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From the Canadian Environmental Assessment Agency to Prodigy Gold Incorporated re: Completeness Check of Response to Information Requests Related to the Environmental Impact Statement Round 1 (Parts 1 and 2) (see reference document #26)

Canadian Environmental Assessment Agency
Ontario Regional Office
55 St. Clair Avenue East
Room 907
Toronto, ON M4T 1M2

Agence canadienne d'évaluation environnementale
Bureau regional de l'Ontario
55, avenue St-Clair Est, bureau 907
Toronto (Ontario) M4T 1M2

Sent by E-mail

February 15, 2018

Mr. Kyle Stanfield
Prodigy Gold Incorporated
Box 209, 3 Dree Road
Dubreuilville, ON
P0S 1B0
Kyle.Stanfield@argonaut.com

Dear Mr. Stanfield,

SUBJECT: Outcome of completeness check of the responses provided by Prodigy Gold Incorporated to Information Requirement #1 on the Environmental Impact Statement for the Magino Gold Project.

Thank you for the response dated January 31, 2018, to Information Requirement #1 (IR-1) on the Environmental Impact Statement (EIS) for the Magino Gold Project (the Project). The Canadian Environmental Assessment Agency (the Agency) has conducted a completeness check, to form an opinion on whether the information required has been provided to enable the Agency to proceed with the environmental assessment (EA), and has concluded that the response is incomplete.

The Agency reviewed the completeness of the response to IR-1 to determine whether the responses provided by Prodigy Gold Incorporated (Prodigy) contained sufficient details and were consistent with the direction provided in IR-1. Responses to the technical questions itemized in IR-1 are necessary for the Agency to draw conclusions to support advice to the federal Minister of Environment and Climate Change on whether the Project, taking into account the implementation of any mitigation measures, is likely to cause significant adverse environmental effects, as described in Section 5 of the Canadian Environmental Assessment Act, 2012 (CEAA 2012). In addition to potential environmental effects, as described in CEAA 2012, with respect to Indigenous peoples, IR-1 also included questions to support the Agency's advice to the Minister on the potential for the Project to impact Aboriginal and/or Treaty rights.

Upon review of the response to IR-1, the Agency has concluded that the response does not meet the requirements of IR-1. The responses were incomplete with respect to a number of topics, including changes to water quality, effects to Fish and Fish Habitat, changes to air quality and effects to health and socio-economic conditions with respect to Indigenous peoples. Specifically, responses to 44 of the 135 information requirements in IR-1 (contained in Annexes 1, 2 and A1) were found to be incomplete. The main reasons for the determination of incompleteness were:…/2

  • incomplete information provided (the question was not responded to in its entirety); and/or
  • the response contained insufficient information to allow a technical review.

The Agency also notes that the response to IR-1 does not allow for a straightforward review. The reader is often referred back to the original EIS to find information, without providing a summary of the information needed to answer a particular information requirement (IR). In order to maintain a transparent process, readers (including the public and Indigenous groups) should be able to review and understand the response without being compelled to re-read the EIS in conjunction with any additional material provided in the disposition table. In order to determine if the information request has been adequately responded to, each IR must be answered directly and specifically. For an IR with multiple parts, the response must address each part clearly and separately. The response should be self-contained to the extent possible. Where references to the revised EIS are used in the response, they should be focused on the issue at hand, provide only additional information to support the response, and be summarized within the response.

Further, when responses may rely on detailed design work that is pending, conceptual information must be used to inform and complete the effects analysis, with conclusions drawn for any alternatives under consideration, where applicable. Deferral to later stages of the regulatory process to provide information such as conceptual or final designs, mitigation measures, monitoring plans, or other requested information is not acceptable.  

For the Agency to confirm that the responses are complete to proceed with the EA, all deficiencies in the response to IR-1, which are further detailed in the attached Annex 1, must be corrected prior to resubmission. Based on the nature of the comments, the Agency has determined that Prodigy must resubmit a revised IR-1 response package that addresses the original IR-1 by correcting all identified deficiencies.  

The Agency notes that the response made reference to updated EIS technical documents that were not provided with the IR-1 response. Prior to re-submitting your response, verify that all EIS documents that are posted on the Canadian Environmental Assessment Registry Internet Site (CEARIS) are the latest versions. Where they are not, provide the most up-to-date versions with errata clarifying the updates for the reader.

The outcome of this completeness check, including this letter and Annex 1, will be shared with federal authorities and Indigenous groups and will be posted on the CEARIS. Upon your submission of a revised response to IR-1, the Agency may take up to a maximum of 15 days to complete another completeness check without the timeline for the EA resuming. The timeline will resume if the Agency has not come to a conclusion after 15 days.

Following the second completeness check, the Agency will notify you in writing about the outcomes and next steps. If the Agency determines that the revised response to IR-1 has addressed the deficiencies identified in Annex 1, the Agency will begin a technical review of the response and will notify Indigenous groups of the outcome. If the deficiencies are not addressed, the Agency will notify you of the information required.

The Agency welcomes the opportunity to discuss the outcome of this completeness check with you and provide further advice on how to best address the information requirements identified. If you wish to schedule a meeting, or have questions about this completeness check, please contact me at 437-999-9046 or via email at Magino@ceaa-acee.gc.ca.

Sincerely,

Original signed by

Ian Martin
Project Manager

Attachments (1)

  1. Annex 1: Completeness check of the response to IR-1 for the Magino Gold Project Environmental Impact Statement

Annex 1: Completeness check requirements directed to the proponent

ID: CEAA-FD1
IR-1 Reference #: IE(1)-01
Complete: No
Rationale: The response does not address each sub-question of the IR.
Context and Information Required for a Complete Response:
The response does not adequately address Part A of the information requirement (IR). A rationale was not provided for the exclusion of one of the four receptors cited in the request (HHR009). Provide a rationale for the exclusion of receptor HHR009.

ID: CEAA-FD2
IR-1 Reference #: IE(1)-02
Complete:  No
Rationale: The supplementary material or changes to EIS documents or TSDs provided as part of the response is/are insufficient to adequately meet the request.
Context and Information Required for a Complete Response:
The response does not address the information requirement (IR) to provide an assessment for the effects of changes to the environment on Aboriginal peoples' socio-economic condition. The rationale that there is no use within the Project Study Area, Local Study Area and Regional Study Area is not in alignment with baseline information provided in the EIS and conclusions provided in other related assessments (for example the current use of lands and resources for traditional purposes and impacts to Aboriginal and Treaty rights).

Revise and provide a response that contains a complete assessment for the effects of changes to the environment on Aboriginal peoples' socio-economic condition in accordance with the original IR IE(1)-02.

Ensure the response is considered in IR CE(1)-01.

ID: CEAA-FD8
IR-1 Reference #: IE(1)-07
Complete: No
Rationale: The response does not address each sub-question of the IR.
Context and Information Required for a Complete Response:
The response does not adequately address Part A of the information requirement (IR).

There is no evidence that engagement activities presented Indigenous groups with description of potential adverse impacts to their rights or interests. Engagement materials show no presentation of potential adverse impacts. Only environmental effects, baseline conditions, mitigation and benefits.

The information presented in Appendix D is unwieldy and does not isolate records demonstrating and clarifying that Indigenous groups were provided the opportunity to understand potential environmental effects and impacts to their Aboriginal and Treaty rights. Furthermore, it is not clear if Indigenous communities were provided opportunities to input and validate the EIS findings related to these potential effects and impacts.

Provide the requested information in Part A of the IR. Ensure that the response clearly identifies for engagement activities:

  • Date and location;
  • Indigenous group(s) present;
  • Potentially adverse impacts presented and discussed;
  • Feedback and concerns received; and,
  • Response, action or follow-up provided.

Responses to Parts B and C are considered complete.

ID: CEAA-FD9
IR-1 Reference #: FFH(1)-01
Complete: No
Rationale: The information provided is insufficient to allow a technical review.
Context and Information Required for a Complete Response:
The response does not adequately address the information requirement (IR). The answers to Parts A and B do not provide sufficient detail to allow a technical review. Further, the effects assessment referred to in Part C does not contain the details required. Providing a reference to Chapter 7, Section 7.3.4 in order to find information about effects related to dust and metals deposition on water quality is inadequate. As noted in the context and rationale of the original IR, this section specifically states that "the interaction of dust and metals deposition on water quality is not addressed [in the EIS] pending integration with the results of the atmospheric environment".

Provide the information required in the original IR, integrating results from the assessment of changes to the atmospheric environment, at a level of detail that would allow for a technical review.

ID: CEAA-FD12
IR-1 Reference #: FFH(1)-04
Complete: No
Rationale: The response does not address each sub-question of the IR.
Context and Information Required for a Complete Response:
The response does not adequately address Part B and D of the information requirement. References are too vague to allow the reviewer to determine completeness of the response. A response was provided relating to not having a water treatment plant operating from the start of the project, but does not discuss the potential effects associated with the construction of a water treatment plant.

Provide specific references to where in the TSDs is located the discussion of uncertainty and risk involved in not treating the water. Assess the potential effects associated with the construction of a water treatment plant.

ID: CEAA-FD16
IR-1 Reference #: FFH(1)-06c
Complete: No
Rationale: The response does not address each sub-question of the IR.
Context and Information Required for a Complete Response:
The response does not adequately address Part A of the information requirement.

The summary of the main elements of the Construction Environmental Protection Plan should make reference to specific mitigation measures to manage water flows and sediment burden. Provide a discussion of the implementation of the measures, including under what circumstances the measures would be required.

The Agency recognizes that the Construction Environmental Protection Plan will only be fully developed at a later stage. However, for the purposes of the environmental assessment further detail is required about the specific mitigation measures for the management of water flows and sedimentation.

ID: CEAA-FD19
IR-1 Reference #: FFH(1)-10
Complete: No
Rationale: The response does not address each sub-question of the IR.
Context and Information Required for a Complete Response:
The response does not adequately address the information requirement.

The methodology was not provided to allow a technical review of the statement that aluminum and nitrites were artifacts of testing. As the results presented in the EIS indicate that the substances exceed CCME guidelines, it is important to ensure that the substances will not cause adverse environmental effects.

Provide the testing methodology, as requested in the original IR.

ID: CEAA-FD41
IR-1 Reference #: FFH(1)-30
Complete: No
Rationale: The information provided is insufficient to allow a technical review.
Context and Information Required for a Complete Response:
The response does not adequately address the information requirement (IR).

The original IR asked to identify areas where riparian habitat would be affected, making a distinction between habitat lost or affected due to the disposal of mine waste, the reduction of upstream catchment areas, and otherwise removed. For example, Goudreau Lake is not identified in the table referred to in the response. However land clearing is expected, and could affect riparian habitat, which is not discussed.

In projects where after the application of avoidance and mitigation measures, there is likely to be serious harm to fish, an offsetting plan must be provided. For complex projects with large and lasting impacts to habitat or death of fish, substantial planning is needed to identify appropriate offsetting measures. It is a requirement of environmental assessment to have a full understanding of the potential effects and mitigation measures for the project, including a level of detail for the offsetting plan that would provide confidence in its feasibility. Without the additional detail required from the original IR on habitat characterization and the offsetting plan, the Agency cannot validate the effects on fish and fish habitat and understand the measures proposed to mitigate potential adverse effects.

Although it is understood that final details of the offsetting plans will be completed at the regulatory phase, sufficient details are required at the environmental assessment stage in order to draw conclusions on the effects to fish and fish habitat. Revise and provide the information required in the original IR.

ID: CEAA-FD42
IR-1 Reference #: FFH(1)-31a
Complete: No
Rationale:
The information provided is insufficient to allow a technical review.
Context and Information Required for a Complete Response:
The response does not adequately address the information requirement (IR). The response re-iterates information already provided and reviewed in the EIS and does not provide any additional detail on habitat accounting and the offsetting plan.

It is a requirement of environmental assessment to have a full understanding of the potential effects and mitigation measures for the project, including a level of detail for the offsetting plan that would provide confidence in its feasibility. Without the additional detail required from the original IR on habitat accounting and the offsetting plan, the Agency cannot validate the effects on fish and fish habitat and understand the measures proposed to mitigate potential adverse effects.

Although it is understood that final details of the offsetting plans will be completed at the regulatory phase, sufficient details are required at the environmental assessment stage in order to draw conclusions on the effects to fish and fish habitat. Revise and provide the information required in the original IR.

ID: CEAA-FD43
IR-1 Reference #: FFH(1)-31b
Complete: No
Rationale:
The information provided is insufficient to allow a technical review.
Context and Information Required for a Complete Response:
The response does not adequately address the information requirement (IR).

In projects where after the application of avoidance and mitigation measures, there is likely to be serious harm to fish, an offsetting plan must be provided. For complex projects with large and lasting impacts to habitat or death of fish, substantial planning is needed to identify appropriate offsetting measures. It is a requirement of environmental assessment to have a full understanding of the potential effects and mitigation measures for the project, including a level of detail for the offsetting plan that would provide confidence in its feasibility. This is important not only to understand the mitigation measures proposed, but also any potential effects captured under section 5(2) of CEAA 2012.

Although it is understood that final details of the offsetting plans will be completed at the regulatory phase, sufficient details are required at the environmental assessment stage in order to draw conclusions on the effects to fish and fish habitat. Revise and provide the information required in the original IR.

ID: CEAA-FD44
IR-1 Reference #: FFH(1)-32
Complete: No
Rationale: The response does not address each sub-question of the IR.
Context and Information Required for a Complete Response:
The response does not adequately address Part B of the information requirement (IR). Provide the location of the suspected groundwater upwellings.
The response does not adequately address Part C of the IR. The IR required verification of the presence of brook trout spawning habitat in the McVeigh Creek system. A summary of the documentation, and any field studies (including timing and methodology) should be provided to support this conclusion.
Responses to Parts D-G will be reassessed upon revision of B and C.

ID: CEAA-FD46
IR-1 Reference #: FFH(1)-34
Complete: No
Rationale: The supplementary material or changes to EIS documents or TSDs provided as part of the response is/are insufficient to adequately meet the request.
Context and Information Required for a Complete Response:
The response does not address the information requirement. The proponent presented different adaptive management plan options for the placement of Potentially Acid Generating Rock, but has not provided a discussion of the advantages, limitations and environmental effects of each option. Provide the assessment requested in the original IR.

ID: CEAA-FD50
IR-1 Reference #: FFH(1)-38
Complete: No
Rationale: The response does not address each sub-question of the IR.
Context and Information Required for a Complete Response:
The response does not address the information requirement (IR). 

The responses to Parts A and B do not address the questions in relation to the seepage that will be diverted to the pit. It is unclear what water quality criteria will be met, and how, prior to connecting the pit to Goudreau Lake, as described in the EIS. Further, the Part B refers to "a reasonable period of time" when providing a timeline.

Revise the answer to include information on the predicted quality of pit water, and include a quantitative description of "a reasonable period of time" for meeting water quality objectives.

ID: CEAA-FD52
IR-1 Reference #: HE(1)-01
Complete: No
Rationale: The response does not address each sub-question of the IR.
Context and Information Required for a Complete Response:
The response does not adequately address Part B of the information requirement. Revise the response to describe the additional mitigation measures that would be protective of human health that can be applied if required.

The response to Part D of the information requirement defers providing additional information on follow-up information to validate predictions in relation to human health effects to a permitting process. This information must be provided during the environmental assessment phase to demonstrate how the follow-up program will verify EA predictions, recognizing that further details may be finalized as part of a permitting process.

The responses to Parts A and C of the information requirement were considered complete.

ID: CEAA-FD53
IR-1 Reference #: HE(1)-02
Complete: No
Rationale: The response does not address each sub-question of the IR.
Context and Information Required for a Complete Response:
The response does not adequately address Part C of the information requirement. Revise the response to describe the additional mitigation measures that can be applied if required.

The response to Part E of the information requirement defers providing additional information to a permitting process. This information must be provided to determine how the follow-up program will verify EA predictions, with an understanding that some details may be finalized as part of a permitting process.

The responses to Parts A, B and D of the information requirement were considered complete.

ID: CEAA-FD62
IR-1 Reference #: HE(1)-11
Complete: No
Rationale: The response does not address each sub-question of the IR.
Context and Information Required for a Complete Response:
The response does not adequately address Part A of the information requirement. Revise the response to more specifically address the question regarding off-site project vehicle traffic in the air quality assessment.

The response does not adequately address Part B of the information requirement. Revise the response to describe the additional mitigation measures that can be applied if required.

ID: CEAA-FD63
IR-1 Reference #: HE(1)-12
Complete: No
Rationale: The response does not address each sub-question of the IR.
Context and Information Required for a Complete Response:
The response defers providing additional information to a permitting process. This information must be provided to determine how the follow-up program will verify EA predictions, with an understanding that some details may be finalized as part of a permitting process. Revise the response to provide the requested information.

ID: CEAA-FD64
IR-1 Reference #: HE(1)-13
Complete: No
Rationale: The response does not address each sub-question of the IR.
Context and Information Required for a Complete Response:
The response defers providing additional information to a permitting process. However, the information requested in this IR is required as part of the EA process as well. This information must be provided to determine how the follow-up program will verify EA predictions, with an understanding that some details may be finalized as part of a permitting process. Revise the responses to provide the requested information.

ID: CEAA-FD65
IR-1 Reference #: HE(1)-18
Complete: No
Rationale: The response does not address each sub-question of the IR.
Context and Information Required for a Complete Response:
The response does not address Part B of the information requirement. Revise the response to address the questions in Part B.

The response to Part A will be re-evaluated for completeness, depending on the revised responses to IE(1)-01 Part A.

ID: CEAA-FD66
IR-1 Reference #: HE(1)-19
Complete: No
Rationale: The information provided is insufficient to allow a technical review.
Context and Information Required for a Complete Response:
The response does not address Part C of the information requirement. Revise the response to address the question.

The response to Part D of the information requirement does not provide enough information for a technical review. Revise the responses to provide the requested information. This information must be provided to determine how the follow-up program will verify EA predictions, with an understanding that some details may be finalized as part of a permitting process.

The responses to Parts A and B of the information requirement were considered complete.

ID: CEAA-FD68
IR-1 Reference #: HE(1)-21
Complete: No
Rationale: The response is incomplete or unclear in relation to environmental effects as defined in section 5 of CEAA 2012.
Context and Information Required for a Complete Response:
The response does not adequately address Part B of the information requirement. While the response indicates there are no cases where addition of Hazard Quotients would be greater than 1, the rationale of the information requirement presents a case.

The response to Part A of the information requirement was considered complete.

ID: CEAA-FD70
IR-1 Reference #: HE(1)-23
Complete: No
Rationale: The response does not address each sub-question of the IR.
Context and Information Required for a Complete Response:
The response does not adequately address Part A of the information requirement (IR). Revise the response, noting that the rationale for considering the risk "negligible" is based on CFIA 2016 which is not relevant in determining potential health risks from chemicals in country foods.

The response does not adequately address Part B of the IR. Revise the response to describe the mitigation measures that would be applied if required. Note that monitoring is not a suitable substitute for mitigation.

ID: CEAA-FD72
IR-1 Reference #: HE(1)-25
Complete: No
Rationale: The response does not address each sub-question of the IR.
Context and Information Required for a Complete Response:
The response does not adequately address Part A of the information requirement (IR). As stated in the rationale for the information requirement, revise the response to carry out an uncertainty analysis "in which the level of conservativeness is quantified for each of the input parameters and the impacts or significance to the risk estimates discussed. In this way, the risk drivers could be identified and a discussion can be provided on how well those drivers are known in the context of the site. This will allow for the risks to be put into context for the reader and also allow for the development of future monitoring activities that would focus on those risk drivers."

The response to Part B of the IR was considered complete.

ID: CEAA-FD73
IR-1 Reference #: HE(1)-26
Complete: No
Rationale: The response is incomplete or unclear in relation to environmental effects as defined in section 5 of CEAA 2012.
Context and Information Required for a Complete Response:
The response does not adequately address Part E of the information requirement (IR).
The response refers to the seepage calculations in Appendix C of TSD 6, but it is not clear how this is incorporated in the uncertainty analysis. In addition, the response does not cover expected effectiveness of the closure cover. Update the uncertainty analysis to include details on the expected effectiveness of seepage collection systems and closure covers.

The Agency notes that the table referred to in Part B of the response is misidentified. Confirm that the table containing the information on groundwater quality is in fact 7-54, not 7.2.3-4. If this is incorrect, update the response to include the information required in Part B of the original IR.

ID: CEAA-FD76
IR-1 Reference #: TW(1)-01
Complete: No
Rationale: The response does not address each sub-question of the IR.
Context and Information Required for a Complete Response:
The response does not adequately address Part A of the information requirement. Revise the response to provide a summary linking main elements of the restoration and/or closure plans to specific commitments and mitigation measures in the EIS.

The response to Part B of the information requirement was considered complete

ID: CEAA-FD82
IR-1 Reference #: TW(1)-07
Complete: No
Rationale: The response is incomplete or unclear in relation to environmental effects as defined in section 5 of CEAA 2012.
Context and Information Required for a Complete Response:
The response defers providing additional information to a permitting process. However, the information requested in this IR is required as part of the EA process and will inform the Agency's selection of mitigation measures for consideration in the Minister's decision.

Revise the response to Parts A to D to provide the requested information.

ID: CEAA-FD85
IR-1 Reference #: TW(1)-10
Complete: No
Rationale: The response does not address each sub-question of the IR.
Context and Information Required for a Complete Response:
The response refers to that of another IR, CEAA-FD76/TW(1)-01. However, the response to that IR is deemed incomplete. Moreover, it makes no reference to this, IR CEAA-FD85, or to its topic.

Revise the response to provide the requested information.

ID: CEAA-FD86
IR-1 Reference #: EA(1)-01a
Complete: No
Rationale: The response is incomplete or unclear in relation to environmental effects as defined in section 5 of CEAA 2012.
Context and Information Required for a Complete Response:
The response does not clearly identify what project activities are associated with each federal decision.

Further, the response does not make clear to the reader how effects, given as references to the EIS, are directly linked or necessarily incidental to any federal decision.

Describe the project activities associated with each federal decision that would be required for the Project and clearly identify those changes to the environment that are directly linked or necessarily incidental to each federal decision, and the effects thereof.

ID: CEAA-FD88
IR-1 Reference #: EA(1)-02
Complete: No
Rationale: The information provided is insufficient to allow a technical review.
Context and Information Required for a Complete Response:
The Agency accepts the rationale that for those structural failures, accidents and other malfunctions having potential effects limited to the PSA, which are not likely to be significant, a more detailed analysis than already provided is not required. However, for the failure of the TMF embankment, the potential impact extends beyond the PSA and therefore the information requested must be provided. Regarding the TMF embankment failure, the information provided in the response does not meet the requirements of Parts A, B and D of the information requirement.

The information provided in part C is considered complete.

ID: CEAA-FD89
IR-1 Reference #: EA(1)-03
Complete: No
Rationale: The response does not address each sub-question of the IR.
Context and Information Required for a Complete Response:
The response does not address Part A of the information requirement. Revise the response to address both questions in Part A.

The response to Part B of the information requirement was considered complete.

ID: CEAA-FD91
IR-1 Reference #: CE(1)-01
Complete: No
Rationale: The supplementary material or changes to EIS documents or TSDs provided as part of the response is/are insufficient to adequately meet the request.
Context and Information Required for a Complete Response:
The proponent has not provided a complete response to IE(1)-02, requiring an assessment of the effects of changes to the environment on Aboriginal peoples' socio-economic conditions. Therefore, it is impossible to undertake a technical review of the cumulative effects to Aboriginal people's socio-economic conditions.

This response can be reassessed once a complete response to IE(1)-02 is received. If residual effects are found in the assessment of socio-economic conditions for Aboriginal peoples, they must be carried through to the cumulative effects assessment.

ID: CEAA-FD92
IR-1 Reference #: CE(1)-02
Complete: No
Rationale: The response does not address each sub-question of the IR.
Context and Information Required for a Complete Response:
The response does not address Part A of the information requirement and the context thereof. Revise the response to address the use of relevance criteria in a clear and consistent manner for the pre-screening of all current activities.

ID: CEAA-FD94
IR-1 Reference #: CE(1)-04
Complete: No
Rationale: The response does not address each sub-question of the IR.
Context and Information Required for a Complete Response:
The response does not address Part B of the information requirement. Provide a map as requested in the original information requirement.

ID: CEAA-FD2(A1)-4
IR-1 Reference #: IE(1)-12
Complete: No
Rationale: The response does not address each sub-question of the IR.
Context and Information Required for a Complete Response:
The response does not adequately address Part A of the information requirement.

Clarify the number of stockpiles present.  Identify the third stockpile, if it exists, or provide any corrections needed to Chapter 6, Table 6-1. Appendix E shows the location of two stockpiles, as did the original figures in the EIS.

ID: CEAA-FD2(A1)-5
IR-1 Reference #: IE(1)-13
Complete: No
Rationale: The response is incomplete or unclear in relation to a major project component or physical activity and the associated environmental effects.
Context and Information Required for a Complete Response:
The response does not adequately address the information requirement. The response defers a decision on the preferred alternative for the landfill to the provincial permitting process.

Given that the proponent is unable to confirm whether an on-site landfill will be used as the preferred alternative (as identified in the alternatives assessment in Chapter 5 of the EIS), a conservative approach to effects assessment should be followed. The alternatives assessment identifies an on-site landfill as having greater environmental effects; therefore this scenario should be assessed in the EIS. Where no preferred alternative can be identified, provide a complete environmental effects analysis of the alternatives under consideration so that a significance conclusion can be reached for each.

Revise the response to include an assessment of the potential effects related to the construction, operation, decommissioning and abandonment of an on-site landfill, including mitigation measures and follow-up.

ID: CEAA-FD2(A1)-6
IR-1 Reference #: IE(1)-14
Complete: No
Rationale: The response does not address each sub-question of the IR.
Context and Information Required for a Complete Response:
The responses do not adequately address Parts B to E of the information requirement. Revise the response to specifically address the questions of the information requirement.

The response to Part A of the information requirement was considered complete.

ID: CEAA-FD2(A1)-7
IR-1 Reference #: IE(1)-15
Complete: No
Rationale: The response does not address each sub-question of the IR.
Context and Information Required for a Complete Response:
The response does not adequately address Part B of the information requirement. Revise the response to provide the information that is requested.

The response to Part A of the information requirement was considered complete. Part C will be reassessed upon revision of Part B.

ID: CEAA-FD2(A1)-9
IR-1 Reference #: IE(1)-17
Complete: No
Rationale: The response does not address each sub-question of the IR.
Context and Information Required for a Complete Response:
The response does not adequately address Part A of the information requirement. Provide updated figures as requested un the original information request.

The response does not adequately address Part C of the information requirement. Revise the response to provide the information that is requested.

The response to Part B of the information requirement was considered complete. Part D will be reassessed up revision of Parts A and C.

ID: CEAA-FD2(A1)-11
IR-1 Reference #: IE(1)-19
Complete: No
Rationale: The response does not address each sub-question of the IR.
Context and Information Required for a Complete Response:
The response does not adequately address Part E of the information requirement. Revise the response to describe the additional mitigation measures that can be applied if required.

The responses to Parts A, B, C, D and F of the information requirement were considered complete.

ID: CEAA-FD2(A1)-12
IR-1 Reference #: IE(1)-20
Complete: No
Rationale: The response does not adequately consider Agency and other federal guidance or policy documents.
Context and Information Required for a Complete Response:
The responses do not consider the guidance provided by Health Canada. Revise the responses to Part A and B to consider the guidance described in the Context and Rationale. If the guidance is not to be followed, a rationale must be provided.

ID: CEAA-FD2(A1)-13
IR-1 Reference #: IE(1)-21
Complete: No
Rationale: The information provided is insufficient to allow a technical review.
Context and Information Required for a Complete Response:
The response to Part C of the information request is insufficient for technical review. Revise the response to provide a description of expected changes to vehicular traffic on Goudreau Road, as the response to Part C indicates that some project traffic is expected to travel on the road.

The response to Part D of the information request does not adequately address the question. Revise the response to either include expected vehicular traffic on Goudreau Road, or describe the uncertainty introduced by not including the source in the noise assessment.

The responses to Parts A and B of the information requirement were considered complete. The responses to Parts E to I will be re-evaluated for completeness, depending on the revised responses to Parts C and D.

ID: CEAA-FD2(A1)-14
IR-1 Reference #: IE(1)-22
Complete: No
Rationale: The response does not address each sub-question of the IR.
Context and Information Required for a Complete Response:
The response does not adequately address Part B of the information requirement. Revise the response to describe the specific mitigation measures that can be applied if required.

The responses do not adequately address Parts E and G of the information requirement. Revise the responses to provide the requested information. This information can be provided at a conceptual level in the EA, with an understanding that final details will be established as part of the proposed committee.

The responses to Parts A, C, D and F of the information requirement were considered complete. Note that the text provided in the response to Part A is not mentioned in TSD 11, Section 5.2.1 of the EIS.

ID: CEAA-FD2(A1)-15
IR-1 Reference #: IE(1)-23
Complete: No
Rationale: The response does not address each sub-question of the IR.
Context and Information Required for a Complete Response:
The responses do not adequately address Part B and D of the information requirement. Revise the response to provide the information that is requested. This information must be provided to determine how the follow-up program will verify EA predictions, with an understanding that some details may be finalized as part of a permitting process.

ID: CEAA-FD2(A1)-24
IR-1 Reference #: GHG(1)-1
Complete: No
Rationale: The response does not address each sub-question of the IR.
Context and Information Required for a Complete Response:
The response does not adequately address Part D of the information requirement (IR).

Greenhouse gas emissions mitigation measures are not described. Provide the information required in the original IR, including a description of air quality mitigation measures and best management practices, objectives to be achieved through mitigation, the monitoring and follow-up program including objectives and measures that will be implemented to verify the predictions and evaluate the effectiveness of the proposed mitigation measures.

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