit these comments work to amplify the concerns of communities within British Columbia, as well as those downstream, who are impacted by and potentially impacted by mining activity within British Columbia and near British Columbia’s transboundary watersheds. We reside in Northwest B.C. and Southeast Alaska and are interested in healthy watersheds, resilient ecosystems and responsible industrial development. How ...
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Attachment Eskay Creek Revitalization Project: greenwash?

  • Eskay Creek Revitalization Project
  • Author: Dr submitted by David Heinimann
  • Reference number: 14
  • Submitted: 2021-09-24 - 12:15 PM
  • Project phase: Planning
  • Participation notice: Public Notice - Public Comments Invited on a Summary of the Initial Project Description
  • To call the "construction, operation, and closure of an open-pit gold and silver mine" a "revitalization project" is exemplary greenwash. Regardless of Skeena Resources' proposed benefit to the community in jobs and dollars, Eskay Creek is misnamed.  Why?  The only answer: to seduce with the mask of ecological concern.  Equally, terms such as "Slurry", "Tailings", "Subsidy", and "Tax Leverage" could replace "Revitalization" for other sorts of washing. The less than honest identification of the project, then, raising suspicion over its integrity. .

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Attachment Federal Authority Advice Record

  • Eskay Creek Revitalization Project
  • Author: Administrator on behalf of Employment and Social Development Canada (ESDC)
  • Reference number: 10
  • Submitted: 2021-09-07
  • Participation notice: Public Notice - Public Comments Invited on a Summary of the Initial Project Description
  • Please see the attached submission.
  • Attachment included
  • Federal Authority Advice Record Form Eskay Creek Revitalization Project – Skeena Resources Ltd. Response due by September 7, 2021 Please submit the form to: EskayCreek@iaac-aeic.gc.ca Agency File: 005791 Registry Reference No.: 82839 Department/Agency Employment and Social Development Canada Lead IA Contact Anchith Mehta Full Address 140 Promenade du Portage, Phase IV, Gatineau, Québec, K1A 0J9 Email Anchith.mehta@hrsdc-rhdcc.gc.ca Telephone 343-550-7311 Alternate Departmental Contact Andre Gossignac 1. Is it probable that your department or agency may be required to exercise a power or perform a duty or function related to the Project to enable it to proceed? If yes, specify the Act of Parliament and that power, duty or function.  No 2. Is your department or agency in possession of specialist or expert information or knowledge that may be relevant to the conduct of an impact assessment of the Project? Specify as appropriate.  ESDC is in possession of expert information related to the following fields: social development, learning, skills development, employment, unemployment, underrepresented groups, and, working conditions and workplace relations 3. Has your department or agency considered the Project; exercised a power or performed a duty or function under any Act of Parliament in relation to the Project; or taken any course of action that would allow the Project to proceed in whole or in part? Specify as appropriate.  No 4. Has your department or agency had previous contact or involvement with the proponent or other party in relation to the Project? (for example, enquiry about methodology, guidance, or data; introduction to ...
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Attachment Federal Authority Advice Record

  • Eskay Creek Revitalization Project
  • Author: Administrator on behalf of Natural Resources Canada (NRCan)
  • Reference number: 11
  • Submitted: 2021-09-07
  • Participation notice: Public Notice - Public Comments Invited on a Summary of the Initial Project Description
  • Please see the attached submission.
  • Attachment included
  • Fe deral Authority Adv ice Re cord Form Eskay Creek Revitalization Project – Skeena Resources Ltd. Re sponse due by Se ptember 7, 2021 Please submit the form to: EskayCreek@iaac-aeic.gc.ca Agency File: 005791 Registry Reference No.: 82839 Department/Agency Natural Resources Canada – Industry and Economic Analysis Division Lead IA Contact Maximilien Genest Full Address 588 Booth Street, Ottaw a, Ontario Email Maximilien. genest@nrcan-rncan.gc.ca Telephone 613-447-2597 Alternate Departmental Contact 1. Is it pr obable t hat y our depart ment or agency may be r equired t o exercis e a pow er or perf orm a duty or f unc t ion r elated t o t he Pr oject t o enable it t o pr oceed? NRCan may be a Regulat or under t he Ex plosives Ac t . Should t he Pr oponent r equire t he manuf act ur e or s t or age of ex plosives f or t he pr oject , NRCan w ill r eview t he inf ormat ion and determine w het her a lic ens e w ould be r equired 2. Is y our depar t ment or agency in pos session of specialist or ex pert inf ormat ion or know ledge t hat may be r elev ant t o t he c onduct of an impac t as sessment of t he Pr oject ? NRCan is in pos s es sion of t he f ollow ing ex pert ise: Eco n o m i c  Soc ial and ec onomic c ondit ions and s ust ainable economic dev elopment ;  Ec onomic c ondit ions of t he Indigenous peoples of Canada;  Changes t o s oc ial or economic mat t er w it hin t he legislat ive authorit y of Par liament ;  Changes in s oc ial or economic conditions and posit ive and negat ive consequences c aused by c ar r ying out t he project;  The ec onomic f eas ibilit y of mit igat ion ...
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Attachment Federal Authority Advice Record

  • Eskay Creek Revitalization Project
  • Author: Administrator on behalf of Health Canada (HC)
  • Reference number: 7
  • Submitted: 2021-09-07
  • Participation notice: Public Notice - Public Comments Invited on a Summary of the Initial Project Description
  • Please see the attached submission.
  • Attachment included
  • Federal Authority Advice Record Form Eskay Creek Revitalization Project – Skeena Resources Ltd. Response due by September 7, 2021 Please submit the form to: EskayCreek@iaac-aeic.gc.ca Agency File: 005791 Registry Reference No.: 82839 Department/Agency Health Canada (HC) Lead IA Contact Herbert Antill Full Address Sinclair Centre – Federal Tower #218 – 757 W. Hastings Street Vancouver, BC, V6C 1A1 Email herbert.antill@hc-sc.gc.ca Telephone (604) 809-7652 Alternate Departmental Contact Yota Hatziantoniou: yota.hatziantoniou@hc-sc.gc.ca Helen (Hsin-ming) Yeh: hsin-ming.yeh@hc-sc.gc.ca 1. Is it probable that your department or agency may be required to exercise a power or perform a duty or function related to the Project to enable it to proceed? If yes, specify the Act of Parliament and that power, duty or function. Not applicable 2. Is your department or agency in possession of specialist or expert information or knowledge that may be relevant to the conduct of an impact assessment of the Project? Specify as appropriate. As a federal authority, HC will provide specialist or expert information and knowledge in the Department’s possession (expertise) to support the assessment of impacts on human health from projects considered individually and cumulatively under the Impact Assessment Act (IAA). The Department provides expertise in the areas described below; it does not play a regulatory role. How the expertise provided by HC will be used in the impact assessment process will ultimately be determined by the reviewing body(ies). It should also be noted that expertise related to assessing human health that are relevant to impact assessments may be held by ...
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Attachment Federal Authority Advice Record

  • Eskay Creek Revitalization Project
  • Author: Administrator on behalf of Women and Gender Equality Canada
  • Reference number: 12
  • Submitted: 2021-09-07
  • Participation notice: Public Notice - Public Comments Invited on a Summary of the Initial Project Description
  • Please see the attached submission.
  • Attachment included
  • Federal Authority Advice Record Form Eskay Creek Revitalization Project – Skeena Resources Ltd. Response due by September 7, 2021 Please submit the form to: EskayCreek@iaac-aeic.gc.ca Agency File: 005791 Registry Reference No.: 82839 Department/Agency Department for Women and Gender Equality Canada Lead IA Contact Denise Gareau Full Address 22 Eddy St., Gatineau QC Email CFC.EvaluationImpacts-ImpactsAssessment.SWC@cfc-swc.gc.ca Telephone 819-938-1132 Alternate Departmental Contact Jessica Bialek 1. Is it probable that your department or agency may be required to exercise a power or perform a duty or function related to the Project to enable it to proceed? WAGE does not hold any regulatory power, function, or duties. 2. Is your department or agency in possession of specialist or expert information or knowledge that may be relevant to the conduct of an impact assessment of the Project? WAGE has expertise in the application of GBA Plus and intersectional analysis as well as information related to gender-based violence. 3. Has your department or agency considered the Project; exercised a power or performed a duty or function under any Act of Parliament in relation to the Project; or taken any course of action that would allow the Project to proceed in whole or in part? No. 4. Has your department or agency had previous contact or involvement with the proponent or other party in relation to the Project? (for example, enquiry about methodology, guidance, or data; introduction to the project) No. 5. Does your department or agency have additional information or knowledge not specified, above? N/A ...
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Attachment Federal Authority Advice Record

  • Eskay Creek Revitalization Project
  • Author: Administrator on behalf of Transport Canada (TC)
  • Reference number: 9
  • Submitted: 2021-09-07
  • Participation notice: Public Notice - Public Comments Invited on a Summary of the Initial Project Description
  • Please see the attached submission.
  • Attachment included
  • Federal Authority Advice Record Form Eskay Creek Revitalization Project – Skeena Resources Ltd. Response due by September 7, 2021 Please submit the form to: EskayCreek@iaac-aeic.gc.ca Agency File: 005791 Registry Reference No.: 82839 Department/Agency Transport Canada Lead IA Contact Suman Atwal Full Address Pacific Region, Environmental Services Suite 600-800 Burrard Street Vancouver, BC, V6Z 2J8 Email Sumandeep.atwal@tc.gc.ca Telephone 236-330-0321 Alternate Departmental Contact Suzanne L’Heureux – Senior Regional Environmental Supervisor Suzanne.lheureux@tc.gc.ca , 604-836-9371 1. Is it probable that your department or agency may be required to exercise a power or perform a duty or function related to the Project to enable it to proceed? If yes, specify the Act of Parliament and that power, duty or function. Transport Canada (TC) may be required to exercise a power, or perform a duty or function with respect to the Canadian Navigable Waters Act (CNWA) based on the Initial Project Description provided. Under the CNWA, the Major Works Order requires an Application for Approval for certain works on any navigable waters that meet certain criteria ( Major Works Order (justice.gc.ca). Water Control Structures are included as a Major Work if it meets the criteria set out in the Order. If the proposed structure at Tom MacKay Lake meets the following t hen an Application for Approval to TC’s Navigation Protection Program (NPP) under s.5(1)(a) of the CNWA would be required: 1 The following water control structures are designated as major works:  (a) dams that o (i) are capable of impounding at least 30 000 m3 of water, and o (ii) are at least 2.5 m high, ...
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Attachment Federal Authority Advice Record

  • Eskay Creek Revitalization Project
  • Author: Administrator on behalf of Environment and Climate Change Canada (ECCC)
  • Reference number: 8
  • Submitted: 2021-09-03
  • Participation notice: Public Notice - Public Comments Invited on a Summary of the Initial Project Description
  • Please see the attached submission.
  • Attachment included
  • Environmental Protection Operations Directorate Pacific and Yukon Region 101 - 401 Burrard Street Vancouver, BC V6C 3R2 September 3, 2021 ECPT: 21-BC-001 CIAR: 82839 Christal Nieman Project Manager, Pacific and Yukon Region Impact Assessment Agency of Canada Dear Christal Nieman: Re: Eskay Creek Revitalization Project- Federal Authority Advice Record Environment and Climate Change Canada (ECCC) received a request from the Impact Assessment Agency of Canada (IAAC) on August 9, 2021 to review Skeena Resources Ltd. (the Proponent)’s Initial Project Description for the Eskay Creek Revitalization Project (the Project). ECCC’s response to this request is included as an attachment to this letter (Annex 1: ECCC’s Federal Authority Advice Record for the Eskay Creek Revitalization Project). ECCC’s comments are founded upon departmental mandate and are related to air quality, greenhouse gases and climate change, water quality and quantity, wildlife, species at risk, migratory birds, wetlands, and environmental emergencies. Please note that ECCC provides only technical, science-based advice to support the relevant authorities in their assessment of whether the Project may result in significant adverse effects to the environment. ECCC does not review projects for regulatory compliance. Comments provided do not constitute legal advice. Following these comments will not necessarily ensure compliance with federal, provincial, and/or any other regulatory requirement. In case of discrepancy between this information and any Acts of Parliament, the Act of Parliament and associated regulations take precedence. Notwithstanding any other regulatory or ...
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Attachment Indigenous Services Canada - Federal Authority Advice Record for the Eskay Creek Revitalization Project

  • Eskay Creek Revitalization Project
  • Author: Administrator on behalf of Indigenous Services Canada
  • Reference number: 6
  • Submitted: 2021-08-30
  • Project phase: Planning
  • Participation notice: Public Notice - Public Comments Invited on a Summary of the Initial Project Description
  • Please see attached. 
  • Attachment included
  • ISC: Comments on Eskay Creek Initial Project Description 1 | P a g e Eskay Creek Revitalization Project The following comments have been provided by Indigenous Services Canada (ISC) regarding the Initial Project Description (IPD) for the Eskay Creek Revitalization Project proposed by Skeena Resources Ltd. Manager: Name: Email: Anik Guertin anik.guertin@canada.ca Project Officer(s): Name: Email: Candice Remillard-Scott candice.remillard-scott@canada.ca Elizabeth Blanchette elizabeth.blanchette@canada.ca Comment #: Page #: Section: Original: Suggested Amendment: 1 N/A 7.3.5 Socio Economic Conditions General Comment There is useful information pertaining how socio-economic conditions within the proposed Project region have evolved throughout history, and factors which have led them to evolve. However, there is little information regarding current socio-economic conditions within potentially affected communities. Example:  unemployment /underemployment rates in the region  job retention  skills and training opportunities  current regional average income  education statistics in nearby communities, etc… s2 36 4.3 Project Workforce “In 2004, the Eskay Creek Mine employed 349 people and 33% were Tahltan Nation members.” “Skeena Resources expects there will be suitably trained and It may be beneficial, if possible – to clarify whether or not Skeena Resources expects to meet certain targets in relation to Indigenous employment based on these statistics. It may also be beneficial to elaborate on how Skeena Resources will work to provide training and ...
  • Attachment included
  • Federal Authority Advice Record Form Eskay Creek Revitalization Project – Skeena Resources Ltd. Response due by September 7, 2021 Please submit the form to: EskayCreek@iaac-aeic.gc.ca Agency File: 005791 Registry Reference No.: 82839 Department/Agency Indigenous Services Canada Lead IA Contact Anik Guertin Full Address 10 Wellington St.,Gatineau, Quebec K1A 0H4 Email anik.guertin@canada.ca Telephone 613-297-3730 Alternate Departmental Contact Candice Remillard-Scott: candice.remillard-scott@canada.ca 1. Is it probable that your department or agency may be required to exercise a power or perform a duty or function related to the Project to enable it to proceed? Indigenous Services Canada is not responsible for approving or issuing licenses, permits, or authorizations for the assessments of large, proposed projects. 2. Is your department or agency in possession of specialist or expert information or knowledge that may be relevant to the conduct of an impact assessment of the Project? Indigenous Services Canada has specialized knowledge pertaining to Indigenous peoples. Areas of expertise include but are not limited to; the provision of health services, community health and wellness programs, and drinking water on First Nations reserves and other social determinants of health. Indigenous Services Canada also has information on and knowledge of Indigenous matters on Federal lands. Indigenous Services Canada has a mandate to support Indigenous people (First Nations, Inuit and Métis) in their efforts to improve social well-being and economic prosperity; to develop healthier, more sustainable communities; and to participate more fully in Canada’s political, social ...
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Attachment Fisheries and Oceans Canada - Federal Authority Advice Record for the Eskay Creek Revitalization Project

  • Eskay Creek Revitalization Project
  • Author: Administrator on behalf of Fisheries and Oceans Canada
  • Reference number: 13
  • Submitted: 2021-08-30
  • Project phase: Planning
  • Participation notice: Public Notice - Public Comments Invited on a Summary of the Initial Project Description
  • Please see attached. 
  • Attachment included
  • Federal Authority Advice Record Form Eskay Creek Revitalization Project – Skeena Resources Ltd. Response due by September 7, 2021 Please submit the form to: EskayCreek@iaac-aeic.gc.ca Agency File: 005791 Registry Reference No.: 82839 Department/Agency Fisheries and Oceans Canada Lead IA Contact Tessa Richardson Full Address 401 Burrard Street, Vancouver, BC V6C 3S4 Email Tessa.Richardson@dfp-mpo.gc.ca Telephone (604) 362-4645 Alternate Departmental Contact Stephanie Russo 1. Is it probable that your department or agency may be required to exercise a power or perform a duty or function related to the Project to enable it to proceed? If yes, specify the Act of Parliament and that power, duty or function. Death of fish and/or harmful alteration, disruption, or destruction (HADD) of fish habitat may be able to be avoided and mitigated through project design and planning. However, a uthorization under Section 34.4(2)(b) and 35(2)(b) of the Fisheries Act may be required for works, undertakings or activities that would result in death of fish or harmful alteration, disruption, or destruction (HADD) of fish habitat following avoidance and mitigation. For example, potential alteration of stream flows that affect downstream fish or fish habitat. 2. Is your department or agency in possession of specialist or expert information or knowledge that may be relevant to the conduct of an impact assessment of the Project? DFO can provide specialist or expert information or knowledge on fish and fish habit at and aquatic species at risk. 3. Has your department or agency considered the Project; exercised a power or performed a duty or function under any Act ...
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