Upper Beaver Gold Project,

                                                                                                                    Agnico Eagle 

                                                                                                         Upper Beaver Gold Project

                                                                                                   Resubmitted Comments from 2021

                                                                                                                  March 7, 2022

 My name is Doug Desjardins and I live on Beaverhouse Lake. This is my primary residence. My municipal taxes classify me as residential. I do not consider myself a cottager. I know of two other property owners who also use this property as their primary residence. I consider Beaverhouse Lake and surrounding area to be a residential and recreational area.

My background has included working for the Department of Indian and Northern Affairs on the Northern Affairs side in Yellowknife Northwest Territories which at the time also included Nunavut. Northern Affairs was responsible for the administration of all Land, Water and Forests outside of municipalities. As the Environmental Impact Coordinator, I was given the task to develop a review process as was mandated under the Environmental Assessment and Review Process (EARP). The process that was developed would review all projects within its jurisdiction to determine if a significant environmental and socioeconomic impact would exist with the development of the project and make appropriate referrals to the Department of Environment EARP Office for a major review of the project. The review processes my team developed included other federal departments, the Government of the NWT, all communities impacted, indigenous groups and Hunter and Trapper Associations.

I worked closely with Proponents to provide the information they needed to navigate our process. I worked with proponents in their communications with the interested parties and coordinated information between all parties to the review. Several mining projects were reviewed using this system. I am familiar with how a Proponent should respectfully approach stakeholders and hear their concerns. This did not happen with Agnico Eagle (hereafter “the Proponent”).

The Proponent stated in its project description (Page 2 paragraph 4 under Community Engagement) to “Build a trusting relationship through dialogue and transparency as more information becomes available” and “To hold workshop meetings with cottagers to agree on collaboration modalities and validate mitigation measures planned to each phase of the project”. This did not take place as described. Meetings did take place but not as described above. The Proponent requested a review of their performance to date from the participants and they received several responses. It would be enlightening to the IAAC to request a copy of all our comments provided to them. This will confirm that I am not the only participant at these public meetings that is unhappy with the proponent’s responses and dialogue with us.

The proponent has been holding meetings with property owners on Beaverhouse Lake using video conference calls. These meetings began for me this spring. Many questions were asked of the Proponent and the responses were incomplete, misleading or just nonexistent. We were told repeatedly they could only answer questions about the advance exploration phase and not the operational phase. The result was our questions regarding our most important concerns were not answered. On three separate occasions I was told they would get back with me with an answer but never did. I was invited to meet with them at their offices at Upper Canada near Dobie. We set a time and date. When I arrived the person that invited me and set the date and time had left. Her response when I contacted her about this was that I should have asked for someone I did not know. I have never encountered a Proponent that had been so misleading and coming so close to an out and out lie.

An example is the timber operation that took place adjacent to our access road. At a meeting I believe in June or July the Proponent stated that a timber company had requested the use of their entrance and road to avoid going through Dobie a small village were Beverhouse Road begins. We discussed this development with them with the assumption the timber operation was separate from the mining project. The proponent continued the discussions without informing us of the whole truth. Once the property owners who took part in this meeting reviewed the project description that was submitted to you in September, we discovered it was the Proponents property that the timber company was clear cutting. If you look at the map entitled Preliminary Site Plan Figure B.1 the area in the lower left corner labelled “Overburden Stockpile” this is the area that was clear cut by the timber company. Overburden Stockpile is a part of the production phase and is now in place prior to the completion of the impact assessment review. Does this not undermine your agency’s review?

The Proponant gave us no indication that the timber operation was a part of the mine project.

The proponent has continued to minimize the size and scope of the project and give us a picture of the project that is very different than it is. The lack of trust in the proponent’s commitment to the transparency and integrity of the process was demonstrated at the next conference meeting with only 2 public participants taking part. I was one of them, only because I was curious.

The Proponent is anything but trusting or transparent. An example is the plan to develop a quarry. In July Proponent employees were staking land on or near a property belonging to people in our community. When approached by a landowner, the proponent employees stated they were setting up sample stations for a quarry. No plans for a quarry on the south side of Beaverhouse Lake was ever mentioned to us at these meetings or any other communication methods. When the property owner spoke with them, they asked if they could build a road on their property for the quarry. There was never any mention or discussion with us about a quarry or road. The project description was submitted to you September 2 of this year and there it is describing the possible need for a quarry; therefore, they knew about it and did not inform us. There is still no mention of access to the quarry from the mine site and a bridge or culvert at the outflow of Beaverhouse Lake is a major issue with homeowners as it may impact the lake levels. If there is a bridge at the outflow of Beaverhouse Lake the boat launch, parking area and road will need to be moved. From discussions with residents, I have heard only opposition to any move of the access road or landing. This also brings into play the legal rights of those that use the access road.

My major concerns with the mine itself are as follows:

1. Open Pit Mine.

2. Draining York Lake.

3. Diverting Misema River.

4. Noise from open pit and crushers.

5. Dust from open pit, blasting and transporting ore.

6. Beaverhouse Lake and watershed water levels.

7. The size and scope of the impacts of the mine are greater than as described.

8. Road crossing at the outflow of Beaverhouse Lake.

The Proponent knew these were the homeowners concerns since July, but they are not listed as our concerns in their project description.

I have more concerns in addition to the above list of my major issues.

There is a need for a review of a much broader impact area. The project description details the active mining area not the impacted area. The impact zone is much larger than the mine property. My place of residence is 1.5 kilometers from the east boundary of mine activity. I will be impacted by noise and dust from the open pit. The prevailing wind is from the west which places me in its path. Blasting in an open pit cannot be mitigated. Indigenous community at Misema Lake, which is 5 kilometers away, has reported hearing noise from mine activities and this is during the exploration phase not open pit and production. The Howard Lake community would be impacted should the lake levels change beyond natural occurrences. The Misema River flows into the Blanche River which has a hydroelectric generating station and active agricultural communities which use the water. The Proponent has made offers to purchase property in Dobie, a village about 9 kilometers from the mine site on our access road. Is Dobie going to be apart of a much larger project in the area that should be a part of this review? The proponent does acknowledge that the area has extensive recreational value. The York Lake area has been used for recreation since the 1920s. The Department of Natural Resources with the Ontario government has stocked trout in the Misema River system close to the mine site. The mine site is situated between Gem Lake Provencial Park and Esker Lakes Provencial Park.

Open Pit

Page 14 paragraph 7 states proponent is collecting bulk ore samples 60,000 tonnes, from underground areas at Upper Beaver Gold site. Proponent has stated underground is dangerous unless the open pit is developed. Is this not a contradiction?

Page 15 under Ongoing Activities. “Completion of detailed engineering studies and associated field investigations”, “Dewatering of the mine to allow safe access”. This information needs to be reviewed by independent experts to verify that an open pit mine is necessary for safety underground. I spoke with a miner with over 40 years’ experience, and he voiced his opinion that the open pit was not needed for safety but was an inexpensive source of ore that would offset the cost of going underground. This issue needs to be addressed by a neutral expert.

Page 16 paragraph 6 “The underground mine will expand on the historical/advanced exploration workings”. Historically no open pit was required to make underground mining viable or safe at this site.

Processing Mill and Ore Stockpiles

Page 14 paragraph 6 states exploration in the region not included in this project is ongoing and they will be bringing ore from other mines for processing. The ore from other mines and exploration not included in this project should be included in this review. Adding unknown ore without knowing its chemical make up makes mitigating impacts inaccurate at best.

Page 18 paragraph 4 Off site ore will be stockpiled locally waiting to be processed at the Upper Beaver Mill. This may impact fish in local creeks. If this is the case what is the expected life of the mill? This project is getting bigger than the Upper Beaver God Mine.

Page 18 paragraph 5 states “there is also the potential that the processing plant could also process ore trucked to the site from other compatible deposits at the same time as processing the Upper Beaver Mine ore, or potentially after the on-site ore resource is depleted.” This leaves the life of the mill open ended and raises the question of managing the increase in waste and the management of tailings. The volume could increase substantially. How do we mitigate impacts when volumes are not known?

Page 22 paragraph 5 states “Preliminary geochemical investigations indicated that these materials are not potentially acid generating” There is unknown ore sources being brought to the site for milling and tailings storage from other mines. We do not know the acid content of these unknown sources. How do we mitigate impacts without knowing their composition? These ore sources should be included in this review.

Page 39 C.6.3 Surface Water and Groundwater. The outflow of Beaverhouse Lake has been estimated as 91.5 million cubic meters per year. Why is this an estimate? Gauges measuring the flow should have been installed as soon as they knew they may need to drain York Lake. Real time measurements need to be taken with full time gauges measuring water height, velocity and volume. I have seen water levels rise and fall within the day. The Proponent is using water from Ava Lake above York Lake for their needs for exploration. They will be using water from this system for daily operations for the mill and other facilities. They intend to drain York Lake and divert Misema River the amount of water we are dealing with needs to be as accurate as is possible. We need to have measured data not estimates. Water is an important resource and should the mine with its increase in capacity require more water, what is its source? Not Beaverhouse Lake.

CONCLUSION

Open pit and diversion of the Mesima River should not take place. Major impacts will obviously take place that are not necessay. 

The proponent has plans for the region that is greater than but includes Upper Beaver Gold Mine. It includes other mines and the use of land near Dobie. It may also include an expansion of the land and water use at the mine site and surrounding area. These possible plans should be included in an Impact Assessment at the highest level.

If we take the position that every possible project mentioned in the project description will occur, the project becomes very large. The impact area would expand to include Dobie, 9 km south, include all possible mines whose ore would be processed at Upper Beaver Mill, including more roads, traffic, dust, tailings and the life of the mill. Each possible mine needs to fall within the scope of this Impact Assessment. Otherwise, the process is only reviewing pieces of the project. We cannot allow such an extensive project to receive approvals through the regulatory process alone. A large project can proceed and receive approvals with a multitude of small permits. The absence of a full high-level review would allow this to occur with regulators only reviewing small pieces of the project without a perspective of the whole.

I believe the whole has not adequately been described or delineated.

The proponent needs to disclose what lands are being purchased and explored for future development within reasonable transportation distances to Upper Beaver Mill. The proponent’s aspirations for the region including the village of Dobie need to be disclosed to this review process. Only in this manner can an accurate and meaningful Impact Assessment take place.

Thank you for this opportunity to offer my concerns and thoughts. I am grateful for your careful consideration.

Doug Desjardins

Member Metis Nation of Ontario

3636 McVittie Township 

Ontario P0K 1L0