City of Kamloops Public Comment Submission
Posted by Stop Ajax Mine on January 8th, 2015 2:20am
Many thanks to everyone who contributed comments during the Public Comment Period from November 18 to December 22. The City of Kamloops also made a submission on December 22. This was prepared by Jen Fretz, Director of Public Works and Utilities and the City’s representative on the Technical Working Group which gives input to the environmental assessment of the proposed Ajax mine. Here is the text of the submission:
RE: Review of Draft Application Information Requirements/Environmental Impact Statement Guidelines – Revision 1.B
The City of Kamloops has taken the time to review the Draft Application Information Requirements/Environmental Impact Statement Guidelines (dAIR) (revision 1.B) for KGHM Ajax Mining Inc., Ajax Project, as well as the Proponent’s responses to the questions and comments raised following the review of the June 2014 dAIR update. Based on our review, we have a number of comments and requests for the inclusion of additional information. For ease of reference, our comments/suggestions/requests are listed below based on the comment number in the Excel file titled “Ajax Revised AIR Working Group Tracking Table_23Oct 2014" as well as the corresponding section and page number in the dAIR (revision 1.B).
1. Project Description - page P2 (Comment #120)
Regarding the location of the project to City limits, the last sentence of the first paragraph states that “Some ancillary facilities, including the exploration camp, administration building, and explosives storage, may be located just within the city boundaries”. However, Section 2.2.2 on page 4 of 202 states that the primary components are proposed to be adjacent to but outside Kamloops city limits, and that the closest Project facility to the neighbourhood of Aberdeen is the EWRSF (East Waste Rock Storage Facility) at approximately 1.7 km. How does the location of the EWRSF relate to the potential location of the ancillary facilities in terms of their proximity to the Aberdeen neighbourhood?
2. Development of the AIR/EIS Guidelines - page P5 & P6 (Comment #121)
If the community associations of Aberdeen, Pineview Valley and Knutsford were adequately consulted, then why are they not included in the list of groups and agencies at the bottom of page 5, top of page 6?
B. Section 2.0 –PROJECT OVERVIEW
1. Section 2.2.2 (Project Location) - page 4 (Comment #123)
As per Comment #120, how do the locations of the EWRSF and the ancillary facilities relate to each other in their proximate distance from the neighbourhood of Aberdeen?
2. Section 2.2.5 (Environmental Management System) - page 7 (Comment #125)
As a footnote, or some other way of providing clarity, please include the definition of the term “pollution” as per the Proponent Response to Comment #125.
C. Section 3.0 - DETAILED PROJECT DESCRIPTION
1. Section 3.4.2 (Pit Design) - page 16 (Comment #128)
The Proponent indicates in their response to Comment #128 that additional description of backfill to the pit has been included in the AIR/EIS, however, there is no such additional information provided in section 3.4.2. If additional information has been included elsewhere in the dAIR, please indicate its location.
2. Section 3.4.4 (Loading and Hauling) - page 17 (Comment #129)
The proponent’s response to Comment #129 reads “The noise assessment will include all trucks and heavy equipment used on-site for air/noise modelling”. Please clarify that the air-quality assessment will also include all trucks and heavy equipment use on site for air/noise modelling.
3. Section 3.7 (Tailings Management) - page 26 (Comment #131)
In the first paragraph, why has reference to Highway 5 being removed? Also, please include a comment that all aspects of the TSF (Tailings Storage Facility) will be captured in the various management plans listed in Section 11.
4. Section 3.12 (Site Water Management) - page 33 to 35 (Comment #133)
Although the proponent’s response to Comment #133 did address effects on groundwater as a result of the MRSFs, the response did not address the issue of additional seepage which was also raised by the City.
D. Section 6.0 - ASSESSMENT OF POTENTIAL ENVIRONMENTAL EFFECTS
1. Section 6.4.4 (Potential Effects of the Project and Proposed Mitigation) - page 67 (Comment #141)
The proponent’s response addresses the issue of chemical binding agents but does not fully address the concern regarding the issue of evaporation rates. If these are to be estimated for the site as indicated in the proponent’s response, then why has “evaporation rates”been removed from the bulleted list of project activities that could affect the hydrological regime?
E. ADDITIONAL QUESTIONS AND COMMENTS
1. Cumulative Effects Assessment of Additional Minerals Rights
To ensure that any incremental development or expansion of the project beyond those set forth in the proponent’s current project design is properly addressed, the City requests that the non-project mineral deposits that the proponent owns near or within the City boundaries (i.e. Rainbow, Ajax North, Crescent, Tia Madra, Iron Mask) be assessed for cumulative effects in conjunction with the project review.
At stake for the City in this matter of future mineral development is the potential impact to the residential development area designated in the Kamloops Official Community Plan and Aberdeen Community Plans, including but not limited to potential impacts to development of these areas beyond the current proposed lifespan of the project.
2. Surface Hydrology and Groundwater Effects Study Areas
Given the significant issue of slope stability in the Aberdeen neighbourhood, it would appear that the Local Study Areas outlined for the Surface Hydrology and Groundwater assessments (Figures 6.4-1 and 6.5-1, respectively) are insufficient to adequately assess the potential impacts of the project on this sensitive area of the City.
The City’s understanding is that the boundaries need to be far enough away from the area being assessed that it does not lock the result (i.e. if a constant head boundary were placed close to an area being evaluated it would probably make the model insensitive to any changes). As the City is quite concerned about the area along Hugh Allan Drive, shouldn’t the Local Study Area boundaries be quite a bit further away?
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