reference: fort mckay technical review of teck frontier

Teck Resources Limited Suite 1000, 205 – 9th Ave. S.E. Calgary, AB Canada T2G 0R3

+1 403 767 8551 Dir +1 403 767 8500 Tel +1 403 265 8835 Fax www.teck.com

April 15, 2016

Bori Arrobo Manager, Environmental and Regulatory Affairs Fort McKay Sustainability Department Fort McKay First Nation PO Box 10 Eagle Ridge PO Fort McMurray, Alberta T9K 2Y4 Eddison Lee-Johnson Senior Manager McKay Métis Sustainability Centre McKay Métis Community PO Box 5000 Fort McMurray, Alberta T9K 3G4

Reference: Fort McKay Technical Review of Teck Frontier Project Update and Responses to Round 4 SIRs

Dear Mr. Arrobo and Mr. Lee-Johnson: On August 17, 2015, Teck Resources Limited (Teck) received your technical reviews of the Frontier Oil Sands Mine Project Update and Teck’s response to Round 4 Supplemental Information Requests (SIRs). The technical reviews were jointly completed by the Fort McKay First Nation and McKay Métis Community. The joint review is referred to as the “Fort McKay August 2015 Statement of Concern (SOC)” throughout the enclosed document. Teck has carefully reviewed the Fort McKay August 2015 SOC and has prepared the enclosed response. Teck is providing a single response to the Fort McKay August 2015 SOC. In addition to the joint Fort McKay August 2015 SOC, the McKay Métis Community provided Métis-specific requests. Teck has responded to these requests in a dedicated portion of a technical issues table that was developed to house Fort McKay’s August 2015 SOCs and the location of Teck’s responses. Teck trusts that the enclosed response will support ongoing efforts to find mutually agreeable outcomes to issues and concerns identified by Fort McKay. Teck will discuss this response and continue its consultation efforts with the Fort McKay First Nation and McKay Métis Community individually as the Project continues to move through the regulatory review process and future stages of planning. Teck would like to take this opportunity to thank Fort McKay and its technical team for undertaking a thorough and thoughtful review of Teck’s submissions.

http://www.teck.com/

Sincerely,

Robin Johnstone General Manager, Community & Indigenous Affairs Teck Energy

Cc. Alvaro Pinto (Director, Fort McKay Sustainability Department) David Haddon (Panel Manager, CEAA) Carolyn Dunn (Crown Consultation Coordinator, CEAA) Richard Chabaylo (Director, Mining Authorizations, AER) Melody Nice (Region Lead, Lower Athabasca North, Lower Athabasca Region, Alberta Indigenous Relations) Toni Hafso (Consultation Advisor, Lower Athabasca Region, Alberta Indigenous Relations) Charlene Richards (Consultation Advisor, Lower Athabasca Region, Alberta Indigenous Relations)

<Original signed by>

Frontier Oil Sands Mine Project

Responses to Fort McKay's Statements of Concern Regarding the Project Update and Round 4 SIR Responses (Received August 2015)

April 2016

FRONTIER OIL SANDS MINE PROJECT TABLE OF CONTENTS

RESPONSES TO FORT MCKAY SOCS – APRIL 2016 Page i

Table of Contents

List of Tables .................................................................................................................................. v List of Figures ................................................................................................................................. v Abbreviations ................................................................................................................................ vii 1 Introduction ............................................................................................................................... 1

1.1 Overview ............................................................................................................................ 1 1.2 Approach and Format of SOC Responses ......................................................................... 2 1.3 Fort McKay Technical Issues Table .................................................................................. 2

2 Key Themes ............................................................................................................................... 5 2.1 Adequacy of the Environmental Impact Assessment ........................................................ 5

2.1.1 Assessment Methods and Completeness ................................................................6 2.1.2 Additional Baseline Data ........................................................................................7 2.1.3 Assessment Methodology .......................................................................................8 2.1.4 Conservatism...........................................................................................................9 2.1.5 Reversibility Criteria ...............................................................................................9 2.1.6 Modelling Methods ...............................................................................................10 2.1.7 Additional Assessment Work ...............................................................................11 2.1.8 Appropriate Stage of Engineering ........................................................................11

2.2 Management, Mitigation and Monitoring ........................................................................ 12 2.2.1 Project Definition Phase .......................................................................................14 2.2.2 Project Execution Planning Phase ........................................................................19 2.2.3 Implementation, Monitoring and Adaptive Management Phase ..........................20

2.3 Climate Change ................................................................................................................ 22 2.3.1 Project Greenhouse Gas Emissions ......................................................................23 2.3.2 Potential Climate Change Effects on the Project ..................................................24 2.3.3 Incorporating Future Climate Scenarios ...............................................................24

2.4 Agreement and Regulator Requests ................................................................................. 27 2.4.1 Agreement Requests .............................................................................................28 2.4.2 Regulator Requests ...............................................................................................29

3 SOC Responses ........................................................................................................................ 31 Cumulative Effects .................................................................................................................. 31

SOC 1 ..............................................................................................................................31 SOC 2 ..............................................................................................................................31

Access Management ............................................................................................................... 32 SOC 3 ..............................................................................................................................32

Traditional Land Use .............................................................................................................. 33 SOC 4 ..............................................................................................................................33 SOC 5 ..............................................................................................................................34 SOC 6 ..............................................................................................................................34 SOC 7 ..............................................................................................................................35


RESPONSES TO FORT MCKAY SOCS – APRIL 2016 Page ii

SOC 8 ..............................................................................................................................36 SOC 9 ..............................................................................................................................36

Wildlife ................................................................................................................................... 37 SOC 10 ............................................................................................................................37 SOC 11 ............................................................................................................................37 SOC 12 ............................................................................................................................38 SOC 13 ............................................................................................................................38 SOC 14 ............................................................................................................................40 SOC 15 ............................................................................................................................40 SOC 16 ............................................................................................................................40 SOC 17 ............................................................................................................................41 SOC 18 ............................................................................................................................42 SOC 19 ............................................................................................................................42 SOC 20 ............................................................................................................................43 SOC 21 ............................................................................................................................43 SOC 22 ............................................................................................................................45 SOC 23 ............................................................................................................................46 SOC 24 ............................................................................................................................48 SOC 25 ............................................................................................................................50 SOC 26 ............................................................................................................................51

Noise ....................................................................................................................................... 52 SOC 27 ............................................................................................................................52 SOC 28 ............................................................................................................................53

Air Quality .............................................................................................................................. 54 SOC 29 ............................................................................................................................54 SOC 30 ............................................................................................................................55 SOC 31 ............................................................................................................................55 SOC 32 ............................................................................................................................56 SOC 33 ............................................................................................................................57

Groundwater ........................................................................................................................... 58 SOC 34 ............................................................................................................................58 SOC 35 ............................................................................................................................58 SOC 36 ............................................................................................................................59

Hydrology/Surface Water ....................................................................................................... 60 SOC 37 ............................................................................................................................60 SOC 38 ............................................................................................................................60 SOC 39 ............................................................................................................................60

Water Quality, Fish and Fish Habitat ..................................................................................... 61 SOC 40 ............................................................................................................................61 SOC 41 ............................................................................................................................61 SOC 42 ............................................................................................................................62 SOC 43 ............................................................................................................................62


RESPONSES TO FORT MCKAY SOCS – APRIL 2016 Page iii

SOC 44 ............................................................................................................................63 SOC 45 ............................................................................................................................64 SOC 46 ............................................................................................................................64 SOC 47 ............................................................................................................................64 SOC 48 ............................................................................................................................65 SOC 49 ............................................................................................................................67 SOC 50 ............................................................................................................................67 SOC 51 ............................................................................................................................69 SOC 52 ............................................................................................................................69 SOC 53 ............................................................................................................................70 SOC 54 ............................................................................................................................71 SOC 55 ............................................................................................................................72 SOC 56 ............................................................................................................................74 SOC 57 ............................................................................................................................76 SOC 58 ............................................................................................................................79 SOC 59 ............................................................................................................................81 SOC 60 ............................................................................................................................82 SOC 61 ............................................................................................................................83 SOC 62 ............................................................................................................................84 SOC 63 ............................................................................................................................84

Vegetation and Wetlands ........................................................................................................ 85 SOC 64 ............................................................................................................................85 SOC 65 ............................................................................................................................85 SOC 66 ............................................................................................................................85 SOC 67 ............................................................................................................................86 SOC 68 ............................................................................................................................87 SOC 69 ............................................................................................................................88 SOC 70 ............................................................................................................................88 SOC 71 ............................................................................................................................88 SOC 72 ............................................................................................................................89 SOC 73 ............................................................................................................................89 SOC 74 ............................................................................................................................90 SOC 75 ............................................................................................................................90 SOC 76 ............................................................................................................................91 SOC 77 ............................................................................................................................91

Biodiversity ............................................................................................................................. 92 SOC 78 ............................................................................................................................92 SOC 79 ............................................................................................................................92

Human Health ......................................................................................................................... 93 SOC 80 ............................................................................................................................93 SOC 81 ............................................................................................................................95 SOC 82 ............................................................................................................................96


RESPONSES TO FORT MCKAY SOCS – APRIL 2016 Page iv

SOC 83 ............................................................................................................................96 SOC 84 ............................................................................................................................97 SOC 85 ............................................................................................................................98 SOC 86 ............................................................................................................................99 SOC 87 ..........................................................................................................................101 SOC 88 ..........................................................................................................................102 SOC 89 ..........................................................................................................................103

Tailings Management ............................................................................................................ 104 SOC 90 ..........................................................................................................................104 SOC 91 ..........................................................................................................................105 SOC 92 ..........................................................................................................................106 SOC 93 ..........................................................................................................................107 SOC 94 ..........................................................................................................................110 SOC 95 ..........................................................................................................................111 SOC 96 ..........................................................................................................................112 SOC 97 ..........................................................................................................................113

Conservation and Reclamation Plan ..................................................................................... 114 SOC 98 ..........................................................................................................................114 SOC 99 ..........................................................................................................................115 SOC 100 ........................................................................................................................115 SOC 101 ........................................................................................................................115 SOC 102 ........................................................................................................................116 SOC 103 ........................................................................................................................116 SOC 104 ........................................................................................................................117 SOC 105 ........................................................................................................................118 SOC 106 ........................................................................................................................118 SOC 107 ........................................................................................................................119 SOC 108 ........................................................................................................................120 SOC 109 ........................................................................................................................120

Cultural Impact Assessment ................................................................................................. 121 SOC 110 ........................................................................................................................121 SOC 111 ........................................................................................................................122 SOC 112 ........................................................................................................................123 SOC 113 ........................................................................................................................124 SOC 114 ........................................................................................................................125 SOC 115 ........................................................................................................................126 SOC 116 ........................................................................................................................127 SOC 117 ........................................................................................................................128

4 Closing .................................................................................................................................... 129


RESPONSES TO FORT MCKAY SOCS – APRIL 2016 Page v

List of Tables

Table 1-1 Fort McKay Technical Issues Table – Structure and Content Description ..........4 Table 2-1 Key Themes ..........................................................................................................5 Table 2-2 Phased Development of Project Management, Mitigation and

Monitoring Plans and Programs..........................................................................13 Table 2-3 Influence of Regulatory and Community Engagement Processes on

Project Plans to Date ...........................................................................................16 Table 13-1 Breeding Bird Survey Effort in the Terrestrial LSA ...........................................39 Table 21-1 Measured versus Predicted Aquatic Plant Concentrations .................................44 Table 23-1 Moose and Small Mammal COPC Concentrations, Base Case and

Application Case .................................................................................................47

List of Figures

Figure 2-1 Planning Schedule for the Frontier Oil Sands Mine Project ...............................15 Figure 93-1 Annual River Water Requirements ...................................................................109


RESPONSES TO FORT MCKAY SOCS – APRIL 2016 Page vi

FRONTIER OIL SANDS MINE PROJECT ABBREVIATIONS

RESPONSES TO FORT MCKAY SOCS – APRIL 2016 Page vii

Abbreviations

7Q lowest 7-day consecutive average flow, measured at various intervals (e.g., 7Q2=2-year and 7Q10=10 year)

95UCLM 95% upper confidence limit of the mean ACB Alberta Cancer Board AEMERA Alberta Environmental Monitoring, Evaluation and Reporting Agency AEP Alberta Environment and Parks AER Alberta Energy Regulator AHS Alberta Health Services AMP access management plan BATEA best available technology economically achievable bbl barrel, petroleum (42 U.S. gallons) BCF bioconcentration factor CALA Canadian Association for Laboratory Accreditation Inc. CBM community-based monitoring CC&R closure, conservation and reclamation CCME Canadian Council of Ministers of the Environment CEAA Canadian Environmental Assessment Agency CEB chronic effects benchmark CEMA Cumulative Environmental Management Association CEQG Canadian Environmental Quality Guidelines CFOP conceptual fisheries offsetting plan CO2e carbon dioxide equivalent COPC chemical(s) of potential concern COSIA Canada’s Oil Sands Innovation Alliance DFO Fisheries and Oceans Canada DFOP detailed fisheries offsetting plan EIA environmental impact assessment EPEA (Alberta) Environmental Protection and Enhancement Act ERCB Energy Resources Conservation Board ESRD (Alberta) Environment and Sustainable Resource Development ETA external tailings area ETMF exposure and toxicity-modifying factor FHCL fish habitat compensation lake Fort McKay Fort McKay First Nation and the McKay Métis Community GHG greenhouse gas ha hectare HADD harmful alteration, disruption or destruction HHRA human health risk assessment HIA health impact assessment HIV human immunodeficiency virus

FRONTIER OIL SANDS MINE PROJECT ABBREVIATIONS

RESPONSES TO FORT MCKAY SOCS – APRIL 2016 Page viii

HQ hazard quotient HU habitat unit JME Jackpine Mine Expansion JRP Joint Review Panel kt kilotonnes LSA local study area mg/kg-dw milligrams per kilogram dry weight mg/kg-ww milligrams per kilogram wet weight Mm³ million cubic metres Mt megatonnes NOX oxides of nitrogen (NO, NO2) (gas), or all nitrogen species (e.g., NOx, N2O, N3O) NPI net positive impact PAH polycyclic aromatic hydrocarbon PAI potential acid input PDA Project disturbance area PDC Planned Development Case RAMP Regional Aquatics Monitoring Program RNV range of natural variability ROPC receptor(s) of potential concern RSA regional study area SCR selective catalytic reduction SIR supplemental information request SOC statements of concern SSD species sensitivity distribution Teck Teck Resources Limited the Project Frontier Oil Sands Mine Project TOR terms of reference TRG tissue residue guideline TUa acute toxicity unit TUc chronic toxicity unit U.S. EPA United States Environmental Protection Agency WBEA Wood Buffalo Environmental Association WHRA wildlife health risk assessment WMMP wildlife mitigation and monitoring plan WQG Water Quality Guideline

FRONTIER OIL SANDS MINE PROJECT 1 INTRODUCTION

RESPONSES TO FORT MCKAY SOCS – APRIL 2016 Page 1

1 Introduction

1.1 Overview

In 2011, Teck Resources Limited (Teck) submitted an Integrated Application to the

Energy Resources Conservation Board (ERCB) and Alberta Environment and

Sustainable Resource Development (ESRD) for the Frontier Oil Sands Mine Project (the

Project). The Project was referred to a federal review panel in 2012. Federal and

provincial reviewers subsequently provided four rounds of supplemental information

requests (SIRs) prior to Teck filing a Project Update in June 2015.

At the request of Fort McKay First Nation and the McKay Métis Community, Teck

funded joint technical reviews of the Integrated Application, and Teck’s response to

Round 1 SIRs. The most recent joint technical review focuses on the Project Update and

Teck’s responses to the Round 4 SIRs. This review was received by Teck in August 2015

and is responded to here. Joint technical reviews and information requests submitted by

Fort McKay First Nation and the McKay Métis Community (hereafter “Fort McKay”) are

referred to here as statements of concern (SOCs).

In December 2013, Fort McKay provided a letter to the Canadian Environmental

Assessment Agency (CEAA) informing the Agency that Teck agreed to provide

additional information sought by Fort McKay directly to Fort McKay. As such, Fort

McKay did not have any comments for the Agency on the sufficiency of the information

provided by Teck to date. Since December 2013, Teck has continued to work directly

with Fort McKay to resolve outstanding concerns regarding the Project.

Teck recognizes that responding to a concern is not the same as addressing or resolving

it. As stated throughout the regulatory process, Teck has carefully considered and

incorporated feedback from Fort McKay into Project planning and into the environmental

impact assessment (EIA). This was done within Project needs and constraints and while

meeting the provincial terms of reference and federal requirements for the Project. Teck

remains committed to continue working through outstanding issues with Fort McKay.

Teck is confident that this response package is complete and provides an appropriate

level of detail in response to the Fort McKay August 2015 SOCs (see Section 3). As part

of this submission, Teck has also considered previous SOCs and has provided a technical

issues table (see Section 1.3). The approach and format of Teck’s responses, and the key

elements of this submission, are summarized below.



1.2 Approach and Format of SOC Responses

In determining how best to respond to Fort McKay regarding the August 2015 SOCs,

Teck’s approach was to first:

• review its previous responses to SOCs

• consider how these SOC responses have been incorporated into other regulatory

submissions for the Project

• evaluate whether an issue remains relevant given changes to the Project plan

During its review, Teck identified overarching themes in the SOCs provided to date.

These ‘key themes’ are described in Section 2 and provide an opportunity to discuss

related concerns. The key theme responses provide a basis from which to facilitate and

focus future discussions with Fort McKay. Where an issue does not align with a key

theme, or requires a technical explanation, a separate and specific response to the SOC is

provided in Section 3.

Some of the SOCs Teck received from Fort McKay prior to the Project Update are

specific to an aspect of the Project that has changed substantially (e.g., tailings

management strategy) or no longer exists (e.g., the south development area). In these

instances, Teck indicates that the concern or issue is no longer relevant.

Teck’s response to previous Fort McKay SOCs and the August 2015 SOCs are compiled

and summarized in a Fort McKay technical issues table (see Section 1.3). This table uses

the same format as the technical issues table provided in Volume 1, Appendix 17A of the

Project Update. The technical issues table can be sorted and filtered by discipline and

theme and concords similar issues. Teck’s intent in providing this table is to work

through these SOCs with Fort McKay to reach mutually satisfying outcomes. Teck trusts

that providing responses in venue will best support efforts to resolve SOCs.

1.3 Fort McKay Technical Issues Table

The technical issues table is an Excel workbook that has four worksheets:

• Legend and User Guide – Provides information to assist users in navigating the

table and sorting information in a manner that meets specific needs and interests.

• 2015 SOCs – Identifies joint Fort McKay technical issues and SOCs in the most

recent SOC package (August 2015) and cross-references Teck’s responses.

• 2015 Métis Requests – Identifies Métis community-specific requests and

cross-references Teck’s responses.

• 2012–2014 SOCs – Identifies technical issues and SOCs in previous Fort McKay

reviews (from 2012 to 2014) and cross-references Teck’s responses.



The 2015 SOC worksheet reflects the most recent engagement with Fort McKay. The

2012–2014 SOC worksheet reflects an earlier stage of engagement and therefore does not

reference the Round 5 SIR responses when identifying the location of Teck’s response.

The SOC worksheets have an identical format that is largely consistent with the format of

the technical issues table provided in Volume 1, Appendix 17A of the Project Update.

The only exception is that the updated table includes two additional columns that make it

easier to locate Fort McKay technical issues and concerns and the corresponding SOC

responses. Table 1-1 illustrates the format of the technical issues table with the new

columns and titles highlighted in bold text.



Table 1-1 Fort McKay Technical Issues Table – Structure and Content Description

COLUMN A COLUMN B COLUMN C COLUMN D COLUMN E COLUMN F COLUMN G COLUMN H COLUMN I

SOC Date Source Document or Consultant

TECK Assigned SOC No.

Discipline Theme(s) Type of Concern

Relates to SIR (Round and #) and SOC from 2012

SOC Text Location of Teck Response

Month and Year of SOC (e.g., F2013 = February 2013)1

Source of Fort McKay SOC1

Teck sequential numbering of SOCs

Primary technical discipline

Themes are used to describe and categorize issues. These are different than Key Themes

Types of concern include: information requests, methodology, mitigation, monitoring, and impacts

SIRs that correspond with an SOC are provided here, if identified

Copied from Fort McKay submissions

Location of Teck’s response to the SOC

NOTE: 1 See legend and user guide in the Fort McKay technical issues table for all SOC abbreviations.

To manage the size and usability of the technical issues table, the table references the location of Teck’s response but does not

include the response. Column I (“Location of Teck Response”) directs the reader to one of the following:

• Section 2 of this document, which includes all key theme responses to SOCs

• Section 3 of this document, which includes all individual responses to SOCs

• a previous Teck response to an SOC

• a specific volume, section or other location within a regulatory submission for the Project where an SOC was considered or

responded to

FRONTIER OIL SANDS MINE PROJECT 2 KEY THEMES


2 Key Themes

Based on its review of Fort McKay SOCs provided for the Project, Teck identified four

key themes (see Table 2-1) that it believes are best addressed with a comprehensive,

collective response. Key theme responses are presented in the following subsections.

Teck hopes that identifying and responding to key themes will help facilitate and focus

future discussions with Fort McKay.

Table 2-1 Key Themes

Key Theme Description

Adequacy of the Environmental Impact Assessment

Issues and concerns related to the adequacy of the EIA for the Project, including but not limited to, baseline data, assessment methodology, and desire for additional assessment work.

Management, Mitigation and Monitoring Issues and concerns related to the desire for detailed engineering design, management and mitigation plans, and monitoring programs.

Climate Change Issues and concerns related to Project design, operation and closure that could be affected by certain climate change scenarios.

Agreement and Regulator Requests SOCs associated with a suggested activity (mitigation or monitoring) that Fort McKay might want to consider in its Agreement negotiations with Teck and SOCs associated with a recommendation to the regulators.

2.1 Adequacy of the Environmental Impact Assessment

Several of the SOCs Teck has received from Aboriginal communities and stakeholders

relate to the adequacy of the environmental impact assessment (EIA) completed for the

Frontier Project. These SOCs focus on the adequacy of baseline data, assessment

methodology, modelling methods and level of engineering detail provided in the

Integrated Application and other regulatory submissions. Teck’s views on the adequacy

of the EIA, its methods and completeness are discussed in this response.

Based on a thorough review of the provincial terms of reference (TOR), federal

requirements and clarifications, and past oil sands EIAs, Teck is confident that (i) the

Project application meets all regulatory requirements, and (ii) the EIA is complete and

ready to proceed to the Joint Review Panel (JRP) process.

Teck’s application for the Project is based on an appropriate level of engineering at this

stage of the development, and it reflects relevant regulations and reference documents. In

preparing its application, Teck:

• adhered to the provincial TOR, the federal requirements and clarifications, relevant

legislation, policies, regulations and directives

• considered technical guidance documents, applicable environmental criteria

(including guidelines, thresholds and objectives), industry best practice documents,



regional environmental frameworks, past oil sands applications, and information and

preferences gathered through consultation with potentially affected Aboriginal

communities and stakeholders

Teck is confident that the quantity and quality of baseline data collected to inform the

Integrated Application and Project Update is sufficient to meet provincial TOR

requirements, support the EIA, and provide regulators, Aboriginal communities and

stakeholders with adequate and appropriate information about current and expected

environmental and socio-economic conditions in the Project area and region.

The assessment methods used in the Integrated Application and Project Update provide

appropriate and robust EIA findings. Further assessment work beyond what has been

included in the Integrated Application, Project Update, five rounds of SIRs and these

current SOC responses would not substantially assist or improve the assessment or

understanding of the Project, nor would it yield substantially different conclusions. Any

remaining differences of opinion about assessment methods, the scope or adequacy of

data collected in support of the Project, or other concerns about the assessment’s

completeness should be discussed within the JRP process.

2.1.1 Assessment Methods and Completeness

As indicated, many of the SOCs Teck has received relate to the adequacy of the EIA

conducted for the Project and the completeness of Teck’s responses to SIRs. Where

possible and appropriate, Teck has provided clarification and additional information in its

response to specific concerns and information requests (see Section 3). However, some

SOCs that question the adequacy of the EIA reflect differences of professional opinion or

preferred assessment methods. Other SOCs are inconsistent with regulatory guidance or

standard practice for oil sands EIAs. Teck will continue to work with Aboriginal

communities and stakeholders to better understand their perspectives; however, Teck is

confident that all TOR requirements have been adequately met and that the EIA is

complete.

Teck considered a large quantity of reference documents in developing its EIA approach.

It also incorporated important information from local and diverse sources such as:

• traditional knowledge

• environmental data from the oil sands region

• recent and relevant scientific literature

• input and advice from initial and ongoing engagement with regulators, Aboriginal

communities and stakeholders



The Project Update further enhanced the thoroughness of the assessment because it

incorporated additional baseline data, emerging science, new regulations, and additional

traditional knowledge. For a complete list of reference documents considered in

developing the EIA approach and methods, see the list of references provided at the end

of each assessment section in the Project Update.

Among the many reference documents Teck reviewed and considered were regulatory

applications and hearing transcripts for other developments in the region. Previous EIAs

and JRP decision reports provided valuable insight into the type of information needed

and the level of effects analysis regulators require to be able to determine whether the

Project is likely to cause significant adverse environmental effects, understand the

benefits of the Project, and ultimately decide whether it is in the public interest. Teck also

sought early federal involvement in the review process to provide federal regulators with

the opportunity to participate in the review process from the first Project filing.

Since detailed, project-specific guidance is not available for all aspects of an EIA,

practitioners must apply judgement based on best available information and professional

opinion. Teck has assembled a credible and experienced technical team that has

completed an appropriate and robust EIA for the Project. Teck’s team of consulting

professionals has been involved in nearly every oil sands mine application approved in

Alberta in the past 15 years, which brings a depth of experience and knowledge on key

issues and regional concerns. This level of consultant expertise is supported by Teck’s

more than 100 years mining history and global experience completing EIAs for mining

developments in various jurisdictions and environmental settings since this type of

assessment has been required. Based on all these factors, Teck’s technical team is

eminently qualified to provide professional judgement as needed to support the effects

analysis and conclusions provided in the Integrated Application and Project Update.

2.1.2 Additional Baseline Data

Teck has received a number of requests for additional (or different) baseline data,

including toxicity data, snow survey data, soil inspection points, noise monitoring, socio-

economic data, and invertebrate data. Teck has carefully evaluated each of these requests

and considered the benefit of gathering additional information against the effort, cost and

perceived value of this information. At this stage of the process, additional data gathering

is warranted only if it would improve the application or add environmental value.

Based on this evaluation, additional baseline surveys were conducted after the Integrated

Application was filed and this information was used to inform the Project Update. The

Project Update also incorporated, where possible, information from traditional land use

and knowledge studies that were provided to Teck after the Integrated Application was

filed.



Overall, the body of site-specific environmental data collected since 2008 to support

Teck’s Application for the Project is more than what has been done for other approved

applications in the oil sands region. The quantity and quality of baseline data collected to

inform the EIA for the Project (as submitted in the Integrated Application and Project

Update) meets or exceeds the TOR requirements. Accordingly, Teck’s view is that

additional baseline data is not required to complete the EIA.

Teck understands that some reviewers have an alternate opinion about the adequacy of

the baseline data collected for the EIA, and Teck respects the right of reviewers to offer

opinion on scope and methodology of baseline data collection. Teck will discuss

opportunities for preconstruction baseline monitoring with Aboriginal communities and

stakeholders and will consider monitoring activities that are important to them. However,

it is ultimately the responsibility of Alberta’s Energy Regulator (AER) to determine

whether the EIA is complete, and the role of the JRP to determine, on the basis of the

evidence and argument, whether the assessment methods used by Teck are appropriate.

2.1.3 Assessment Methodology

Some SOCs regarding the Project Update and Teck’s SIR responses express concern

about conservatism and how it relates to the assessment, concerns about reversibility, and

differences of opinion related to assessment assumptions, modelling, issue screening,

statistical analysis and parameter selection. It is Teck’s position that the assessment

methods selected for the Integrated Application and Project Update are appropriate and

provide robust EIA conclusions that regulators can rely on to make decisions, and that

support consultation and engagement with Aboriginal communities about potential

Project effects.

As indicated, the EIA methods were selected to meet the TOR for the Project and

considered relevant reference documents. Since detailed, project-specific guidance is not

available for all aspects of an EIA, practitioners applied judgement based on available

science and professional opinion as is common practice. When selecting assessment

methods, the practitioners balance a number of factors to make a final selection,

including regulatory requirements, scientific rigor, regulator acceptance, stakeholder

input, data availability, practicality and regulatory precedence. It is ultimately the

responsibility of AER to determine whether the EIA is complete, and the role of the JRP

to determine, on the basis of the evidence and argument, whether the assessment methods

used by Teck are appropriate.



2.1.4 Conservatism

Teck has received SOCs that request that modelling methods be revised to remove

excessive conservatism. These requests are based on Teck occasionally identifying that

predicted guideline exceedances are due to conservativeness inherent in the assessment

that can be verified as being conservative by operational monitoring. On this basis, Teck

justifies that the exceedance is not a concern requiring mitigation. Teck recognizes that

there are some disadvantages in overpredicting potential environmental effects; however,

it believes that these consequences are outweighed by the benefits—so long as

assumptions and reasons for the conservatism are clearly stated and understood. Teck has

identified where the EIA is conservative and has provided the appropriate rationale. The

level of conservatism built into each aspect of the EIA was set according to the certainty

in the modelling approach and input data used in the assessment, so that predictions were

not underestimated.

Conversely, several SOCs request that modelling methods be revised to increase

conservativeness. These requests stem from concerns that Teck has not adequately

considered possible adverse outcomes because (i) generic criteria have not been

considered, or (ii) insufficient safety factors have been applied. It is Teck’s position that

the EIA is appropriately conservative because it was informed by guidance documents

and the opinion of experienced professionals (see Section 2.1.1). On balance, some SOCs

request that Teck remove conservativeness and others add conservativeness. Teck

believes the assessment achieved the right balance between the two.

Teck believes that the EIA provides an appropriately conservative assessment of possible

effects and does not intend to reassess conservatism built into models. However, as part

of planning for post-approval monitoring, Teck will identify opportunities to verify and

refine predictions. For additional information about management, mitigation and

monitoring plans for the Project, see Key Theme – Management, Mitigation and

Monitoring (Section 2.2).

2.1.5 Reversibility Criteria

Reversibility is a key criterion required under federal EIA guidance, and several SOCs

focus on reversibility criteria for the effects classification. The approach to reversibility

used in the EIA is similar to proven methods used in previous EIAs in the region,

including those used for existing oil sands mines approved through a JRP process.

Concerns about reversibility tend to focus on (i) whether environmental components are

truly reversible, and (ii) whether effects are likely to be reversed in the timelines

considered by the EIA.



Teck has acknowledged these concerns by conservatively considering a predevelopment

reference condition and by not considering reclamation in prediction outcomes in the

traditional land use assessment. Although Teck considers this approach overly

conservative (see Section 2.1.4), it opted to use this approach in the effects assessment

because it reflects Aboriginal community preferences.

Teck has a successful track record and has received widespread recognition regarding its

ability to reverse the effects of mining at historic and operating properties. As such, Teck

is confident that equivalent land capability will be established when mining is complete.

Through its adaptive management process, Teck will monitor mitigation success and the

progress of reversible components. This process will enable Teck to adjust mitigation

based on observed conditions and evolving societal preferences. For more information

about Teck’s adaptive management process, see Section 2.2.

2.1.6 Modelling Methods

Several SOCs focus on modelling approaches for the EIA and request changes such as:

• additional modifications to model assumptions

• further model validation

• revised screening procedures

• additional statistical analysis

• inclusion of more chemical parameters beyond that provided in the Project Update

Teck considers these SOCs differences of professional opinion regarding assessment

methods. Nonetheless, it has carefully reviewed each request and maintains that the

assessment methods selected for the EIA are the appropriate technical approach to

address the requirements of the TOR.

Teck understands that some reviewers have an alternate opinion, and Teck respects the

right of reviewers to offer opinion on methodology. It is ultimately the responsibility of

AER to determine whether the EIA is complete, and the role of the JRP to determine, on

the basis of the evidence and argument, whether the assessment methods used by Teck

are appropriate. Based on the outcome of past JRP hearings, Teck anticipates that model

validation may be a condition of approval in instances where uncertainty remains.



2.1.7 Additional Assessment Work

Generally, requests for additional assessment work seek further assessment of specific

technical areas or additional geographic areas. Teck’s view is that the EIA and additional

supporting information provided for the Project application are adequate, and that further

assessment work beyond what has been included in the Integrated Application, Project

Update, five rounds of SIRs and these current SOCs is not required.

Teck recognizes that discussion and debate are important part of the regulatory process,

and has considered input and advice provided through ongoing engagement with

regulators, Aboriginal communities and stakeholders. Based on this and the extensive

information included in EIA and Teck’s regulatory application for the Project, Teck is of

the opinion that all contentious items have been identified, discussed and assessed to an

appropriate extent. There is a practical need for any remaining discussion to proceed via

the JRP process where it can be explored and decided upon in a timely manner.

Teck has received several SOCs that request additional or alternate assessment work

related to predevelopment or existing conditions. Examples include:

• further discussion and definition of these conditions

• development of a socio-economic predevelopment condition

• requests for additional health risk assessment work related to these conditions

Teck notes that the TOR does not require assessment of predevelopment and existing

conditions. These temporal snapshots were included to provide context for the mandatory

assessment cases (i.e., Base Case, Application Case and Planned Development Case) and

in response to community preferences. Teck’s view is that adequate and appropriate

information for predevelopment and existing conditions is included in the existing

assessment work for the Project.

2.1.8 Appropriate Stage of Engineering

Some SOCs request information that is typically and most logically provided during

future stages of engineering. Examples include groundwater seepage control system

design, detailed tailings pond emission profiles, expected changes in solvent quality over

time, aircraft flight schedules and bridge design details. The EIA is based on two full

cycles of prefeasibility engineering (i.e., one for the Integrated Application and one for

the Project Update), which is greater than what has typically been done for other oil sands

mine applications in Alberta. Teck intends to complete additional engineering studies;

however, this work should be done after the Project receives the anticipated regulatory

approvals.



Similarly, several SOCs request more detailed modelling of mitigation systems and their

performance. Examples include the groundwater interception system, mitigation for karst

features, drawdown effects, and dyke failure scenarios. Teck has reviewed these requests

and concluded that more detailed modelling will not provide better or different results

than what is presented in the Project Update. EIA predictions reasonably represent what

future conditions will be. Future monitoring requirements are expected to be a condition

of the anticipated approval for the Project, and will test the effectiveness of planned

mitigation. In the unlikely event that monitoring identifies that a particular mitigation

measure is not as effective as predicted, Teck’s adaptive management plan will guide

appropriate action. For details on Teck’s monitoring and adaptive management plans, see

Key Theme – Management, Mitigation and Monitoring (Section 2.2).

2.2 Management, Mitigation and Monitoring

Several of the SOCs Teck has received from Aboriginal communities and stakeholders

relate to management, mitigation and monitoring identified for the Project. Some SOCs

request additional Project detail, primarily detailed engineering designs, management and

mitigation plans and monitoring programs. Teck’s view on these requests and the

proposed evolution of these plans and programs throughout the development and

operation of the Project are discussed in this response.

Based on a thorough review of the provincial TOR, federal requirements and

clarifications, and past oil sands EIAs, Teck is confident that the Project application

meets all regulatory requirements and the Project EIA is complete and ready to proceed

to the JRP process (see Section 2.1). Teck understands and appreciates the interest in

detailed engineering designs, management and mitigation plans and monitoring

programs; however, Teck’s view is that the Project Application is based on an

appropriate level of engineering that describes a project that can realistically be built (see

Volume 1, Section 12.3 of the Project Update). The information provided to date is

appropriate for proposed development projects seeking regulatory approval.

Although the need for various management (e.g., emissions management, water

management, tailings management) and mitigation (e.g., conceptual closure, conservation

and reclamation plan, conceptual fisheries offsetting plan, wildlife mitigation and

monitoring plan) plans and monitoring programs has been identified within the Project

Application, detailed plans and programs need not be finalized at this stage of the Project.

These plans and programs will be developed in further detail, subject to further

engagement with Aboriginal communities, regulators and government agencies, in future

phases of the Project.



Teck recognizes and appreciates the desire to review detailed designs, plans and

programs but has had to balance Project information available at this stage of engineering

with the level of information required to develop detailed designs, plans and programs.

An important part of developing these items is the input and feedback received from

regulators, Aboriginal communities and stakeholders. Further, Teck has had to balance

the desire and willingness of some Aboriginal communities with the expressed reluctance

of other communities to engage on the development of plans and programs before a

Project has received approvals and authorizations. Teck understands that these latter

communities are concerned that participation could be misinterpreted to imply consent,

which Teck understands is not the case. Teck has made best efforts to balance these

viewpoints when advancing plans and programs at this stage of the Project.

Teck recognizes three key phases of development for management and mitigation plans

and monitoring programs aligned with development of the Project (see Table 2-2):

(1) project definition phase

(2) project execution planning phase

(3) implementation and adaptive management phase

Teck will continue to engage Aboriginal communities, listen, consider and respond to

their interests throughout these three key phases of development.

Table 2-2 Phased Development of Project Management, Mitigation and Monitoring Plans and Programs

Phase Description

Project Definition • Conceptualization of management, mitigation and monitoring plans and programs early in the Project timeline

• Based on a prefeasibility study level of engineering • Influenced by engagement with Aboriginal communities, regulatory and government

agencies and stakeholders • Incorporated into the EIA • Meets the provincial TOR and federal requirements and clarifications for the Project • Project definition influenced throughout the regulatory process

Project Execution Planning

• Formalization of management, mitigation and monitoring plans and programs following regulatory approval and sanction of the Project

• Meets conditions of the regulatory approval • Influenced by more advanced engineering • Influenced by engagement with Aboriginal communities, regulatory and government

agencies and stakeholders • Informed by collaboration with existing oil sands developments and regional research

consortia • Influenced by preconstruction monitoring results



Table 2-2 Phased Development of Project Management, Mitigation and Monitoring Plans and Programs (cont’d)

Phase Description

Implementation and Adaptive Management

• Implementation of management, mitigation and monitoring plans and programs • Monitoring of the effectiveness of the management and mitigation plans, including

operational and regionals monitoring programs • Adaptation of the plans, as required, based on monitoring results and engineering

advances • This iterative process allows management, mitigation and monitoring plans to evolve

throughout the life of the Project • Influenced by ongoing input from Aboriginal communities, regulatory and government

agencies and stakeholders NOTE: This table summarizes the key activities within each phase but is not meant to be a comprehensive list of all activities within a phase.

This management, mitigation and monitoring key theme response describes the phase-by-

phase evolution of management and mitigation plans and monitoring programs for the

Project. The influence of key activities within each phase on the development of these

plans and programs is discussed. See Volume 1, Section 12 of the Project Update for an

explanation of Teck’s approach to Project overall implementation.

2.2.1 Project Definition Phase

In the project definition phase, management and mitigation plans and monitoring

programs are conceptual, which is recognized in the provincial TOR. For example, the

provincial TOR for the Project require a conceptual closure, conservation and

reclamation (CC&R) plan and potential plans for fisheries offsetting. Because the Project

timeline spans more than 15 years from initial concept through project start-up, detailed

plans and programs should not be finalized in the midst of the regulatory process.

Figure 2-1 illustrates the information provided in Volume 1, Sections 12.2 and 12.3 of the

Project Update in relation to the three phases of management and mitigation plan and

monitoring program development that Teck recognizes.



Figure 2-1 Planning Schedule for the Frontier Oil Sands Mine Project

2005

2006

2007

2008

2009

2010

2011

2012

2013

2014

2015

2016

2017

2018

2019

2020

2021

2022

2023

2024

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2026

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2028

2029

2030

2031

2032

2033

2034

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2036

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2039

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2080

Public DisclosureFinal EIA Terms of ReferenceApplication undertaken and filedRound 1 SIRsRound 2 SIRsRound 3 SIRsRound 4 SIRsProject UpdateJoint Review Panel HearingJoint Review Panel Decision StatementAssociated Project ApprovalsTeck Board of Directors Project Sanction DecisionPrescoping and scoping studiesPrefeasability studiesUpdate to prefeasibilityFeasability preparationFeasability studies and Project Execution PlanDetailed engineering for Phase 1Phase 1, production train 1- site prep. & constructionPhase 1, first oilPhase 1, production train 2 - constructionPhase 1, production train 2 - first oilPhase 2 - constructionPhase 2 - first oil Operational lifePhase 1 and 2 - end of mine lifeClosure completeProject DefinitionProject ExecutionImplementation and Adaptive Management



Plans and programs evolve as input is collected throughout the regulatory and community

engagement processes. As an example, Table 2-3 describes the influences that the

regulatory and community engagement processes have had on the progress of the access

management plan (AMP), biodiversity management plan, detailed fisheries offsetting

plan (DFOP) and wildlife mitigation and monitoring plan (WMMP). Teck has advanced

these plans in line with, or beyond, what has historically been done in the oil sands.

Teck’s ability to do so is due, in part, to its extensive mining experience and existence of

similar plans at its operating mines as well as the willing participation of Aboriginal

communities and regulators. Teck recognizes that other plans have been identified and

anticipates additional plans may be identified in the future as the Project, and

commensurately the engineering, progresses. Teck anticipates that management and

mitigation plans and monitoring programs will evolve in a similar manner to what is

discussed below.

Table 2-3 Influence of Regulatory and Community Engagement Processes on Project Plans to Date

Purpose Influence of Regulatory and Community Engagement

Processes on Project Plans

ACCESS MANAGEMENT PLAN

The AMP aims to safely manage all aspects of land access (including type and frequency of access) through or around an area that is being developed.

• Aboriginal communities have shared opinions and concerns during engagement regarding access and access management. These include: (i) loss of, or hindrance to, access to lands and resources considered important for traditional and cultural use, and (ii) increased access by non-Aboriginal land users.

• Teck committed to develop an AMP in Volume 8, Section 6.5.4 in the Integrated Application.

• In response to a provincial information request, Teck presented a draft table of contents for a conceptual AMP (see the response to ESRD/CEAA Round 3 SIR 75, Appendix 75a.1).

• In Volume 1, Section 14.8.5 of the Project Update, Teck committed to advance the AMP in 2015, which was achieved by a November workshop with Aboriginal communities and regulatory agencies.

BIODIVERSITY MANAGEMENT PLAN

A biodiversity management plan sets out how Teck’s vision of having a net positive impact (NPI) on biodiversity may be achieved, on the basis of information that has been gathered and assessed to date.

• In response to ESRD/CEAA Round 1 SIR 221 and ERCB Round 2 SIR 29b, Teck stated that offset planning should not occur until the anticipated Environmental Protection and Enhancement Act (EPEA) approval for the Project is received.

• In Volume 1, Section 14.8.3 of the Project Update, Teck discussed its nine-step approach to biodiversity management planning.

• In Volume 1, Appendix 14A of the Project Update, Teck provided an example of Teck’s approach to biodiversity management planning.

• In response to CEAA Round 5 SIR 131b, Teck provided a general timeline for completing the nine-step process. Information is currently available to complete a draft of Steps 1 through 4. Step 5 can be completed in the detailed phase of management, mitigation and monitoring plan and program development. Steps 6 and 7, while underway, require more regulatory certainty. Steps 8 and 9 are implementation, monitoring and adapting actions.



Table 2-3 Influence of Regulatory and Community Engagement Processes on Project Plans to Date (cont’d)



DETAILED FISHERIES OFFSETTING PLAN

A DFOP is a required component of an application for authorization under the Fisheries Act.

• Teck developed a conceptual fish habitat compensation plan which was included in Volume 1, Section 15 of the Integrated Application.

• The conceptual fish habitat compensation plan was revised in 2013, based on engagement with DFO regarding affected fish populations. The conceptual plan was resubmitted in response to ESRD/CEAA Round 2 SIR 30 (see Appendix 30j.1).

• In 2013, the Frontier Fisheries Offsetting Framework, an agreement between Teck and DFO, was developed because of several uncertainties that were external to the proposed fish habitat compensation lake’s function to offset losses in fisheries productivity associated with the Project.

• In July 2014, Teck engaged Aboriginal communities and regulatory and government agencies on the Frontier Fisheries Offsetting Framework.

• Teck included a conceptual fisheries offsetting plan as part of the Project Update (see Volume 1, Section 15.4), which included the Frontier Fisheries Offsetting Framework.

• In April 2015, Teck held a workshop to receive feedback on the fisheries offsetting options included in the Frontier Fisheries Offsetting Framework. Feedback received from Aboriginal communities will be considered in the draft DFOP.

• In response to CEAA Round 5 SIR 164b, Teck describes how feedback from the April 2015 workshop was considered and how decisions were made.

• In November 2015, Teck held a workshop to present decisions regarding fisheries offsetting measures. Teck also identified three opportunities for continued input into the DFOP: (i) identifying a potential fish species assemblage for the proposed fish habitat compensation lake (ii) discussing community interest in the design and execution of fish and fish habitat monitoring (iii) discussing community interest in developing regional Aboriginal fisheries offsetting objectives as a complimentary measure that includes a list of potential offsetting options in the oil sands region that meet regional Aboriginal community desires



Table 2-3 Influence of Regulatory and Community Engagement Processes on Project Plans to Date (cont’d)



WILDLIFE MITIGATION AND MONITORING PLAN

The purpose of a WMMP is to outline how predicted effects on wildlife and wildlife habitat will be mitigated during all phases of a project, how mitigation effectiveness will be monitored, and how mitigation will be adapted, if necessary, based on monitoring results.

• Aboriginal communities have raised a number of concerns during engagement regarding wildlife habitat, abundance and health, and traditional and cultural use of wildlife. Aboriginal communities provided some preliminary guidance on wildlife mitigation, including monitoring.

• In response to ESRD/CEAA Round 1 SIR 440, Teck stated that concerns expressed by potentially affected Aboriginal communities related to wildlife will be considered during the development of a wildlife mitigation and monitoring plan, and that the plan will be developed together with potentially affected Aboriginal communities and regulators.

• Teck has stated that development of a WMMP would begin in 2014 (see the response to ESRD/CEAA Round 1 SIR 226). It has since revised this timeline and confirmed that development of the WMMP will be delayed to allow for a plan that will better reflect the updated Project (see the response to ESRD/CEAA Round 3 SIR 54).

• Teck has identified specific measures that will be included in the WMMP (e.g., see the response to ESRD/CEAA Round 1 SIR 211, ESRD/CEAA Round 3 SIRs 54, 59 60).

• In Volume 1, Section 14.8.4 of the Project Update, Teck states that it “will advance the development of the WMMP using the data and analysis that have been provided in the Project Update; however, the WMMP cannot be completed in 2015 as it will be informed by the Joint Review Panel process.”

• Teck expects that a detailed WMMP will be a condition of the anticipated EPEA approval and that its content will be influenced by provincial direction at that time. Therefore, the WMMP is scheduled for detailed development following regulatory approval.

• In response to CEAA Round 4 SIR 31 Teck provided a framework for a WMMP.

• In Volume 1, Section 14.8.4 of the Project Update, Teck states that “the form and content of the WMMP will be determined in consultation with regulators, Aboriginal communities and stakeholders.”

• On November 5, 2015, Teck held a workshop to discuss guiding principles for a WMMP. Teck heard that continued engagement is extremely important throughout the process of developing the WMMP.



2.2.2 Project Execution Planning Phase

In the project execution planning phase, management and mitigation plans and

monitoring programs will be advanced as their development will be informed by

regulatory approvals, detailed engineering, additional input from Aboriginal

communities, regulatory and government agencies and stakeholders and, preconstruction

monitoring results.

• Regulatory Approvals – The AER decides whether an EPEA approval will be

issued and under what conditions. Management and mitigation plan and monitoring

programs must take into account applicable conditions.

• Detailed Engineering – Once approved and sanctioned by Teck’s Board of

Directors, project engineering and environmental management designs can advance

to a higher level of definition as required to enable tendering for construction.

Engineering and environmental management designs are studied in greater depth and

consider additional geologic and processability test work. The increased level of

understanding gained by continued investment during this phase fully defines a

project (definitive technical, environmental and commercial details). Detailed

management and mitigation plans and monitoring programs that are aligned with the

project execution plan can be produced during this phase. Accordingly, clear

management, mitigation and monitoring actions, and procedures for execution of the

actions, can be determined.

• Additional Input from Aboriginal Communities, Regulatory and Government

Agencies and Stakeholders – Engagement with Aboriginal communities, regulatory

and government agencies and stakeholders is the primary means through which Teck

understands expectations and identifies opportunities to reduce impacts and enhance

potential benefits from Project activities. This engagement will occur early enough to

inform Teck’s engineering and environmental management designs. Continued

engagement during this phase will reveal new detail, improve understanding and

enable refinement of designs and plans.

• Preconstruction Monitoring – The purpose of preconstruction monitoring is to

further develop the baseline of environmental reference conditions as required to

support operational monitoring (discussed in the implementation, monitoring and

adaptive management phase). While much of the preconstruction monitoring takes

place in preparation for and during the regulatory process, the dataset is refined and

becomes more detailed after approval has been granted. With site preparation being

planned to start two years after Project approval, ample time exists to refine the

environmental and socio-economic baseline dataset, as appropriate. In some cases,

preconstruction monitoring results may be required to finalize a mitigation plan.



2.2.3 Implementation, Monitoring and Adaptive Management Phase

In the implementation, monitoring and adaptive management phase, management and

mitigation plans and monitoring programs will be evaluated for effectiveness and adapted

as needed on an ongoing basis. Management and mitigation plans and monitoring

programs are subject to refinement throughout the life of a project as lessons are learned

and circumstances change and technologies advance. As a global mining company with

over 100 years of experience, Teck has been recognized for its commitment to effective

environmental management, mitigation, monitoring and adaptive management (for more

information, see http://www.teck.com/about/awards/).

Project-specific and regional monitoring will be part of Teck’s ongoing operations, as

monitoring is a critical learning and adaptive management tool. Regional, multi-

stakeholder organizations provide data, perspective, knowledge and experience that help

identify environmental and socio-economic challenges and solutions. Collaborative

monitoring with Aboriginal communities and regulators, whether through operational or

regional monitoring initiatives, is an area of interest for Teck. Approaches that involve

Aboriginal communities provide key advantages, namely:

• They improve trust and confidence in the data and in management decisions.

• They enable Teck to develop monitoring programs that answer the questions posed

by Aboriginal communities.

• They provide an opportunity to integrate traditional knowledge into the monitoring

program.

• They provide an opportunity for Teck to implement adaptive management solutions

that consider Aboriginal community interests.

Two examples of Teck’s involvement in collaborative monitoring are:

• Teck and Aboriginal communities have had early discussions about Aboriginal

community involvement in the design and execution of a fish and fish habitat

monitoring program, a component of a detailed fisheries offsetting plan (for details,

see the response to CEAA Round 5 SIR 164b).

• Under the Wood Buffalo Environmental Association (WBEA), a Traditional

Knowledge Committee has designed a community-based project to share Fort

McKay traditional knowledge and concerns about local berry populations. Teck will

consider these findings alongside scientific monitoring of berry populations.

Additional themes for future study have been identified, including wetland, medicinal

plant and animal tissue monitoring.



Participation in relevant regional initiatives is important to Teck and will be a

requirement of the anticipated EPEA approval for the Project. Teck acknowledges that

support for multi-stakeholder organizations that include Aboriginal communities, like

WBEA and Ronald Lake Bison Herd Technical Team, is important. Therefore, Teck will

consider and respond to Aboriginal community views on multi-stakeholder organizations

now and in the future. Currently, Teck is a member of the following organizations:

• the Alberta Environmental Monitoring, Evaluation and Reporting Agency

• Canada’s Oil Sand Innovation Alliance

• the Wood Buffalo Environmental Association

• the Ronald Lake Bison Herd Technical Team (see CEAA Round 5 SIR 134 for an

update on the team’s activities)

Adaptive management is a key part of environmental management for the Project and

will allow management and mitigation plans to evolve in step with changing

circumstances, local and regional monitoring results, and advances in science. Teck will

develop an adaptive management plan to enable appropriate response to trends detected

through accrued operational, regional and collaborative monitoring initiatives. See

Volume 1, Section 13.3.4 for a description of Teck’s approach to adaptive management.

Teck has committed to including Aboriginal communities in the development of

mitigation plans and their implementation. For example:

• As part of the CC&R plan, and through a Reclamation Working Group, Teck will

develop and implement a program to salvage and relocate known occurrences of rare

(vascular) species to areas outside the Project footprint. Traditional resource

harvesters will be invited to harvest traditional plants before disturbance. With the

involvement of local Aboriginal communities, Teck will harvest and collect seeds

and individuals (as relevant) of rare and culturally important species for use in

propagation and revegetation efforts.

• As part of the historical resources management plan, Teck will invite members of

local Aboriginal communities to participate in future historical resources assessments

and mitigations where logistically feasible.

In summary, Teck’s view is that the Project application is complete and ready to proceed

to the JRP process. The Project application is based on an appropriate level of

engineering and sufficient mitigation has been identified at this stage of the Application.

Detailed management and mitigation plans and monitoring programs should not be

finalized at this stage of the Project as they need to be informed by the outcome of the

JRP process and additional Aboriginal community and stakeholder input. Teck will

continue to listen and respond to the interests of, and engage with, Aboriginal



communities and stakeholders throughout the three key phases of development:

(1) project definition, (2) project execution planning phase, and (3) implementation and

adaptive management phase. Management and mitigation plans and monitoring programs

cannot be fully detailed until the Project execution and planning phase because detailed

plans rely on a complete regulatory process, advanced engineering designs and additional

input from regulatory and government agencies, Aboriginal communities and

stakeholders. In the implementation, monitoring and adaptive management phase,

management and mitigation plans and monitoring programs will be evaluated for

effectiveness and adapted as needed on an ongoing basis.

2.3 Climate Change

Climate change, the potential effects of future climate change on the Project design and

operation, and requests for additional climate change analysis are themes that exist in

several SOCs received from Aboriginal communities and stakeholders. This response

discusses the general implications of climate change on the Project and explains how

climate change has been considered in the Project’s design, assessment and management

plans.

Teck has considered potential effects of climate change in its regulatory submissions for

the Project, including the Integrated Application, responses to SIRs and the Project

Update. In doing so, Teck has met the requirements of (i) the provincial terms of

reference issued for the Project (AENV 2009), and (ii) the federal guidance document

Incorporating Climate Change Considerations in Environmental Assessment: General

Guidance for Practitioners (The Federal-Provincial-Territorial Committee on Climate

Change and Environmental Assessment 2003). The latter recommends that proponents:

• discuss their project’s contribution to greenhouse gas (GHG) emissions on both a

provincial and national scale

• consider how climate change could affect the project

As part of the environmental impact assessment (EIA) completed for the Project, Teck

assessed a range of future climate change scenarios to evaluate potential effects of future

climate conditions (see Volume 5, Appendix 3C of the Integrated Application). In the

Project Update, climate change was considered quantitatively and qualitatively; for

example:

• the updated hydrology assessment quantitatively evaluates several climate change

scenarios (see Volume 3, Section 6 of the Project Update)



• the updated air quality assessment considers climate change in quantifying GHG

emissions (see Volume 3, Section 4 of the Project Update)

• for several disciplines, the discussion of prediction confidence considers climate

change (e.g., see Volume 3, Sections 4.6.11, 6.4.7, 6.5.7 and 6.6.5 of the Project

Update)

The breadth and depth of climate change analysis completed for the Project meets

regulatory requirements and is considered appropriate in the context of an EIA.

Additional climate change analysis is not required at this time; however, Teck will keep

abreast of emerging research, regulations and guidelines for managing GHG emissions

from the Project and will look for opportunities to further reduce GHG emissions during

future stages of engineering. For details of Teck’s greenhouse gas management plan for

the Project, see the response to AER Round 5 SIR 39.

2.3.1 Project Greenhouse Gas Emissions

Teck takes its commitment to sustainability seriously and has established short term goals

to implement projects that reduce GHG emissions by 275 kt (kilotonnes) of CO2-

equivalent (CO2e) across its operations by 2020, and long term goals to reduce GHG

emissions by 450 kt of CO2e by 2030. The Project has been designed to operate in an

efficient manner using technically proven and commercially available technology. The

updated Project design incorporates several improvements and mitigation measures that

are expected to:

• reduce the Project’s overall (direct and indirect) GHG emission rate by 21%, and

• reduce the Project’s GHG emission intensity by 12% compared to the Integrated

Application

For a more detailed comparison and discussion of these improvements, see Volume 1,

Section 14.4.2.5 of the Project Update.

Overall, GHG emissions (direct and indirect) from the Project are expected to contribute

approximately 4 Mt (megatonnes) per year. Teck expects that these emissions will not

exceed the 100 Mt annual emission cap established by the provincial government.

Further, with a direct emissions intensity of 38.4 kg of CO2e per barrel, Teck believes that

the Project represents best-in-class for oil sands GHG emissions.

Teck remains active in the area of research and development into commercially and

economically viable technologies to reduce GHG emissions, particularly those that are

applicable to oil sands mining and extraction. This includes methane emissions, which

Canada intends to regulate by 2017. Teck’s involvement in oil sands-related research and

development is largely through its membership in Canada’s Oil Sands Innovation



Alliance (COSIA) and its GHG Environmental Priority Area. Teck anticipates that the

Project’s GHG emission rate and GHG emission intensity will be further reduced during

future stages of engineering, which will consider the Alberta Government’s Climate

Leadership Plan and associated regulations, when available.

2.3.2 Potential Climate Change Effects on the Project

Teck has designed the Project with future climate change in mind and will adaptively

manage the construction, operation and closure of the Project within a potentially

changing climate. The current and final Project design, and its associated management

plans, will consider climate change and its effects. For example:

• Teck’s water management plans, including off-stream storage requirements, comply

with the Surface Water Quantity Management Framework for the Lower Athabasca

River (GOA 2015), which considers future climate change scenarios.

• Operational diversion channel design will consider climate change during future

stages of engineering.

• Potential climate change effects are considered as part of the detailed fisheries

offsetting plan (DFOP).

• The closure plan and planned land capability and vegetation prescriptions for the

Project consider climate change and will be modified based on emerging conditions

and forecasts during operations.

Climate change predictions have inherent uncertainty. As such, adaptive management is a

key aspect of the environmental management for the Project and will be important for

managing potential effects of climate change on the Project. For an overview of Teck’s

adaptive management strategy, see Volume 1, Section 13.3.4 of the Project Update. See

Key Theme – Management, Mitigation and Monitoring (Section 2.2) for additional

discussion about the importance of adaptive management.

2.3.3 Incorporating Future Climate Scenarios

As mentioned, Teck considered multiple climate change scenarios in assessing potential

effects of the Project. These scenarios were assessed as part of the Integrated Application

(see Volume 5, Appendix 3C), and updated scenarios were assessed in the Project Update

consistent with the approach outlined in the response to ESRD/CEAA Round 2 SIR 28,

Appendix 28a.1. In total, 37 different climate scenarios have been considered as part of

the Project assessment work to date (13 in the Integrated Application and 24 in the

Round 2 SIRs and Project Update). These scenarios consider median and extremes of wet

or dry and cool or warm conditions.



Most requests for additional climate change analysis focus on the hydrology assessment,

and it is through the hydrology assessment that Teck has considered the 37 climate

change scenarios referenced above. Although Teck understands the desire of some

reviewers to have additional climate scenarios or datasets assessed, Teck considers the

approach used in the Integrated Application and Project Update to be appropriate and

robust. Further assessment, including refinement of methods used to incorporate climate

change effects in the hydrology assessment, will not meaningfully change the conclusions

of the assessment or its associated prediction confidence. As such, Teck will consider

additional climate change scenarios as part of adaptive management, following Project

approval and as the Project develops over time.

Some SOCs request more information about the effects of climate change on other

modelled assessments, such as the air quality assessment. Teck has considered the effects

of future climate scenarios on other environmental components (i.e., those with potential

to be measurably affected by climate change) by assessing effects on aquatic and

terrestrial resources. Climate change is expected to have a negligible effect on other

environmental components assessed in the Project Update (e.g., air quality, vegetation).

Should future research and monitoring suggest adverse effects from climate change, these

effects will be adaptively managed.

Teck is currently participating in research on extreme climate variability, which some

climate change scenarios indicate could increase in the future. The work is related to the

tree ring study for the Athabasca River completed by the University of Regina

(Sauchyn et al. 2015). Teck has engaged with Dr. Sauchyn through COSIA to understand

the implications of this study on Athabasca River flows at Fort McMurray. The tree ring

study looks at multi-century, historical data showing the range of climate variability for

the Athabasca River. Teck is reviewing this study and, if appropriate, will determine how

it may be incorporated into future stages of engineering to help prepare for climatic

extremes.

In summary, the Integrated Application and the Project Update have appropriately

covered, both quantitatively and qualitatively, climate change and the potential effects of

future climate change related to the Project design and potential Project effects.

Additional assessment at this stage of the Project will not provide meaningfully different

findings. Adaptive management is a key aspect of environmental management for the

Project and provides confidence that Teck is committed to change and adapt as the

Project develops over time. Learning from experience and modifying subsequent actions

in light of that experience will enable the Project to evolve in step with changing

regulations, circumstances, local and regional monitoring results, and scientific advances.

For example, Alberta’s Climate Leadership Plan was released in November 2015, and

Teck expects more details on how this plan will be implemented throughout 2016. Teck



has already identified a number of actions that it will take to prepare for anticipated

regulatory changes. These actions relate to Project design, research and development,

continuous improvement, additional emission studies and continued evaluation and

investment in green-energy initiatives (for details, see Volume 1, Section 14.4.2.5 of the

Project Update).

Teck will continue to monitor potential regulatory changes related to GHG emissions as

they evolve and will comply with applicable requirements for the Project. Because the

timing, extent and implementation details for potential regulatory changes are not fully

known at this time, Teck considers additional focus on GHG reductions is premature at

this stage of Project development. However, Teck will continue to focus on research and

strategies to reduce GHG emissions and will seek opportunities to incorporate

improvements into the Project design during future stages of engineering to support

Teck’s short-term and long-term GHG emission reduction goals.

References

AENV (Alberta Environment). 2009. Final Terms of Reference Environmental Impact Assessment Report

for the Proposed UTS Energy Corporation/Teck Cominco Limited Frontier Oil Sands Mine

Project. Edmonton, Alberta.

GOA (Government of Alberta). 2015. Surface Water Quantity Management Framework for the Lower

Athabasca River (SWQMF). March 2015. Available at: http://esrd.alberta.ca/focus/cumulative-

effects/cumulative-effects-management/management-frameworks/documents/LARP-

SurfaceWaterQuantityMgmt-Feb2015.pdf. Accessed March 2015.

Sauchyn, D.J., J-M. St-Jacques and B.H. Luckman. 2015. Long-term reliability of the Athabasca River

(Alberta, Canada) as the water source for oil sands mining. Proceedings of the National Academy

of Sciences of the United States of America (PNAS) 112(41): 12621–12626. October 13, 2015.

The Federal-Provincial-Territorial Committee on Climate Change and Environmental Assessment. 2003.

Incorporating Climate Change Considerations in Environmental Assessment: General Guidance

for Practitioners. November 2003. Cat. No. En106-50/2003E-PDF. Available at:

https://www.ceaa-acee.gc.ca/default.asp?lang=En&n=A41F45C5-1. Accessed February 2016.



2.4 Agreement and Regulator Requests

Fort McKay First Nation and McKay Métis Community (‘Fort McKay’) undertook a

joint technical review of the Frontier Project Update and Teck’s response to Round 4

SIRs. This technical review formed the basis for each community’s August 2015

statement of concern (SOC) to Teck and regulators. As part of this SOC, Fort McKay

categorized a potential path forward to address each of its concerns. The categories used

by Fort McKay are:

• Government Agencies (including AER, ACO, AEMERA, AEP) – directed at the

Crown – Fort McKay’s request to the Crown, including information requests,

regulatory requirements and approval conditions (if the project is ultimately

approved); and

• Industry – directed at the proponent – a deficiency or question or potential mitigation

on which Fort McKay requests that a response or additional information from Teck

is provided to Fort McKay and government, prior to the application being deemed

completed by the regulators. When information or a response is requested from Teck,

Fort McKay requests a reasonable opportunity to review the response and

information and an opportunity to provide comments and input.

This key theme response constitutes Teck’s response to all concerns that Fort McKay has

indicated are directed to government agencies. In addition, this key theme response is

intended to respond to concerns that Teck has identified as best addressed through a

long-term agreement with Fort McKay First Nation and McKay Métis Community. At

the time of drafting this response, Teck is actively negotiating with both the Fort McKay

First Nation and McKay Métis Community and hopes to reach a long-term agreement.

Such an agreement would formalize Teck’s relationship with the community, including

how Teck and the community will work together to manage potential effects of the

Project on Fort McKay.

The balance of this key theme response articulates Teck’s specific views regarding

agreement and regulatory requests, including potential next steps.



2.4.1 Agreement Requests

In some cases, the SOCs that Teck has identified as best discussed within a long-term

agreement have been contemplated and spoken to by Teck through the regulatory and

consultation process to date (see examples listed below). Nonetheless, Teck would like to

further discuss these and other requests with Fort McKay First Nation and McKay Métis

Community to reach an understanding on how to address the SOC in a mutually

satisfactory manner.

• Volume 3, Section 4.8.2 of the Project Update – In addition to focusing on

minimizing odour sources, Teck’s odour management plan will include working with

neighbouring Aboriginal communities to report, identify and manage detectable

odours at identified receptor locations.

• Volume 1, Section 14.4.2.6 of the Project Update – Teck will control dust from

construction, mining and tailings operations using a variety of methods that will be

identified in a dust management plan.

• Volume 3, Section 4.7.1.1 of the Project Update – Participation in relevant regional

initiatives is important to Teck and will be a requirement of the anticipated

Environmental Protection and Enhancement Act (EPEA) approval for the Project.

Teck recognizes that support for multi-stakeholder organizations that include

Aboriginal communities (e.g., the Wood Buffalo Environmental Association and

Ronald Lake Bison Herd Technical Team), is important to Aboriginal communities.

As such, Teck will consider Aboriginal community views on multi-stakeholder

organizations now and in the future.

• Volume 5, Section 3.5.9 of the Integrated Application – An adaptive strategy will

be adopted to manage the potential effects associated with predicted flow changes in

receiving watercourses. This strategy will involve continuing and expanding

hydrologic and geomorphic monitoring. Should the monitoring data indicate

unacceptable hydrologic effects (e.g., increased channel erosion), mitigation options

(e.g., reduced flow releases) will be considered and implemented. Teck will continue

to discuss watershed management strategies with potentially affected Aboriginal

communities.



• Volume 1, Section 14.8.5 of the Project Update – Teck has committed to begin

developing an access management plan in cooperation with regulators, potentially

affected Aboriginal communities and stakeholders. Its objective will be to minimize

effects on hunting, fishing, gathering and trapping while maintaining public safety,

site development and mining operations.

• Volume 1, Section 18.6.4.2 of the Project Update – Teck will develop and

implement a weed management plan throughout the life of the Project, including

during reclamation and at closure.

2.4.2 Regulator Requests

As part of its August 2015 SOCs, Fort McKay included requests directed to regulators.

Teck has not provided a response to requests that were specifically directed to regulators.

Given Teck’s ongoing discussions with Fort McKay First Nation and McKay Métis

Community, some of these requests may be addressed prior to the JRP hearing for the

Project.

Teck asks that regulatory and government agencies reviewing the Frontier Project

application refrain from making any decisions on regulatory approval conditions at this

time. Teck is of the view that decisions about specific regulator requests should be made

only after the JRP hearing, when all parties’ submissions and evidence can be properly

considered. This will ensure that the implications of these requests to the Project can be

properly considered prior to a decision being made.

FRONTIER OIL SANDS MINE PROJECT 3 SOC RESPONSES CUMULATIVE EFFECTS


3 SOC Responses

Cumulative Effects

Cumulative Effects Assessment

SOC 1

Fort McKay requests that Teck supports, with funding and data, an ongoing and updated

cumulative-effects assessment of impacts on Fort McKay’s Traditional Territory and rights so that

constructive and decisive measures can be developed to address cumulative effects within Fort

McKay’s Traditional Territory.

Teck Response:

See Key Theme – Agreement and Regulator Requests (Section 2.4).

SOC 2

Fort McKay requests that Teck develops and implements, in collaboration with Fort McKay, in a

Working Group created by Teck, follow-up programs and monitoring that specifically determine if

the EIA projections and assumptions are valid and accurate and if proposed mitigation is effective.

Teck Response:

See Key Theme – Management, Mitigation and Monitoring (Section 2.2).

FRONTIER OIL SANDS MINE PROJECT 3 SOC RESPONSES ACCESS MANAGEMENT


Access Management

Access Management Plan

SOC 3

Fort McKay requests that Teck develops and finalizes an access management plan (AMP) in

consultation with Fort McKay, and that it includes mitigations to concerns expressed by Fort

McKay in order to meaningfully practice traditional activities.

Teck Response:

See Key Theme – Agreement and Regulator Requests (Section 2.4) and Teck’s response to AER Round 5

SIR 102 and CEAA Round 5 SIR 162.

FRONTIER OIL SANDS MINE PROJECT 3 SOC RESPONSES TRADITIONAL LAND USE


Traditional Land Use

Mitigation Monitoring

SOC 4

Fort McKay supports the above measures listed by Teck in Section 17.6.3 of the Project Update and

requests that Teck commits to ensuring that it monitors, follows-up and tracks these commitments

to the satisfaction of Fort McKay throughout the project’s life.

Teck Response:




Reclamation

SOC 5

Fort McKay would like to collaborate with Teck to develop a mitigation and an offset plan in

relation to the adverse effects and loss of key cultural and traditional use areas that would be

affected by the plan in the Frontier Project Update.

Teck Response:


SOC 6

Fort McKay requests that Teck:

i. formalizes a process with Fort McKay outlining how Community input would be part of a

jointly developed reclamation criteria development for the Teck Frontier mine; and

ii. supports Aboriginal involvement in developing reclamation criteria in regional committees and

research organizations.

Fort McKay also requests assurance from the provincial and federal governments that reclamation

criteria will be developed with Aboriginal involvement with the Teck lease and will be binding and

upheld during the reclamation certification process and once Teck has returned the land to the

Crown.

Teck Response:




Access

SOC 7

Fort McKay requests that Teck formalizes an agreement with Fort McKay to support developing

an access management plan on the West side of the Athabasca River than takes into consideration

the bridge across the Athabasca River that Teck is proposing in the Project Update.

Teck Response:

See Key Themes – Management, Mitigation and Monitoring (Section 2.2) and Agreement and Regulator

Requests (Section 2.4). For additional discussion, see the response to AER Round 5 SIR 102 and

CEAA Round 5 SIR 162.



Trappers

SOC 8

Fort McKay requests that Teck establishes access management plans, in collaboration with Fort

McKay, to facilitate Fort McKay community member access to traplines and other traditional use

areas throughout the life of the mine.

Teck Response:




SOC 9

Fort McKay requests that Teck confirms it will continue ongoing consultation with affected

trappers regarding project development and provide compensation or implement mitigation

measures as needed following the Fort McKay Trapper Compensation Guidelines.

Teck Response:




FRONTIER OIL SANDS MINE PROJECT 3 SOC RESPONSES WILDLIFE


Wildlife

Wildlife Surveys

SOC 10

Fort McKay requests that AMERA validates breeding bird and wildlife survey data and presents

the results to Fort McKay for review.

Teck Response:


SOC 11

The term “comparable” does not express the expected scientific rigour considering the amount of

survey data collected. Fort McKay requests a more scientific description (i.e., statistics) of how the

bird and wildlife community compares to other areas of the RSA. Information should include

population parameters, community diversity measures, and changes over time, if detected.

Teck Response:

See Key Theme – Adequacy of the Environmental Impact Assessment (Section 2.1).



SOC 12

Teck has completed several years of wildlife surveys yet it is unclear if enough data has been

obtained to meet the baseline survey objectives. Fort McKay requests that Teck completes an

analysis to ascertain if sufficient surveys have been completed to determine if all wildlife species

have been detected (e.g., analyze cumulative observations of species per visit) and if survey effort

has been sufficient to confirm the absence of species of concern. Fort McKay also requests that

Teck shares the survey data with Fort McKay.

Teck Response:


SOC 13

Fort McKay requests that Teck reviews the scientific rigour of the bird survey methods it employed

in comparison to current EIA guidelines (requirement for replication of surveys). Fort McKay

wishes to understand the scientific limits of the methods used by Teck and the potential need for

additional field work.

Teck Response:

Breeding bird surveys conducted for the Project in 2006, 2008, 2010 and 2012 comply with current

survey standards for the province (ESRD 2013) in that they were completed:

• using a modified point-count method to obtain species identification and record distance to

observation, time interval and behavioural information

• using point-count stations spaced at least 300 m apart

• by experienced observers (as required by the guidelines) familiar with the biology, behaviour and

habitat of boreal bird species

• during the recommended breeding period for boreal songbirds (i.e., June 1 to July 7)

• during the recommend time of day (i.e., between a half hour before sunrise and 10:00 am)

• under appropriate environmental conditions (i.e., above 0ºC, no precipitation, winds less than or equal

to 20 km/h, and background noise that did not hinder detection of birds)

During the breeding bird surveys conducted for the Project, field personnel visited each breeding bird

station once per season (see Volume 2, Section 9.2.2.5 in the Project Update and Volume 2,

Section 9.2.2.2 in the Integrated Application). ESRD (2013) recommends that two surveys be conducted



at each station within the same season, separated by a minimum of 10 days. Teck acknowledges that

survey replication helps capture both early- and late-nesting species and account for within-season and

inter-season factors affecting songbird detectability (e.g., associated with adverse weather events or

climate-driven phenological variation). However, the breeding bird surveys completed in the terrestrial

local study area (LSA) are considered appropriate for an environmental impact assessment, and the results

accurately represent songbird species, including species of management concern, nesting in the

terrestrial LSA.

Between 2006 and 2012, 314 breeding bird survey stations were established in the terrestrial LSA. Of the

34 vegetation types in the terrestrial LSA that provide breeding habitat for migratory songbirds, 29 (85%)

were surveyed at least once (see Table 13-1). All vegetation classes considered high quality habitat for

songbird species of management concern were surveyed. Breeding bird surveys were carried out:

• during the period of peak nesting intensity for songbird species nesting in all boreal habitat types

(i.e., wetland, open and forested) based on Environment Canada nesting calendars (Environment

Canada 2014), and

• during the recommended survey period for boreal songbirds in Alberta (ESRD 2013)

Given the field work conducted to date, additional breeding bird surveys are not likely to alter the

conclusions of the wildlife assessment.

Future wildlife surveys will be completed as part of the Project’s wildlife mitigation and monitoring plan.

For additional information, see Key Theme – Management, Mitigation and Monitoring (Section 2.2).

Table 13-1 Breeding Bird Survey Effort in the Terrestrial LSA

Year Number of Survey Stations Number of Vegetation Types

Surveyed1 Vegetation Type Coverage

(%)

2006 4 2 6 2008 140 16 47 2010 89 18 53 2012 81 16 47 Total 314 29 85 NOTE: 1 Vegetation types are a combination of ecosite phases and Alberta Wetland Inventory classes. Burned upland and

burned wetland are also included for 2012 survey data to account for the 2011 Richardson fire.

References

Environment Canada. 2014. General Nesting Periods of Migratory Birds in Canada. Available at:

https://www.ec.gc.ca/paom-itmb/default.asp?lang=En&n=4F39A78F-1. Accessed October

27, 2015.

ESRD (Alberta Environment and Sustainable Resource Development). 2013. Sensitive Species Inventory

Guidelines. Available at: http://esrd.alberta.ca/fish-wildlife/wildlife-management/documents/

SensitiveSpeciesInventoryGuidelines-Apr18-2013.pdf. Accessed October 26, 2015.

http://esrd.alberta.ca/fish-wildlife/wildlife-management/documents/SensitiveSpeciesInventoryGuidelines-Apr18-2013.pdf

http://esrd.alberta.ca/fish-wildlife/wildlife-management/documents/SensitiveSpeciesInventoryGuidelines-Apr18-2013.pdf



SOC 14

Teck has delayed the mine development. Fort McKay requests that through the work already done

and in progress at the Roland Lake Bison Heard Technical Team Teck uses the best and most

recent data and information available to redefine the bison herd boundary and study areas and

reanalyze impacts to bison.

Teck Response:

See the response to CEAA Round 5 SIRs 130 and 134 for a reassessment of Ronald Lake bison.

SOC 15

Fort McKay is concerned about bison, it is a traditional use species and its sustainable populations

are important for Fort McKay’s exercise of its Aboriginal and Treaty rights. Fort McKay requests

that Teck addresses sample size issues with regard to monitoring impacts on bison.

Teck Response:


SOC 16

Fort McKay requests further discussion with Teck on the extent of the wallow surveys and if they

extended into the LSA and how the presence of wallows might be indicative of bison distribution

and seasonal land use.

Teck Response:

Teck is willing to meet with Fort McKay to further discuss the extent of the wallow surveys and how

wallows may be indicative of bison distribution and seasonal land use.



Wildlife Assessment

SOC 17

Fort McKay requests that Teck provides a more detailed explanation for no longer using RNV in

the EIA to evaluate environmental consequence. In addition, Fort McKay would like to know how

removing RNV improves the EIA.

Teck Response:

As stated in Volume 3, Section 11.9 of the Project Update, the effects classification and environmental

consequence ratings in the updated wildlife assessment are similar to those in the Integrated Application.

However, the updated assessment takes a more conservative approach than the Integrated Application by

considering overall change in the availability of preferred habitat (i.e., high and moderate suitability only)

relative only to predevelopment conditions. It does not characterize change compared to the range of

natural variability (RNV). This revision was made in response to supplemental information requests from

regulators and requests from certain Aboriginal communities.

Removing RNV allows changes in preferred habitat to be assessed consistently for all key indicators. In

the Integrated Application, RNV was not applicable to all wildlife species and habitat types (i.e.,

vegetation communities). Specifically, RNV was not generated for species for which forest age structure

was not an important part of habitat suitability models. In these circumstances (e.g., yellow rail, rusty

blackbird, waterfowl, horned grebe, whooping crane and toad species), changes in regional habitat

availability and population levels were assessed relative to predevelopment. In addition, for some species

(e.g., beaver, bison, moose, and short-eared owl) where habitat availability for reference conditions was

below the theoretical RNV, change had to be assessed relative to the mean, not the lower 5% limit.

Although RNV was not determined as part of the updated wildlife assessment, the same thresholds were

applied to determine the magnitude of effects as used in the Integrated Application. Specifically, a 20%

change from assessment cases relative to predevelopment (2066) habitat levels (based on CEMA 2008)

was still used as a criterion to identify a high magnitude change in habitat availability for valued key

indicators. Likewise, a 10% change threshold was used for species at risk (for details, see Volume 3,

Section 11.3.6 of the Project Update). Overall, not using RNV is a more conservative approach as it

results in a greater difference from predevelopment (2066) for species in which RNV would apply.

References

CEMA (Cumulative Environmental Management Association). 2008. Terrestrial Ecosystem Management

Framework for the Regional Municipality of Wood Buffalo. Fort McMurray, Alberta.



SOC 18

Fort McKay requests that Teck becomes an active participant in CEMA or other multi-stakeholder

organizations that include Aboriginal participation regarding wildlife issues.

Teck Response:


SOC 19

Fort McKay is concerned that Teck limited the scope of connectivity analysis based on female

caribou data. Fort McKay requests that Teck ensures connectivity of caribou populations in the

three caribou ranges near the project by securing movement corridors.

Teck Response:

See Key Theme – Management, Mitigation and Monitoring (Section 2.2). See the response to

AER Round 5 SIR 123 for further discussion of movement blockage.



Wildlife Health Assessment

SOC 20

The wildlife health assessment predicts that the project will not adversely affect wildlife. Fort

McKay community members will be skeptical of the results. Teck should consider writing a plain-

language wildlife health assessment for the public and the non-expert readers. Teck should also be

prepared to explain the wildlife health assessment to the Community of Fort McKay.

Teck Response:


SOC 21

Fort McKay requests that Teck describes the model validation for the wildlife health assessment

models and develops a monitoring program to confirm model predictions on wildlife.

Teck Response:

The wildlife health risk assessment (WHRA) model relies on input from the air quality and surface water

quality assessments to estimate exposure levels and predict potential effects on wildlife health. Model

performance for the air quality assessment is described for identified key indicators throughout Volume 3,

Section 4 of the Project Update. For example, see:

• Volume 3, Section 4.3.4 of the Project Update for a discussion of the air quality modelling approach,

model uncertainty, and data validation methods used in the assessment

• Volume 3, Sections 4.6.1.4, 4.6.2.4, 4.6.3.4 and 4.6.4.5 of the Project Update for a summary of air

quality prediction confidence as it relates to specific key indicators

• Volume 3, Appendix 4D, Section 4D.4 of the Project Update for a more detailed discussion of

prediction confidence and CALPUFF model performance

Model performance for surface water quality data is similarly described (see Volume 5, Section 4.5.7 of

the Integrated Application).



Project-specific monitoring and regional monitoring of air quality and water quality will effectively serve

to test the air quality and surface water quality predictions. Planned monitoring of air quality and water

quality in the region will help validate the input to the WHRA model, thereby reducing some of the

uncertainty identified in the WHRA. One of the key sources of uncertainty identified in the WHRA, for

example, stems from an absence of measured chemical concentrations in aquatic plants in the region. As a

result, the WHRA estimates concentrations based on literature bioconcentration factors, which resulted in

a number of elevated (albeit conservative) estimates of risk to wildlife.

To validate the model and reduce key sources of uncertainty in the WHRA, aquatic plants were sampled

from the aquatics local study area to further characterize the current concentrations of polycyclic aromatic

hydrocarbons (PAHs) and metals in these plants. Table 21-1 lists measured versus predicted

concentrations of chemicals associated with elevated risks in the WHRA (i.e., for wildlife species eating

aquatic plants, such as beaver, muskrat, goose, mallard and whooping crane). These chemicals include

antimony, chromium, manganese, selenium, and thallium. With the exception of manganese, the WHRA

model overstates the actual concentrations by up to a factor of 236. This demonstrates the conservatism

that is incorporated into the WHRA model and provides some assurance that risks to wildlife are not

underestimated. The exception is manganese, for which the predicted concentration was 63% lower than

the mean measured concentration. However, the predicted manganese concentration still falls inside the

range of measured concentrations.

Table 21-1 Measured versus Predicted Aquatic Plant Concentrations

Chemical

Measured Concentration [mg/kg-dw]

Predicted Concentration in WHRA (Existing

Condition)

Percent Difference1

(%) Min Mean Max Count

Total Antimony (Sb) 5.00E-03 1.18E-02 3.41E-02 5 2.80E+00 23,585

Total Chromium (Cr) 2.00E-01 3.68E-01 1.00E+00 5 1.47E+01 3,897

Total Manganese (Mn) 1.56E+03 1.98E+04 3.69E+04 5 7.35E+03 -63

Total Selenium (Se) 5.00E-02 6.00E-02 7.60E-02 5 1.89E+00 3,043

Total Thallium (Tl) 2.50E-03 5.36E-03 7.90E-03 5 1.36E+00 25,232 NOTE: 1 Percent difference compares predicted concentration (existing condition) in the WHRA with mean measured

concentration in aquatic plant samples.

Teck acknowledges that additional or enhanced management or monitoring may be identified through

ongoing consultation with potentially affected Aboriginal communities. Teck is committed to developing

or incorporating additional elements to its program, whether at a community, project or regional level,

where feasible and appropriate.



SOC 22

Fort McKay requests that Teck provides references for the weights of wildlife species used in the

wildlife health assessment and confirms that they are representative of wildlife found in the LSA.

Teck Response:

General physical characteristics of the wildlife species assessed in the WHRA are described in Volume 3,

Section 13.5.1.3 of the Project Update. The weights of these wildlife species are referenced in Volume 3,

Appendix 12C1, Table 12C1-19 of the Project Update. In the absence of site-specific body weight data,

the WHRA relied on the following references for weights of wildlife species:

• British Columbia Ministry of Environment, Lands and Parks. 2001. Animal Weights and their Food

and Water Requirements, Resource Document 1996 (minor updates 2001). Environment and

Resource Division, Water Management Branch, Water Quality. Available at:

http://www.env.gov.bc.ca/wat/wq/reference/foodandwater.html.

• Dunning, Jr., J.B. [ed.]. 2008. CRC Handbook of Avian Body Masses, Second Edition. CRC Press,

New York, NY.

• Government of Canada. 2012. Module C: Standardization of wildlife receptor characteristics. March

2012. In: Federal Contaminated Sites Action Plan (FCSAP) Ecological Risk Assessment Guidance.

ISBN 978-1-100-22282-0. Cat. En14-19/1-2013E-PDF.

• Nagy, K.A., I.A. Girard and T.K. Brown. 1999. Energetics of free-ranging mammals, reptiles, and

birds. Annu. Rev. Nutr. 19: 247–277.

• U.S. EPA (United States Environmental Protection Agency). 1993. Wildlife Exposure Factors

Handbook. Volumes I and II. Office of Research and Development. ORD. EPA-600-R-93-187.

December 1993.

• U.S. EPA OSW (United States Environmental Protection Agency Office of Solid Waste). 1999.

Screening Level Ecological Risk Assessment Protocol for Hazardous Waste Combustion Facilities,

Volume I Peer Review Draft. U.S. EPA Region 6. Multimedia Planning and Permitting Division.

Center for Combustion Science and Engineering. Office of Solid Waste.

These references are commonly used in ecological risk assessments and offer a reasonable account of

wildlife body weights in the absence of site-specific information. The weights of wildlife species used in

the WHRA are considered representative of wildlife found in the terrestrial LSA.

http://www.env.gov.bc.ca/wat/wq/reference/foodandwater.html



SOC 23

There is a discrepancy in the diets of the wolverine used in the Teck updated EIA (wildlife health

and wildlife habitat assessments). This would change the predicted wolverine habitat use and

chemical exposure through ingestion. The correct diet should be determined and the assessment

predictions adjusted.

Teck Response:

For the purpose of the WHRA (see Volume 3, Section 13 of the Project Update), the wolverine’s diet is

assumed to “consist of 90% small mammals, 5% terrestrial invertebrates and 5% berries.” This

information was adopted from the Committee on the Status of Endangered Wildlife in Canada

(COSEWIC 2003) and Alberta Environment and Sustainable Resource Development (ESRD 2015).

ESRD (2015) states that the “bulk of [a wolverine’s] diet consists of mice, squirrels, grouse and marmots

and may include larger animals.” As such, the WHRA assumes that the wolverine diet consists primarily

of small mammals. The updated wildlife assessment (see Volume 3, Section 11 of the Project Update)

acknowledges that a large proportion of a wolverine’s diet may include scavenged ungulates such as

moose, when available. Nonetheless, shifting the wolverine diet to primarily include large ungulates (like

moose) would not change the conclusions of the WHRA.

Table 23-1 compares predicted concentrations of six chemicals of potential concern (COPC) (i.e., arsenic,

cadmium, chromium, lead, nickel and vanadium) in moose and small mammals. As Table 23-1 shows,

tissue concentrations differed between small mammals (used in the WHRA) and moose. However,

predicted concentrations of some COPC were greater in moose, but for other COPC, concentrations were

greater in the small mammals.

The risk estimates presented in the WHRA for wolverine (expressed as hazard quotients [HQs]) are based

on the assumption that small mammals make up most of the wolverine diet. As Table 23-1 shows, none of

the predicted HQs for wolverine exceeded 1.0, suggesting that the risks are low. In cases where the

predicted concentration of COPC in moose is lower than the predicted concentration in small mammals,

the HQs would be less than those presented in the Project Update. Although some HQs would increase if

the WHRA assumed that wolverine primarily scavenge and consume ungulates, the revised HQs would

still be less than 1.0. For example, a 271% increase in the HQ for arsenic would not result in the

benchmark of 1.0 being exceeded. In other words, if the percent difference in concentration between

moose and small mammals is directly multiplied by the wolverine HQ based on small mammal

consumption, the HQs would still remain below 1.0. Therefore, if the WHRA were to assume that

wolverine primarily consume large ungulates such as moose rather than small mammals, the overall

findings of the assessment would not change.



Table 23-1 Moose and Small Mammal COPC Concentrations, Base Case and Application Case

Assessment Case COPC

Concentration [mg/kg-dw] Percent Difference1 in

Concentration (%)

Wolverine HQ based on Small Mammal

Consumption Moose Small

Mammal

Base Case Arsenic 1.6E-01 4.3E-02 271 2.1E-03

Cadmium 1.2E-01 5.5E-01 -78 5.4E-02

Chromium 2.2E+00 1.3E+00 75 2.4E-02

Lead 2.2E-01 1.3E+00 -83 1.0E-02

Nickel 4.9E-01 4.0E+00 -88 7.8E-03

Vanadium 5.2E-01 3.1E-01 67 6.8E-03

Application Case

Arsenic 1.7E-01 4.3E-02 306 2.1E-03

Cadmium 1.3E-01 5.5E-01 -76 5.4E-02

Chromium 2.8E+00 1.3E+00 120 2.4E-02

Lead 2.4E-01 1.3E+00 -81 1.0E-02

Nickel 5.0E-01 4.0E+00 -88 7.8E-03 Vanadium 5.3E-01 3.1E-01 68 6.9E-03

NOTE: 1 Percent difference calculated as: [(Moose - Small Mammal)/Small Mammal]

References

COSEWIC (Committee on the Status of Endangered Wildlife in Canada). 2003. COSEWIC Assessment

and Update Status Report on the Wolverine, Gulo gulo. Eastern Population and Western

Population in Canada.

ESRD (Alberta Environment and Sustainable Resource Development). 2015. Fish and Wildlife – Wildlife

Species – Mammals – Weasels & Related – Wolverine (Gulo gulo).



Mitigation and Monitoring

SOC 24

Fort McKay requests that Teck summarizes the scientific support for the planned underpass

dimensions for maintaining connectivity. In addition, Fort McKay requests that Teck discusses

other options to allow wildlife passage and connectivity in the Athabasca River corridor such as

additional underpasses, overpasses, and alternate bridge designs. The feasibility and costs of

options should also be discussed.

Teck Response:

The conceptual Athabasca River bridge design includes a large open span on both sides of the river,

between the high watermark and bridge abutments. These open spans provide a north-south passageway

for wildlife under the bridge that are more than 2.5 m high (current plans exceed 10 m) and more than

10 m wide (see Volume 1, Section 10.4.1 of the Project Update). The open-span underpass design (also

known as a viaduct or flyover design) allows existing riparian habitat to remain both within, and adjacent

to, the underpass, which generally improves the likelihood that wildlife will use these areas as crossing

locations.

Large ungulates, in particular, prefer an open underpass design that is short, and as wide and as tall as

possible (Cramer et al. 2015; Clevenger and Huijser 2011). This style of open-span design is considered

more successful at passing large ungulates than other underpass designs (e.g., culverts) (Cramer 2013).

Clevenger and Waltho (2004) found that use of newly constructed underpasses by elk and deer was

positively correlated and partially explained by structure height and width, while Cramer (2013) and

Schwender (2013) suggest that height of the structure is less important than width for deer passage.

Moose also appear to select wide underpasses (Olsson and Seiler 2012), perhaps because these structures

provide visibility and escape routes from predators (Cramer et al. 2015). In their Wildlife Crossing

Structure Handbook, Clevenger and Huijser (2011) recommend a minimum underpass height of 4.5 m

and minimum width of 12 m to allow passage for large ungulates.

High and wide, open-span bridge underpasses are also recommended for most other large-sized mammals

(e.g., black bear) and can be readily adapted (e.g., by planting vegetation close to passages and providing

artificial cover within the structure), for small and medium-sized mammals and other species, including

amphibians (Grilo et al. 2008; Clevenger 2011; Clevenger and Huijser 2011). Red fox, striped skunk,

beaver, garter snake, and rare or elusive species such as wolverine and Canada lynx have been observed

passing through open-span underpasses (Clevenger et al. 2009; Clevenger 2013). Low human

disturbance, both within and surrounding crossing structures, is key for many of these species (Grilo et al.

2008; Clevenger and Huijser 2011). Managing human activity at crossing locations will be addressed in



the access management plan, following consultation with Aboriginal communities (including Fort

McKay). Crossing areas under the proposed bridge will include signage to discourage human use as well

as wing fencing along the approach. Clevenger (2011) recommends installing wing fencing to guide

animals to the passage and help prevent traffic-related incidents.

These findings suggest that the open-span underpass design associated with the proposed Athabasca River

bridge will accommodate the passage of wildlife that travel the Athabasca River corridor. Data from

Clevenger et al. (2009) indicate that wildlife underpasses similar to those proposed for the Athabasca

River bridge provide passage for large ungulates in the Bow Valley corridor. In addition, monitoring

under Suncor’s Steepbank River bridge has documented moose using the 4 m wide open-span

passageways on either side of the river (Boulton 2016, pers. comm.).

Teck has identified that the wildlife mitigation and monitoring plan (WMMP) will include, among other

measures determined through engagement with regulators, Aboriginal communities (including Fort

McKay) and stakeholders:

• monitoring during all Project phases to evaluate potential effects of the Project on wildlife movement

patterns

• mitigation measures to reduce sensory disturbance to wildlife and wildlife movement

• measures to manage Project influences associated with mortality risk (direct and indirect)

References

Boulton, M. 2016.Senior Environmental Advisor, Suncor Energy. Personal communication. Email dated

February 9, 2016.

Clevenger, A.P. 2011. Planning Considerations for Wildlife Passage in Urban Environments. Best

Practice Guideline, Government of Alberta, Alberta Transportation.

Clevenger, A.P. 2013. Mitigating highways for a ghost: Data collection challenges and implications for

managing wolverines and transportation corridors. Northwest Science 87(3): 257–264.

Clevenger, A.P. and N. Waltho. 2004. Long-term, year-round monitoring of wildlife crossing structures

and the importance of temporal and spatial variability in performance studies. In Proceedings of

the 2003 International Conference on Ecology and Transportation. Irwin, C.L., P. Garrett and

K.P. McDermott [eds.]. Center for Transportation and the Environment, North Carolina State

University, Raleigh, NC.

Clevenger, A.P. and M.P. Huijser. 2011. Wildlife Crossing Structure Handbook. Design and Evaluation

in North America. Publication No. FHWA-CFL/TD-11-003. Department of Transportation,

Federal Highway Administration, Washington D.C., USA.



Clevenger, A.P., A.T. Ford and M.A. Sawaya. 2009. Banff Wildlife Crossings Project: Integrating

Science and Education in Restoring Population Connectivity across Transportation Corridors.

Final report to Parks Canada Agency, Radium Hot Springs, British Columbia, Canada. June 11,

2009.

Cramer, P.C. 2013. Design recommendations from five years of wildlife crossing research across Utah. In

Proceedings of the 2013 International Conference on Ecology and Transportation, 2013. Center

for Transportation and the Environment, North Carolina State University, Raleigh, NC. Available

at: http://www.icoet.net/ICOET_2013/documents/papers/ICOET2013_Paper402A_

Cramer_Formatted.pdf.

Cramer, P. M. Olsson, M.E. Gadd, R. van der Ree, and L.E. Sielecki. 2015. Transportation and large

herbivores. In: Handbook of Road Ecology, First Edition. van der Ree, R., D.J. Smith and C.

Grilo [eds.]. John Wiley & Sons, Ltd

Grilo, C., J.A. Bissonette, and M. Santos-Reis. 2008. Response of carnivores to existing highway culverts

and underpasses: implications for road planning and mitigation. Biodiversity Conservation

17:1685–1699

Olsson, M. and A. Seiler. 2012. The use of a moose and roe deer permeability index to develop

performance standards for conventional road bridges. In IENE 2012 International Conference,

October 21 to 24, 2012. Swedish Biodiversity Centre, Berlin-Potsdam, Germany.

Schwender, M. 2013. Mule deer and wildlife crossings in Utah, USA. Paper 1465. Master’s Thesis, Utah

State University. Available at: http://digitalcommons.usu.edu/etd/1465/. Accessed October 2015.

SOC 25

Fort McKay requests that Teck provides additional detail on the monitoring methods that will be

used to determine the passageway’s effectiveness and maintenance of connectivity in the Athabasca

River corridor. Teck’s response should include a power analysis (e.g., to determine the number of

required cameras) and a contingency plan if the underpass is not effective (e.g., installing

overpasses and underpasses).

Teck Response:




SOC 26

Fort McKay requests that Teck develops a scientifically robust WMMP prior to project approval.

Fort McKay restates its requests to be involved in the WMMP’s development.

Teck Response:


FRONTIER OIL SANDS MINE PROJECT 3 SOC RESPONSES NOISE


Noise

Noise Complaint Process

SOC 27

Fort McKay requests that Teck supports establishing a Noise Complaint Process that will hear and

respect Community complaints around audible noise.

Teck Response:


FRONTIER OIL SANDS MINE PROJECT 3 SOC RESPONSES NOISE


Best Practice beyond Directive 038

SOC 28

Fort McKay requests that Teck will work with the Community of Fort McKay to mitigate impacts

of audible noise, even though it might be in compliance with AER Directive 038.

Teck Response:


FRONTIER OIL SANDS MINE PROJECT 3 SOC RESPONSES AIR QUALITY


Air Quality

Acid Deposition and Effects

SOC 29

Fort McKay requests that Teck and AER acknowledge that fugitive-dust related base cation

emissions cannot be used in offsite PAI calculations as the expectation is that there will be no or

minimal offsite dust deposition.

Teck Response:

Teck plans to implement dust control measures to manage fugitive dust emissions (see Volume 3,

Section 4.4.1 of the Project Update); however, a portion of these fugitive emissions will be unavoidably

transported and deposited outside the Project disturbance area (PDA). Although dust management

practices at mines are improving, it is not expected that mining operations in the future will be 100%

dust-free due to the nature of extracting and transporting the ore from the mine pits to the extraction

operations. Although these dust emissions have the benefit of neutralizing acidic emission contributions,

Teck acknowledges that managing fugitive dust emissions remains a priority.

The approach used to evaluate fugitive dust emissions in the Project Update is more representative of

existing and future conditions than the Integrated Application, which did not consider fugitive dust

emissions. Although there is some uncertainty with estimating fugitive dust emissions, Teck considers the

use of the updated base cation deposition appropriate.

The Project is a minimal source of sulphur compound emissions, and Teck recognizes that appropriate

NOX emission controls are required to reduce the nitrogen compound emissions. For this reason, Teck

plans to manage NOX emissions by adopting dry low NOX +1 (or equivalent) technology for the

cogeneration facilities and using mine fleets that meet Tier IV emission standards.



Co-generation NOx Emission Limits

SOC 30

Fort McKay requests that Teck and the regulators acknowledge that Fort McKay considers that

BATEA for co-generation units is SCR and Fort McKay cannot support the NOx emission limits

currently being proposed by Teck for its co-generation units.

Teck Response:

See Key Theme – Agreement and Regulator Requests (Section 2.4) and the response to AER Round 5

SIR 48.

SOC 31

Fort McKay requests that the regulators acknowledge that no NOx approval limits should be set

for the co-gen units at this time and if an EPEA approval is issued for the project it should indicate

that NOx emission limits will established for these units when design details for the unit are being

finalized and equipment procurement is planned to occur within a year period.

Teck Response:




Compliance or Attribution Continuous Ambient Air Quality Monitoring Requirements

SOC 32

Fort McKay requests that Teck confirms that regardless of regulatory requirements Teck will

install a continuous ambient air monitoring station between its central processing facility and Fort

McKay and will consult with Fort McKay on the exact siting of this station.

Teck Response:




Air Emission and Ambient Air Monitoring

SOC 33

Fort McKay requests that Teck confirms with Fort McKay its expectations regarding support for

and participation on CEMA and WBEA and that this issue is addressed in any Environmental

Agreement the Community enters into with Teck.

Teck Response:


FRONTIER OIL SANDS MINE PROJECT 3 SOC RESPONSES GROUNDWATER


Groundwater

Seepage Control System

SOC 34

Fort McKay requests that Teck provides the opportunity to review annually performance reports

on the seepage control wells and estimates of the percent of process-affected seepage captured by

the wells.

Teck Response:


SOC 35

Fort McKay requests that Teck consults with the Community on whether or not it is considered

feasible to install the interceptor trench earlier, i.e., before operations cease, if there are indications

of process-affected seepage flowing downgradient of the interceptor wells that might travel beyond

the proposed location of the interceptor trench by the time of closure.

Teck Response:


FRONTIER OIL SANDS MINE PROJECT 3 SOC RESPONSES GROUNDWATER


SOC 36

Since far future seepage modelling suggests the potential for off-site migration to the southeast of

the ETAs, Fort McKay requests that Teck considers the alternative of continuing to operate the

active hydraulic control system (i.e., with pumping wells) for a longer period of time beyond

operations.

Teck Response:


FRONTIER OIL SANDS MINE PROJECT 3 SOC RESPONSES HYDROLOGY/SURFACE WATER


Hydrology/Surface Water

Athabasca River and Tributary Water Use

SOC 37

Fort McKay requests that Teck drops all plans for using tributary water as a fresh water source

and obtains its entire fresh water supply from the Athabasca River.

Teck Response:

As requested by Fort McKay, Teck has altered its plans for using tributary water as a fresh water source.

See the response to AER Round 5 SIR 31 for further discussion.

SOC 38

Fort McKay requests that, should Teck not change its Water Act application, AER deny Teck’s

proposal to use pristine water from tributaries and diversion channels associated with the Frontier

Project.

Teck Response:



SOC 39

Fort McKay requests that Teck ensures that all pristine water in the stream diversion system is

diverted around the project and not through the OSSP situated in the Unnamed Creek 2 valley.

Teck Response:



FRONTIER OIL SANDS MINE PROJECT 3 SOC RESPONSES WATER QUALITY, FISH AND FISH HABITAT


Water Quality, Fish and Fish Habitat

Process Water Seepage

SOC 40

Fort McKay requests that Teck provides contingency plans and potential mitigation if the barrier

walls and seepage capture of the External Tailings Areas do not perform as anticipated in

preventing seepage from contaminating groundwater and surface waters.

Teck Response:


SOC 41

Fort McKay requests that Teck assesses the potential impacts of discharging up to 40 L/s

(3500 m³/d; Figure 7-13) of process-affected seepage to the fish habitat compensation lake.

Teck Response:

See the response to CEAA Round 5 SIR 167b.



Surface Water and Sediment Quality

SOC 42

Fort McKay requests that Teck adds dibenzothiophene in sediments to the list of monitored

substances for any watercourses downstream of the project, plus sediments of pit lakes and the

FHCL.

Teck Response:


SOC 43

Fort McKay requests that Teck provides assurance that the analytical laboratories contracted for

water and sediment analyses are capable of achieving detection limits at criteria intended to protect

aquatic life.

Teck Response:

Analytical laboratories contracted for Project water and sediment analyses are accredited by the Canadian

Association for Laboratory Accreditation Inc. (CALA). Under CALA’s accreditation program,

performance evaluation assessments are conducted annually for laboratory procedures, methods and

internal quality control. Where achievable, the detection limit for each substance analyzed is less than the

corresponding water or sediment quality guideline. Detection limits less than water or sediment quality

guidelines may not be achievable for all samples (e.g., where dilutions are required because of high

dissolved solids or other matrix effects). Teck will continue to confirm that appropriate detection limits

(i.e., less than water or sediment quality guidelines) are used for all water and sediment analyses

conducted for the Project.

In some cases, laboratories that are not CALA-accredited (e.g., university laboratories) may be used for

water and sediment analyses. Non-accredited laboratories would be used only in rare cases where they

provide a specialized service that is not available at an accredited laboratory.



Muskeg and Overburden Drainage – Mercury

SOC 44

Fort McKay requests that Teck models mercury and methylmercury loadings to the FHCL and any

downstream waters, including the Athabasca River, considering uptake by piscivorous fish. Models

should consider the potential methylmercury production and augmentation of mercury export by

muskeg and overburden drainage activities under both the Application and Planned Development

(cumulative impact) cases.

Teck Response:

Mercury and methyl mercury loadings to the fish habitat compensation lake (FHCL) will be addressed in

the detailed fisheries offsetting plan (DFOP) for the Project. Similar to the work completed for the Shell

Jackpine Mine Expansion (JME), Teck will use regional data to describe mercury and methyl mercury

concentrations in water, benthic invertebrates, plankton, zooplankton and fish, and will rely on literature

values for anticipated rates of increase. Literature values will be drawn mainly from flooded hydroelectric

reservoirs in northern Canada and Europe. Similar to the work completed for the JME, a conservative

approach will be adopted whereby the highest rates of increase in mercury concentrations (in water and

biota) observed in flooded reservoirs will be applied to the FHCL. This estimate will provide a reasonable

“worst-case” prediction of mercury concentrations and an anticipated timeline to return to baseline

conditions.



Pit Lake Residual Toxicity and Research

SOC 45

Fort McKay requests that Teck commits to ongoing participation in pit lake research, including

studies of bottom sediments and possible contaminants transfer through the aquatic food chain, as

well bioturbation and wind-induced sediments resuspension.

Teck Response:


SOC 46

Fort McKay requests that Teck provides results and/or reports on any studies into pit lake

sediments and transfer of contaminants to aquatic food webs.

Teck Response:


SOC 47

Fort McKay requests that Teck provides further discussion about the fate and transport of

napthenic acids and PAHs over time in its pit lakes, and discuss those substances that are expected

to exceed effects benchments, notably in sediments.

Teck Response:

See the response to CEAA Round 5 SIR 141e.



Derivation of Site-specific Guidelines

SOC 48

Fort McKay requests that Teck accepts published CCME guidelines for all substances for which

they are available until such time as CCME or a provincial government agency evaluates and

approves the newly-derived CEBs presented by the company.

Teck Response:

This request is identical to Fort McKay SOC 103i (June 2012). Teck’s response (provided February 2013)

is reproduced here for ease of review.

Published CCME guidelines were applied in the early stages of the assessment to help

provide an initial screening of substances of concern. However, in the formal assessment

of potential Project effects, application of the default generic CCME Canadian

Environmental Quality Guidelines (CEQGs) is not considered to provide a reliable basis

for assessing probability or magnitude of harm. CCME (1999) acknowledges the role of

refinements to the generic CCME guidelines, stating that “…although CEQGs are

nationally endorsed, provincial and territorial jurisdictions may have or may develop

their own science-based environmental assessment tools (e.g., criteria, guidelines,

objectives and standards), which may be implemented within their respective

jurisdictions.” CCME (1999) also recognizes that CEQGs often form the scientific basis

upon which further site-specific criteria, guidelines, objectives or standards are

developed.

Canadian Water Quality Guidelines (WQGs) are developed with the goal “…to protect

all forms of aquatic life and all aspects of the aquatic life cycles, including the most

sensitive life stage of the most sensitive species over the long term” (CCME 1999). That

is, a value above a WQG indicates the possibility, but not probability or magnitude, of

adverse effects. The WQGs are a management tool intended to provide a high level of

protection to aquatic life under all environmental scenarios but do not directly consider

site-specific factors.

In the early stages of the assessment, the CEQGs are not dismissed outright, but rather

are refined and customized to be more relevant to the Project area. CCME not only

acknowledges the role of CEQG refinement, but outlines a technical methodology for

such refinements in the CCME (2007) protocol for the derivation of WQGs. CCME

(2007) states that “…in some situations it may be necessary or advantageous to derive a



site-specific guideline (or objective)” to “account for unique conditions and/or

requirements at the site under investigation”. Importantly, their derivation protocol

includes site-specific exposure and toxicity-modifying factors (ETMFs) and the

application of the species sensitivity distribution (SSD) concept. Under CCME (2007)

guidance, the preferred method for examining effects to the aquatic ecosystem is a SSD

(Posthuma 2002; CCME 2007). The use of species sensitivity distributions is based on

the recognition that not all species are equally susceptible to toxicants. The basic

assumption of the SSD is that the sensitivities of a set of species can be described by a

particular distribution (e.g., normal, logistic, gamma), and that variation exists among

species in terms of toxic response to substances of concern.

Peer review of Project-derived individual CEBs by the CCME or another government

environmental agency would be desirable. However, the rate at which individual

substances have been formally assessed by CCME using the SSD method is not sufficient

to support an analysis of the many substances screened into the Project Update.

Moreover, the derivation procedures described in CCME (2007) are intended to

accommodate site-specific derivations; defaulting to generic WQGs would be

unnecessarily restrictive. Although there have been some discussions regarding a regional

initiative to harmonize CEB derivations across projects in Northern Alberta, no such

process has been formalized to date.

References

CCME (Canadian Council of Ministers of the Environment). 1999. Canadian water quality guidelines for

the protection of aquatic life: Introduction. In: Canadian Environmental Quality Guidelines,

1999, Canadian Council of Ministers of the Environment, Winnipeg, Manitoba.

CCME. 2007. A protocol for the derivation of water quality guidelines for the protection of the aquatic

life 2007. In: Canadian Environmental Quality Guidelines, 1999, Canadian Council of Ministers

of the Environment, Winnipeg, Manitoba.

Posthuma, L., G.W. Suter II and T.P. Traas. 2002. Species Sensitivity Distributions in Ecotoxicology.

Lewis Publishers. Boca Raton.



SOC 49

Fort McKay requests that Teck provides a tabulated comparison of CCME guidelines to its site-

specific guidelines (CEBs) for those substances where guidelines exist.

Teck Response:

This request is identical to CEAA Round 5 SIR 140c. Teck’s response is reproduced here for ease of

review.

The updated surface water quality assessment includes a series of tables (see Volume 3,

Section 7.4, Tables 7-6 to 7-16 of the Project Update) that list water quality guidelines

for the protection of aquatic life and chronic effects benchmarks. These values are

provided in table format for ease of comparison.

SOC 50

Fort McKay requests that Teck address the potential impact and toxicity of mixtures of

contaminants that might all occur simultaneously

Teck Response:

The Project Update (see Volume 3, Section 7.11) considers multiple lines of evidence in assessing

potential effects on aquatic health. These include findings from laboratory-based studies of toxicity of

mixtures and water quality predictions of acute and chronic toxicity. The assessment evaluates potential

changes in water quality in waterbodies and watercourses based on dynamic water quality modelling

(described in Volume 3, Section 7.4 of the Project Update). This modelling included simulations of acute

and chronic toxicity that are based on actual toxicity testing of mixtures of oil sands process waters.

Whole-effluent acute and chronic toxicity are considered the most relevant indicators of potential effects

of oil sands release waters on aquatic organisms because they represent the whole mixture of constituents

potentially entering the aquatic receiving environment. These simulations are conservative because they

account for dilution of toxic units (TUa and TUc, estimated following the procedures of AEP 1995), but

not potential mitigating factors such as degradation and other factors that modify toxicity in the receiving

environment (e.g., hardness, dissolved organic carbon).



For individual substances, chronic effects benchmarks (CEBs) formed the basis of the effects assessment

component of the water-column-based aquatic health assessment. For some substances, the CEBs (see

Volume 3, Appendix 7C of the Project Update) are based on methods that consider the potential mixture

toxicity of related constituents. For example:

• CEBs for polycyclic aromatic hydrocarbons (PAHs) (those based on the target lipid model; McGrath

and Di Toro 2009) consider that PAHs may act additively via non-polar narcosis

• CEBs for naphthenic acids were based on toxicity testing of representative fractions of the naphthenic

acid mixtures

• CEBs for total dissolved solids considered testing of ionic mixtures that represented the major ions

originating from the Project

The updated aquatic health assessment (see Volume 3, Section 7.11 of the Project Update) compares

predicted concentrations of individual substances in fish tissue to applicable fish tissue effects

benchmarks. This provided an additional method of aquatic health effects assessment that was appropriate

for bioaccumulative substances.

Teck expects that chronic and acute toxicity testing will be part of the monitoring requirements outlined

in the anticipated Environmental Protection and Enhancement Act (EPEA) approval for the Project, as it

is a standard line of evidence in provincial and federal approvals, permits and authorizations. These data

will be compared to assessment predictions and will provide an important line of evidence to confirm

literature-based predictions. Teck will also continue to engage and consult with potentially affected

Aboriginal communities to address concerns related to aquatic health and traditional land use, and to

discuss Project-specific monitoring programs and results throughout the life of the Project.

References

AEP (Alberta Environmental Protection). 1995. Water Quality Based Effluent Limits Procedures Manual.

Environmental Protection. Edmonton, Alberta.

McGrath, J.A. and D.M. DiToro. 2009. Validation of the target lipid model for toxicity assessment of

residual petroleum constituents: monocyclic and polycyclic aromatic hydrocarbons. Environ.

Toxicol. Chem. 28: 1130–1148.



Aerial Emissions and Snowmelt Concentrations

SOC 51

Fort McKay requests that Teck provides an update of the cumulative impacts of aerial emissions in

surface waters, including any further snow survey results.

Teck Response:


SOC 52

Fort McKay requests that Teck commits to sharing with the Community snowmelt data that exceed

water quality guidelines, as soon as possible, not just upon request.

Teck Response:




Loss of Traditionally Significant Surface Waters

SOC 53

Fort McKay requests that Teck meets with Fort McKay to discuss how it might support the

Community with access to and preservation of special places, including but not limited to,

habitation sites in the Frontier Project lease and the Moose Lake area.

Teck Response:




Fish Rescue from Destroyed or Diverted Streams and Lakes

SOC 54

Fort McKay requests that Teck confirms that it will rescue all fish species from all aquatic habitats

that will be destroyed or diverted, that support fish during any season, and that it will not limit the

rescue operations to only those waters that support large-bodied fish species.

Teck Response:

See Key Theme – Agreement and Regulator Requests (Section 2.4) and the response to AER Round 5

SIR 90.



Tissue Residue Guideline - Mercury

SOC 55

Fort McKay requests that Teck provides justification and further information about the source of

information, species and size of fish that show a current concentration that is very low

(0.058 mg/kg), and that presumably was used in the prediction of a future concentration that is

correspondingly low.

Teck Response:

The estimated predevelopment and Application Case mercury fish tissue concentrations were calculated

using a mercury bioconcentration factor (BCF) that was based on the central tendency (95% upper

confidence limit of the mean [95UCLM]) of observed fish tissue concentrations (see additional detail

provided below). The 95UCLM was considered appropriate because (i) it represents a reasonable worst-

case average accumulation of mercury (i.e., highest 95UCLM of multiple years, based on fish species

with the highest observed mercury accumulation) for fish in the receiving environment, and (ii) it is

consistent with the methods applied for estimating mercury exposure in people consuming fish. Although

individual fish tissue concentrations identified as part of regional monitoring might exceed this 95UCLM,

these individual fish would not represent exposure in the fish population as a whole. Furthermore, the

estimated predevelopment mercury fish tissue concentration does not represent an estimate of the existing

or current mercury fish tissue concentrations in the region; the Application Case estimate (which is almost

seven times higher than the predevelopment estimate) is anticipated to be more consistent with the current

average mercury fish tissue concentrations in the region.

Predevelopment and Application Case fish tissue estimates were based on water quality predictions for

predevelopment and Application Case, respectively, and the estimated mercury BCF. As presented in

Volume 3, Section 7.11.5, Table 7-46 of the Project Update:

• The estimated mercury fish tissue concentration (i.e., 0.058 mg/kg wet weight) for predevelopment

conditions was calculated by multiplying the predevelopment median concentration in water

(0.0000004 mg/L) by the mercury BCF (145,673 L/kg).

• The estimated mercury fish tissue concentration (i.e., 0.39 mg/kg wet weight) for the Application

Case was calculated by multiplying the predicted Application Case maximum median concentration

in water (0.0000027 mg/L) by the mercury BCF (145,673 L/kg).



Volume 3, Appendix 12B, Section 12B.9 of the Project Update describes the method for calculating

BCFs for fish. The mercury BCF was calculated based on the predicted predevelopment surface water

quality in the Athabasca River (downstream of Redclay Creek) and the fish mercury exposure point

concentration used in the human health risk assessment for this location.

For additional information on mercury concentrations in fish tissues based on monitoring data, see

Volume 3, Appendix 12B, Section 12B.7 of the Project Update. These data were used to derive the

mercury BCF. As described in Section 12B.7, the most recent fish tissue quality data are available from

the Regional Aquatics Monitoring Program (RAMP 2015) and focus on mercury concentrations in

specific fish species (e.g., lake whitefish, northern pike and walleye). Baseline data used in the Project

Update were entirely based on the most recent three years of available data from RAMP (i.e., 2005, 2008

and 2011) and focus on the Athabasca and Muskeg rivers given their proximity to the Project. The

maximum 95UCLM for walleye (based on the most recent three years of available mercury data) was

used to characterize baseline mercury concentrations in fish tissue. Mercury concentrations in walleye

were selected because they represented the highest mercury concentrations of the three fish species. The

RAMP fish tissue data for mercury were collected from walleye measuring 212 mm to 635 mm fork

length and 91 g to 3,060 g total weight.

The site-specific mercury BCF estimated for the Project Update (145,673 L/kg) is substantially higher

than the recommended values for mercuric chloric (3,530 L/kg) and methylmercury (11,168 L/kg)

(U.S. EPA 1999). Therefore, the site-specific value adds conservatism to the assessment because it results

in higher predicted mercury tissue concentrations than these recommended values.

References

RAMP (Regional Aquatics Monitoring Program). 2015. Fish Tissue Program Data. Available at:

http://www.ramp-alberta.org/data/Fisheries/Tissue/Tissue.aspx. Accessed December 2015.

U.S. EPA (United States Environmental Protection Agency). 1999. Screening Level Ecological Risk

Assessment Protocol. Appendix C: Media-To-Receptor BCF Values. U.S. EPA Office of Solid

Waste, Multimedia Planning and Permitting Division, Center for Combustion Science and

Engineering.



SOC 56

Given that Teck’s calculation of future fish tissue residue for mercury under the application case is

close to seven times higher than the current level, Fort McKay requests that Teck addresses

impacts to wildlife consumers of fish that might be caused (the future predicted level is more than

ten times higher than the TRG to protect wildlife consumers of aquatic biota).

Teck Response:

The updated surface water quality assessment uses a methyl mercury concentration of 0.058 mg/kg-ww as

an estimate of predevelopment fish tissue concentrations (see Volume 3, Section 7.11.5, Table 7-46 and

Section 7.11.6, Table 7-57 of the Project Update). This value does not represent the actual (or existing)

concentrations of methyl mercury in large predatory fish that were used to describe the potential effects of

the Project on wildlife consumers of fish (piscivorous wildlife) in the wildlife health risk assessment

(WHRA). Those details are provided in Volume 3, Section 13 of the Project Update:

• See Tables 13-22, 13-23 and 13-31 for fish methyl mercury concentrations used to assess potential

effects on piscivorous wildlife (horned grebe, whooping crane and river otter).

• See Section 13.5.1.3 for a list of piscivorous wildlife species identified as receptors of potential

concern (ROPC) and included in the WHRA.

• See Section 13.7.2 for results and discussion of the wildlife effects analysis related to the methyl

mercury concentrations.

The existing methyl mercury fish concentration used in the WHRA is 0.44 mg/kg-ww.

Results of the WHRA as it relates to methyl mercury are summarized as follows:

River Otter: Predicted methyl mercury hazard quotients (HQs) for river otter exceeded 1.0 for the

existing condition, Base Case, Application Case, PDC, pit lakes and fish habitat compensation lake

(FHCL) scenarios. Fish consumption accounts for 99% of this species’ exposure to methyl mercury.

However, HQ values greater than 1.0 are due, in part, to conservative assumptions applied in the WHRA.

For example:

• Measured mercury concentrations were based on large-bodied sport fish (i.e., walleye) ranging in

length from 200 mm to 600 mm. However, river otters generally prefer fish ranging from 150 mm to

170 mm (Erlinge 1968).

• River otters are expected to consume a variety of herbivorous and piscivorous fish species that would

accumulate various levels of mercury. The WHRA conservatively assumes they eat only walleye, a

predatory fish that tends to accumulate higher levels of mercury compared to smaller fish such as lake

whitefish.



Based on a more realistic set of exposure parameters, the HQs did not exceed 1.0 for the river otter (see

Volume 3, Section 13.7.2.3 of the Project Update).

Horned Grebe and Whooping Crane: Predicted methyl mercury HQs for the horned grebe and

whooping crane exceeded the benchmark of 1.0 in several scenarios. These risks were also based on the

assumption that the horned grebe and whooping crane would exclusively eat large-bodied sport fish

(i.e., walleye) ranging in length from 200 mm to 600 mm. In reality, these fish would be too large for the

horned grebe and whooping crane to eat. Typically the grebe preys on fish that are between 20 mm and

120 mm in length (Piersma 2009), while the whooping crane tends to prey upon minnows that are less

than 20 mm in length (Sonnenblick et al. 2012). As such, the fish size and mercury concentrations

assumed for these two birds are probably unrealistic. With more realistic exposure parameters

(e.g., smaller fish sizes), total mercury concentrations in fish consumed by horned grebe and whooping

crane are expected to be below 0.1 mg/kg-ww. Assuming that existing fish mercury concentrations were

0.1 mg/kg-ww, methyl mercury HQs would not exceed the benchmark of 1.0 for the horned grebe and

whooping crane (see Volume 3, Section 13.7.2.2 of the Project Update).

References

Erlinge, S. 1968. Food studies on captive otters Lutra lutra L. Oikos 19: 259–270.

Piersma, T. 2009. Body size, nutrient reserves and diet of Red-necked and Slavonian Grebes Podiceps

grisegena and P. auritus on Lake Usselmeer, The Netherlands. Bird Study 35: 1, 13–24.

Sonnenblick, K., S. Klosiewski and B.B. Kienbaum. 2012. A Closer Look at Whooping Cranes:

Whooping Crane Education in Wisconsin and Eastern North America. Wisconsin Department of

Natural Resources. PUB-ER-661.



Accounting for Residual Impacts on Fish Abundance and Productivity

SOC 57


i. clarifies statements that indicate effects on fish abundance are not anticipated in the aquatics

LSA, when it is known that the compensation lake will not likely account for all losses in the

LSA;

ii. provides values and percent reduction of low flows (e.g., 7Q2, 7Q10) in addition to reduction in

mean annual flows, including whether there might be occasions when there is no flow in these

watercourses compared to the current scenario, since fish might occur in the lower reaches of

Big and Redclay creeks during any open water season;

iii. identifies which species will lose habitat in Big Creek and Redclay Creek that will not benefit

from the compensation lake;

iv. justifies ranking residual effects to fish as ‘reversible’ and ‘medium duration’ when the

timespan to reversibility spans several generations of most species; and

v. discusses possible mitigative solutions that might provide additional instream flow needs to

these watercourses rather than gradually diminishing flows over the course of operations, given

the cause of lost habitat in lower Big and Redclay creeks is lack of flow (due to withheld or re-

directed water).

Teck Response:

i. The conceptual fisheries offsetting plan (CFOP) includes a 60 ha fish habitat compensation lake

(FHCL), which would be located in the aquatics LSA and provide a portion of the required offset for

habitat losses associated with the Project. The CFOP also identifies additional offsetting options that

could be used, in whole or in combination, to provide the full offset (see Volume 1, Section 15.4 of

the Project Update). These additional offsetting options include options both within and outside of the

aquatics LSA.

Consultation with stakeholders and regulators regarding these offsetting options is part of the ongoing

development of the offsetting plan. Following consultation, Teck will develop a draft detailed

fisheries offsetting plan (DFOP). This plan will include offsetting measures that are located in the

aquatics LSA to account for all habitat losses in the LSA and maintain habitat productivity and fish

abundance in the LSA.



ii. Predicted changes in low flows (i.e., 7Q10 low flow discharge) for Athabasca River tributaries in the

aquatics LSA are provided in the updated hydrology assessment (see Volume 3, Section 6.4.5.3,

Tables 6-9 to 6-11 of the Project Update). These changes range from no change to small increases in

7Q10 flows for Big Creek and Redclay Creek. Because the predicted changes in low flows are small

and consist of flow increases, these changes are considered to have no potential for adverse effects on

fish or fish habitat.

iii. Some fish species may be affected by predicted habitat changes in lower Redclay Creek and lower

Big Creek, but not benefit from the FHCL. This would include species present in affected habitats but

that are not included in the FHCL’s target fish community (and do not otherwise naturally colonize

the lake).

The target fish community for the FHCL is being developed for the draft DFOP as part of the ongoing

refinement of the offsetting plan, based on consultation with regulators and potentially affected

Aboriginal communities. At present, it is known that the FHCL will include some (but not all) of the

affected fish species since the total number of fish species for the FHCL is less than the number of

species present in the two natural watercourses. However, the FHCL system will be designed to allow

for some level of use by all species that use the Big Creek and Redclay Creek watersheds, should they

choose to access the new habitats.

Fish species documented or assumed to be present in lower Big Creek and lower Redclay Creek

include a number of sport fish, sucker and forage fish species (see Volume 1, Section 15.3.2,

Table 15.3-2 of the Project Update). The FHCL (located in the Redclay Creek watershed) will be

designed to provide a variety of habitats that meet all life stage requirements (i.e., spawning, nursery,

rearing, feeding, overwintering) of the various species of the target fish community. In addition, as

part of the development of the draft DFOP, the FHCL outlet channel will be designed to have a

naturalized, geomorphic channel that will be an analogue of the existing Redclay Creek channel at the

location of the FHCL. This design will provide (i) two-way passage for fish species that use the

natural habitats in Redclay Creek, and (ii) useable channel habitats such as riffle/run sequences and

associated diversity of substrates currently present in Redclay Creek. In combination, the FHCL and

outlet channel will provide a variety of new lake habitats as well as riverine habitats similar to the

adjacent Redclay Creek channel. The design will allow all species that use Redclay Creek to use the

FHCL outlet channel as habitat, and to access the FHCL to use the available lake habitats.

Several of the sucker and forage fish species present in lower Redclay Creek or Big Creek are also

present at the FHCL location, indicating these species can be expected to colonize the FHCL and

outlet channel soon after construction. Migratory fish species from the Athabasca River that use

tributary habitats in either Big Creek or Redclay Creek on a seasonal basis will also be able to access

the newly constructed habitats, should they choose to do so.

Most fish species that occur in lower Redclay Creek or lower Big Creek are either already present at

the planned FHCL location (e.g., longnose sucker, white sucker, brook stickleback, fathead minnow,

finescale dace, lake chub, longnose dace, northern redbelly dace, pearl dace, slimy sculpin and trout-



perch), or are migratory species capable of accessing the new habitats in the FHCL system (e.g.,

Arctic grayling, burbot, northern pike and walleye). Species that use the lower natural creeks and are

unlikely to access the FHCL or outlet channel include yellow perch, flathead chub and spottail shiner,

three species that are generally known to be associated with the Athabasca River and to have limited

distributions in small tributary watersheds (RAMP 2004).

iv. The updated fish and fish habitat assessment (see Volume 3, Section 8 of the Project Update) rates the

predicted effects of habitat changes on fish habitat productivity and fish abundance in the aquatics

LSA as long duration and reversible. The duration scale is based on the duration of the changes

themselves, some of which are permanent. Effects were considered reversible in light of productive

compensation habitats, as described in the CFOP.

Although some time will be required for the newly constructed offsetting habitats to develop to their

full level of habitat productivity, current monitoring data for existing fish habitat compensation lakes

in the oil sands region indicate that initial habitat productivity develops rapidly, with fish populations

colonizing the new habitats as soon as they are available for use. This rapid colonization occurred in

cases where the new habitats were directly connected to natural fish-bearing habitats, as is the case

for the Project’s FHCL. Colonization also occurred most rapidly for species with the shortest

generational time-span (i.e., small-bodied forage fish species).

The full amount of offsetting habitat for the Frontier Project will be provided during construction,

whereas some of the effects of the Project on fish habitat productivity (e.g., effects on lower Redclay

Creek and lower Big Creek) do not occur at the construction snapshot, but rather, 25 years or later

during the diversion, maximum build-out or closure snapshots. This schedule limits the effects of the

delay in the full development of habitat productivity in the offsetting habitats.

v. Teck does not plan to implement further mitigation strategies that would provide additional flows to

Big Creek and Redclay Creek during operations. The current plan already includes appropriate

mitigation measures to reduce flow changes in lower Big Creek and lower Redclay Creek. However,

potential mitigation options may include pumping water within the release water drainage system

(i.e., to redistribute flow releases between the lower Big Creek and lower Redclay Creek) or using a

portion of the water withdrawn from the Athabasca River to supplement the flows in these two

creeks. Appropriate evaluation and consultation of these options would need to be conducted prior to

any changes to the water management plan described in Volume 1, Section 7 of the Project Update.

References

RAMP (Regional Aquatics Monitoring Program). 2004. Oil Sands Regional Aquatics Monitoring

Program (RAMP) 2004: Review of Historical Fisheries Information for Tributaries of the

Athabasca River in the Oil Sands Region. Prepared by Golder Associates Limited for the

Regional Aquatics Monitoring Program (RAMP) Steering Committee. February 2004.



Pit Lakes as Fish Habitat

SOC 58

Fort McKay requests that Teck further explains the functionality as fish habitat and planned

incorporation into local ecosystems of its large end pit lakes that will be located far from fish that

might naturally colonize them.

Teck Response:

The pit lakes are designed primarily as mine closure features. Shallow littoral habitats incorporated into

the lake design provide diverse aquatic habitat for promoting biological productivity. Unlike the fish

habitats that are part of the conceptual fisheries offsetting plan (CFOP), the pit lakes are not part of the

plan to offset the effects of the Project on productive fish habitats. The pit lakes are expected to provide

productive aquatic habitat on the closure landscape in addition to the habitats included in the CFOP.

As described in the responses to AER Round 4 SIRs 19, 20, 21 and 27, the pit lakes closure drainage

system has naturalized geomorphic watercourse channels that will drain the lakes to downstream natural

watercourses where fish-bearing habitats are present. This will allow fish from downstream habitats to

access upstream portions of the closure drainage system and the pit lakes. The central pit lake will be

connected to the fish habitat compensation lake (FHCL) and lower Redclay Creek, and the south pit lake

will connect to fish-bearing habitat in lower Big Creek. The north pit lake will connect to Unnamed

Creek 18, which is not known to be fish-bearing; however, there are fish-bearing habitats farther

downstream (see the response to AER Round 4 SIR 20).

The fish species with the potential to naturally colonize the pit lakes will be those present in the connected

natural fish-bearing watercourses. The central and south pit lakes are connected to tributaries of the

Athabasca River, so it will be possible for additional fish species to access the lakes from the Athabasca

River.

Presence of fish species in the pit lakes would be through colonization from connected downstream

natural habitats, and these will be species that are able to use the geomorphic closure channels (e.g., the

channels are suitable habitat for migration). Although a number of fish species could colonize the pit

lakes, it is likely that fish distribution in the closure drainage system will be similar to the natural

tributaries of the Athabasca River. Regional fish distribution data show that, in most natural Athabasca

River tributaries, the number of fish species present declines upstream away from the Athabasca River.

This observation suggests that not all species in the natural habitats downstream of the pit lakes would

necessarily access the lakes.



Fish populations would likely become naturally established for species whose life stage requirements are

provided by the habitats in the pit lakes, or in combination with the habitats in the adjacent connected

closure channels. The productivity achieved in the pit lakes for each colonizing species will depend on the

species-specific suitability of the habitats that are present.



Fish Habitat Offsetting Plans

SOC 59

Fort McKay requests that Teck summarizes how its calculations (HADD versus “serious harm to

fish”) related to fish habitat offsetting might have changed for the Updated project scenario as a

result of recent amendments to the Fisheries Act (input values, not compensatory plans).

Teck Response:

There have been no changes in the way habitat losses or alterations (formerly referred to as harmful

alteration, disruption or destruction [HADD]) have been calculated or identified in the Project Update

compared to the Integrated Application. As described in both the conceptual fish habitat compensation

plan (see Volume 1, Section 15.3.2 of the Integrated Application) and the conceptual fisheries offsetting

plan (CFOP; see Volume 1, Section 15.3.2 of the Project Update), habitat losses and alterations were

calculated based on the number of affected habitat units (HUs).

As in the Integrated Application, productive fish habitats in waterbodies or watercourse segments were

identified as part of the updated fish and fish habitat assessment (see Volume 3, Section 8.4, Table 8-5 of

the Project Update), and all habitats identified as being affected by the Project were included in HU

calculations. This includes habitats that will be lost (i.e., eliminated) or altered (e.g., flow changes) due to

Project development. Permanent and temporary alterations (e.g., during some operational periods) were

both included in the HU calculations. In identifying affected habitats, no specific consideration was given

to whether the affected habitats and associated fish populations are part of, or support, a commercial,

recreational or Aboriginal fishery.

Differences in the results of the calculations of HU losses or alterations in the Project Update relative to

the Integrated Application are the result of changes to the Project disturbance area (PDA) and drainage

plan, incorporation of additional baseline data, and incorporation of assumed fish distributions in the

affected habitats. These changes are described in the CFOP (see Volume 1, Section 15.4.1 of the Project

Update), and are not the result of the Fisheries Act amendments.



Access Management Plans

SOC 60

Fort McKay requests that Teck consults with the Community about access to lands and waters in

the project area.

Teck Response:

See Key Theme – Agreement and Regulator Requests (Section 2.4). See the response to CEAA Round 5

SIR 162 for an update on the access management planning process for the Project.



Climate Change Impacts to Project

SOC 61

Fort McKay requests that Teck specifically discusses how climate change in addition to industrial

demand might reduce or impact water availability for its project and for fisheries in the Athabasca

River mainstem and project-area tributaries.

Teck Response:

See Key Theme – Climate Change (Section 2.3). See the response to AER Round 5 SIR 66 and

CEAA Round 5 SIR 142 for a discussion of the potential effects of climate change on the mine water

balance and the Athabasca River.



Consultation – Bridge and Monitoring

SOC 62

Fort McKay requests that Teck consults with them about navigation and fisheries concerns and

offsets related to the Athabasca Bridge.

Teck Response:


SOC 63

Fort McKay requests that Teck consults with them about all project-specific aquatic monitoring

plans, including community-based monitoring (CBM).

Teck Response:


FRONTIER OIL SANDS MINE PROJECT 3 SOC RESPONSES VEGETATION AND WETLANDS


Vegetation and Wetlands

Wetlands

SOC 64

Fort McKay requests that Teck develops and participates in research programs focused on wetland

reclamation, with an emphasis on peat-forming wetlands (bogs and fens).

Teck Response:

See the response to CEAA Round 5 SIR 145.

SOC 65

Fort McKay requests that Teck develops best management practices for peatlands in a multi-

stakeholder group (in CEMA or in a group similar to CEMA) acceptable to Fort McKay that

allows for participation by Fort McKay.

Teck Response:


SOC 66

Fort McKay requests that Teck follows up-to-date wetland reclamation guidelines: the Guidelines

for Reclamation to Forest Vegetation in the Athabasca Oil Sands Region, 2nd Edition (Alberta

Environment 2010), and the Guideline for Wetland Establishment on Reclaimed Oil Sands Leases

(Alberta Environment 2008).



Teck Response:

Teck has used the Guidelines for Reclamation to Forest Vegetation in the Athabasca Oil Sands Region,

2nd Edition (AENV 2010), and the Guidelines for Wetland Establishment on Reclaimed Oil Sands

Leases, 3rd Edition (CEMA 2014) in developing the closure, conservation, and reclamation plan

submitted as part of the Project Update (see Volume 1, Section 13). Teck will reference updated versions

of these documents, or their successors, as they become available and use these guidelines to inform

reclamation activities. Teck will also continue to participate in regional committees and research

organizations that include groups such as Canada’s Oil Sands Innovation Alliance (COSIA). Ongoing

research and new guidance documents and frameworks will be reviewed and applied as appropriate to

help meet the Project’s reclamation goals and objectives. This includes guidelines relating to wetland

reclamation.

References

AENV (Alberta Environment). 2010. Guidelines for Reclamation to Forest Vegetation in the Athabasca

Oil Sands Region, 2nd Edition. Prepared by the Terrestrial Subgroup of the Reclamation Working

Group of the Cumulative Environmental Management Association, December 2009. Fort

McMurray, Alberta.

CEMA (Cumulative Environmental Management Association). 2014. Guidelines for Wetland

Establishment on Reclaimed Oil Sands Leases, 3rd Edition. Edited by West Hawk Associates for

the Wetlands and Aquatics Subgroup, Reclamation Working Group, CEMA. Available at:

http://cemaonline.ca/index.php/administration/cat_view/2-communications/18-rwg-

recommendations. Accessed December 2015.

SOC 67

Fort McKay requests that Teck includes Fort McKay in the development and review of wetland

monitoring programs. These monitoring programs should focus on wetlands adjacent to the

Planned Development Area (PDA) to assess the effects of potential hydrologic alterations to intact

wetlands adjacent to the mine disturbance. In addition, a program should be designed and

implemented to mitigate any wetland effects that occur.

Teck Response:




SOC 68

Fort McKay requests that organic soils are salvaged where possible and that direct placement of

these soils is implemented in locations that have a high potential for peatland reformation.

Teck Response:

Teck is planning the direct placement of soil over 6,540 ha, of which 1,110 ha are in areas identified for

reclamation to wetland communities. The areas identified for reclamation to wetland communities in the

closure, conservation, and reclamation (CC&R) plan (see Volume 1, Section 13 of the Project Update) are

those most likely to be suitable for peatland development in the future. Teck will salvage organic soils

and some of these soils will be directly placed in areas identified in the CC&R plan for wetland

reclamation.

As reclamation progresses, additional areas for peatland reformation could be identified. One of the

benefits of progressive reclamation is that it allows an adaptive management approach (for details, see

Volume 1, Section 13.3.4 of the Project Update). This approach provides an opportunity to incorporate

improvements in reclamation techniques into the mine reclamation plan that Teck anticipates will be

required as a condition of the Project approval. This plan will be updated throughout the life of the Project

to reflect these changes.

Teck recognizes that peatlands are an important traditional use area for Aboriginal communities. Teck

will continue to work with potentially affected Aboriginal communities and seek input on the Project’s

reclamation plan, measures and targets to determine its success. This information will be used to refine

reclamation plans for the Project. Teck will also continue to participate in regional committees and

research organizations and examine new research, guidance documents and frameworks for potential

application to the Project’s reclamation program.



Traditional-use Plant Potential

SOC 69

Fort McKay requests that Teck engages Fort McKay in collecting Traditional Use plant seeds that

Teck plans to collect from the surrounding project area for reclamation purposes. Fort McKay

requests that Teck collects plant seeds, including fungi and lichen in addition to the tree and shrub

seeds Teck already plans to collect.

Teck Response:


SOC 70

Fort McKay requests that Teck provides support to Fort McKay to continue traditional plant

research within the community. This would include: field verification of the traditional use plant

list, including both scientific and traditional names; documentation of all ecosites in which the plant

grows; and, documentation and field verification of preferred ecosites/habitats for harvesting the

plant. This research would include all plants, including fungi and lichen.

Teck Response:


SOC 71


i. commits to engaging Fort McKay following established community protocols to ensure that

appropriate and culturally relevant species are used in revegetation planning for reclamation of

ecosystems that support traditional land uses – details on how this engagement/collaboration

will occur should be outlined in an agreement;



ii. provides a formal plan that describes how it will protect and reclaim traditional plant species in

collaboration with the Fort McKay community and specifically defined traditional use end

land-use targets in the reclamation plan; and,

iii. provides a formal plan that describes how research on traditional-plant species and other

ecosystem elements will be developed and supported and/or synthesized to produce functional

reclaimed landforms and landscapes with equivalent traditional-use capability.

Teck Response:


SOC 72

Fort McKay requests that Teck engages in an active on-site research and trial reclamation program

to develop techniques for:

i. re-establishing native shrub and groundcover species identified as traditional-use plant species

on reclaimed areas, and

ii. the reclamation and conservation of fen and bog land-cover classes that will be eliminated on

the Frontier Project footprint.

Teck Response:


SOC 73

Fort McKay requests that Teck endeavours to reclaim the land so that the reclaimed soils and

landforms are capable of supporting self-sustaining, locally common boreal forests, regardless of

the end land use, and so that the maximum number of pre-disturbance ecosites is present.

Teck Response:




Non-native and invasive species

SOC 74

Fort McKay requests that Teck implements a monitoring and control program for non-native and

invasive species during the project’s construction, operation, reclamation and closure phases to

ensure that these species do not invade disturbed sites and compete with native species.

Teck Response:

Teck is committed to effective environmental management, mitigation and monitoring of non-native and

invasive vegetation species. Following Project approval, a weed management plan will be developed and

implemented to limit weeds across the PDA. Teck will evaluate the plan’s effectiveness and adapt it as

needed on an ongoing basis. For additional discussion, see the response to CEAA Round 5 SIR 146 and

Key Themes – Management, Mitigation and Monitoring (Section 2.2) and Agreement and Regulator

Requests (Section 2.4).

SOC 75

Fort McKay requests that Teck avoids any seed mixes that include non-local and non-native species

for erosion control, to reduce the potential for introducing persistent grass species and to ensure

that the natural recovery of vegetation communities on site is returned to those of pre-disturbance

conditions. Furthermore, BMP 15 in Alberta Environment and Water (2012) indicates that the use

of seed mixes should be avoided to preserve propagule diversity and integrity (Alberta

Environment and Water 2012). If a seed mix is used, Fort McKay requests that the seed mix

contains only native species local to the project area.

Teck Response:




SOC 76

Given the relative lack of opportunity for direct placement of surface soils in the Frontier

reclamation plan, Fort McKay requests that Teck develops and implements a reclamation material

stockpile revegetation specifically designed to re-establish a diversity of native vegetation species

and to develop a propagule (seed, root) bank in these stockpiles. This bank might then aid in

natural regeneration of vegetation upon placement of these materials. Stockpile configuration and

use could be designed to optimize this strategy. Fort McKay requests that the results of this

planning and implementation are reported to Fort McKay.

Teck Response:


SOC 77

Fort McKay requests that excess slash and non-merchantable timber are saved, either in soil

stockpiles, or in separate slash/non-merchantable timber stockpiles and replaced as coarse woody

debris and slash on the reclaimed sites.

Teck Response:


FRONTIER OIL SANDS MINE PROJECT 3 SOC RESPONSES BIODIVERSITY


Biodiversity

Biodiversity

SOC 78

Fort McKay requests that Teck commits to establishing a biodiversity research and monitoring

program to better understand changes in biodiversity on reclaimed sites over time and assesses how

to increase biodiversity on the post-reclamation landscape.

Teck Response:


SOC 79

Fort McKay requests that Teck defines goals for re-establishing biodiversity and appropriate

reclamation techniques such that biodiversity in the post-reclamation landscape is equivalent to the

pre-mining landscape. ‘Equivalent’ should be defined in terms of ecosite types and not equivalent

land capability as measured by forest productivity.

Teck Response:


FRONTIER OIL SANDS MINE PROJECT 3 SOC RESPONSES HUMAN HEALTH


Human Health

Chemical Mixtures and Synergism

SOC 80

Fort McKay requests that Teck presents clear justification for not including potential synergism in

its HHRA and comments on whether potential synergism could occur within the identified CofC

and other chemicals already present in the regional air and water sheds and further explains how

the exclusion of synergism supports conservatism claimed throughout the HHRA approach.

Teck Response:

In assessing the effects of chemical mixtures in the updated human health risk assessment (HHRA), Teck

and its study team referred to Health Canada (2010) and Alberta Health and Wellness (2011) for

guidance. Their approach is consistent with that guidance in that it treated the potential risks of chemicals

with the same general toxicological endpoints (or effects) as additive. At measured and predicted

concentrations of the chemicals of potential concern, synergism is not expected to occur in the regional

air and watersheds.

According to Alberta Health and Wellness (2011), “it is considered cautious to assume that [interactive]

effects may be additive, unless it can be specifically demonstrated that different chemicals have different

mechanisms of action on the same cellular target.” In turn, Health Canada (2010) states, “in most cases,

the risks should be summed for chemicals with similar modes of action and/or the same target organ

tissue. Otherwise, toxicity and risk should be assessed on a chemical-by-chemical basis.”

Available guidance from the United States Environmental Protection Agency (U.S. EPA) on risk

assessment of chemical mixtures indicates that in most cases toxicological information on all the joint

effects from the multiple stressors is unavailable. The U.S. EPA states that toxicological interactions such

as synergism may be of minor consequence at concentrations observed in the environment (Callahan and

Sexton 2007; U.S. EPA 2000). As well, the U.S. EPA (2000) recommends that the assumption of

additivity be made for low exposure levels when no interaction information is available since the

likelihood of significant interaction at these exposure levels is usually considered low.

Synergistic interactions are known to occur in some situations involving high exposure levels. For

example, there is a higher incidence of lung cancer resulting from simultaneous exposure to asbestos and

tobacco smoke (through smoking), than would be expected from simple addition of the effects of asbestos

and tobacco smoke acting independently. However, synergistic effects such as this have been shown to

occur only at much higher exposure levels than those experienced under ambient or natural conditions.



At relevant environmental exposures (i.e., such as those estimated for the study area), interactions

between chemicals have not been shown to occur. Synergistic effects are typically observed only at high

exposure levels that are well above the toxicity threshold for each individual chemical (Feron et al. 1998;

Konemann and Pieters 1996; Yang and Dennison 2007).

At low exposure levels, such as those expected in the study area, chemical interactions (including

antagonism, potentiation and synergy) are either unlikely to occur or toxicologically insignificant.

According to Boobis et al. (2011), low exposure levels are defined as near or below doses that do not

cause statistically significant effects in experimental studies, such as no-observable-adverse-effect-levels

or benchmark dose levels.

Given that researchers have found that toxicological interactions such as synergism are generally of minor

consequence at concentrations observed in the environment, and considering that the HHRA followed

regulatory guidance, Teck and its study team maintain that chemical mixtures were assessed appropriately

in the updated HHRA (see Volume 3, Section 12 of the Project Update).

References

Alberta Health and Wellness. 2011. Guidance on Human Health Risk Assessment for Environmental

Impact Assessment in Alberta. Alberta Health and Wellness, August 2011.

Boobis, A.R., R. Budinsky., S. Collie, K. Crofton, M. Embry, S. Felter, R. Hertzberg, D. Kopp, G.

Mihlan, M. Mumtaz, P. Price, K. Solomon, L. Teuschler, R. Yang and R. Zaleski. 2011. Critical

analysis of literature on low-dose synergy for use in screening chemical mixtures for risk

assessment. Crit. Rev. Toxicol. 41: 369–83.

Callahan, M.A. and K. Sexton. 2007. If cumulative risk assessment is the answer, what is the question?

Environmental Health Perspectives 115(5): 799–806.

Feron, V.J., F.R. Cassee, and J.P. Groeten. 1998. Toxicology of chemical mixtures: international

perspective. Environmental Health Perspectives 106(6): 1281–1289.

Health Canada. 2010. Guidance on Human Health Detailed Quantitative Risk Assessment for Chemicals

(DQRAchem). Federal Contaminated Site Risk Assessment in Canada. ISBN:

978-1-100-17926-1.

Konemann, WH and M.N. Pieters. 1996. Confusion of concepts in mixture toxicology. Food and

Chemical Toxicology 34(11-12): 1025–1031.

U.S. EPA (United States Environmental Protection Agency). 2000. Supplementary Guidance for

Conducting Health Risk Assessment of Chemical Mixtures. EPA/630/R-00/002. U.S. EPA, Risk

Assessment Forum, Office of Research and Development, Washington, DC.

Yang, R.S. and J.E. Dennison. 2007. Initial analyses of the relationship between “Thresholds” of toxicity

for individual chemicals and “Interaction Thresholds” for chemical mixtures. Toxicology and

Applied Pharmacology 223(2): 133–138.



Community Wellness

SOC 81

Fort McKay requests that Teck provides evidence whether or not the HHRA has taken into

consideration community concerns on industrial impacts on health and wellness, e.g., issues related

to drugs, alcohol or cultural integrity.

Teck Response:

Potential health effects associated with the Frontier Project are assessed in the updated human health risk

assessment (HHRA) (see Volume 3, Section 12 of the Project Update). The HHRA follows the Alberta

Health and Wellness Guidance on Human Health Risk Assessment for Environmental Impact Assessment

in Alberta (AHW 2011). In doing so, the HHRA focuses on characterizing health risks associated with

environmental exposures.

Teck is familiar with the more holistic approach described by Fort McKay that considers other health

determinants such as nutrition, access to education, substance abuse, socio-economic status and cultural

integrity. Teck and its study team acknowledge that the HHRA does not address broader issues of

community health and well-being, or community fear associated with perceived environmental

contamination. Some of these issues are considered in other parts of the Project Update, such as the

updated traditional land use assessment (see Volume 3, Section 17) and the updated socio-economic

impact assessment (see Volume 1, Section 16). Teck feels that these issues are most effectively addressed

on a regional basis through a collaborative process between industry, government and communities like

Fort McKay.

References

AHW (Alberta Health and Wellness). 2011. Guidance on Human Health Risk Assessment for

Environmental Impact Assessment in Alberta. Alberta Health and Wellness, Government of

Alberta. August 2011.



SOC 82

Fort McKay requests that Teck undertakes a risk assessment on the likely health impacts on all

determinants of health from the Project Update. Fort McKay also requests that Teck considers the

value of a more holistic approach to human health risk assessment using an established Health

Impact Assessment approach and adopts results of a HIA in evaluating the human health impacts

of the proposed Frontier Mine Project.

Teck Response:


SOC 83

Fort McKay requests that Teck constructively discusses with Fort McKay strategies to effectively

communicate health risks associated with the proposed Frontier Mine Project to mitigate health

concerns and fear within the Community of Fort McKay.

Teck Response:




Health Programs

SOC 84

Fort McKay requests that Teck constructively discusses with Fort McKay ways to explore what

programs could be supported or devised to promote health so as to offset potential negative health

impacts of the proposed project resulting from a more comprehensive HIA.

Teck Response:




Regional Multi-stakeholder Groups

SOC 85

Fort McKay requests that Teck constructively participates in and supports existing and future

environmental and health management and monitoring programs within the region including

WBEA and CEMA.

Teck Response:




Cancer

SOC 86

Fort McKay requests that Teck provides further details on the Alberta Cancer Board’s assessment

of rare cancers in the community of Fort Chipewyan, in particular, providing an numerical

estimate of the observed versus expected rates of cholangiocarcinoma.

Teck Response:

A detailed account of the Alberta Cancer Board (ACB 2009) and Alberta Health Services (AHS 2014)

assessments of cancer in Fort Chipewyan is provided in Volume 3, Section 12.6.3 of the Project Update.

For ease of reference, parts of this discussion are excerpted below, and presented with the ACB’s and

AHS’s estimates of observed versus expected rates of cholangiocarcinoma.

In response to concerns raised regarding certain types of cancer in Fort Chipewyan, the

Government of Alberta conducted an investigation to determine if there is an elevated

rate of cholangiocarcinoma (a rare form of bile duct cancer) and whether there is an

elevated rate of cancers overall in the community [Fort Chipewyan] (ACB 2009).

[According to the ACB and external peer reviewers of the study,] the investigation

followed generally accepted guidelines on cluster investigations from the Center for

Disease Control and Prevention in the United States.

In the Alberta Cancer Board (ACB 2009) study, the number of observed cases in Fort

Chipewyan was compared to the number of expected cases over a 12-year period (1995

to 2006). Cancer rates at communities in similar geographic locations were calculated

for comparison as well.

According to the ACB (2009, p. 24), “in total, two cases of cholangiocarcinoma were found in Fort

Chipewyan compared to 0.4 expected.” ACB (2009) concluded that “these numbers were within the

expected range” for Fort Chipewyan.

The overall findings of the ACB (2009) study are described as:

• overall cancer incidence rate was higher in Fort Chipewyan than expected

• observed number of cancers of the blood and lymphatic system, biliary tract [cancers

as a group], and soft tissue [cancers] were higher than expected for the population

• observed number of colon and lung cancer rates were within expected ranges

The ACB indicated that the increased rates were based on a small number of cases and

could be due to chance, increased detection, or increased risk in the community.



The ACB indicated that further investigation would be required to determine whether the

difference between the observed and expected cancer rates was due to chance or if there

was an actual increased risk associated with living in Fort Chipewyan. The study was not

designed to determine the cause of any of the cancers experienced in Fort Chipewyan.

Further analysis was recommended by the ACB to determine whether risk factors such as

family history, lifestyle, occupational exposures and/or environmental exposures are

contributing to the observed cancer incidence.

A follow-up report by Alberta Health Services (AHS) (2014) found that the total number

of cancers and most types of cancers in the Fort Chipewyan area from 1992 to 2011 were

the same as rates in the rest of Alberta. The AHS study found that no childhood cancer

cases were diagnosed in Fort Chipewyan during that same time period. The 20-year

study period was subdivided into four five-year periods: 1992 to 1996; 1997 to 2001;

2002 to 2006; and 2007 to 2011. The findings of the study are summarized below:

• Biliary tract cancer incidence [which includes cholangiocarcinoma] was higher than

expected from 2002 to 2006, which caused the overall biliary tract cancer incidence

to be elevated for the 20-year study period. Three cases were reported while none

would be expected. Alberta Health Services described some of the risk factors for bile

duct cancer, including family history, bile duct stones, cysts and abnormalities, liver

cirrhosis, diabetes, aging and viral hepatitis.

• [When considering both sexes, between the years of 1992 and 2011 there were three

observed cases of biliary tract (including “other and unspecified”) compared to zero

expected cases (AHS 2014, page 6)].

• The number of cervical cancer cases was higher than expected in the 2007 to 2011

time period and the entire 20-year study period (1992 to 2011). Four cases of

cervical cancer were reported while one case would be expected. According to

Alberta Health Services, cervical cancer is most commonly associated with the

human papilloma virus.

• The number of bronchus/lung cancer cases for men and women combined was no

different than expected based on provincial rates for any of the time periods

examined. For women, a total of eight cases of lung cancer were reported between

1992 and 2011, while four cases would be expected for the same time period. Lung

cancer is most commonly associated with smoking.

• There were more cases of non-Hodgkin lymphoma than expected between 1992 and

1996. Since then, none of the time periods have shown a difference between the

expected and observed number of cases of non-Hodgkin lymphoma.

• The findings for the other types of cancer were unremarkable, in that the rates for

these cancers were no different than expected based on the provincial rates for any of

the examined time periods.



Alberta Health Services (2014) states that, due to the small population in Fort

Chipewyan, a small number of cancer cases can make a significant statistical difference

in the cancer incidence rates. Alberta Health Services further stated that it will continue

to monitor the Fort Chipewyan area every three years to determine if a trend develops

over time (AHS 2014).

Teck acknowledges that despite government responses to the cholangiocarcinoma incidence rate in Fort

Chipewyan, communities remain concerned about the potential linkage between environmental factors

and direct health effects.

References

ACB (Alberta Cancer Board). 2009. Cancer Incidence in Fort Chipewyan, Alberta 1995-2006. Alberta

Cancer Board, Division of Population Health and Information Surveillance.

AHS (Alberta Health Services). 2014. Cancer Incidence in Fort Chipewyan Follow Up Report. March 24,

2014. Available at: http://www.albertahealthservices.ca/assets/healthinfo/poph/hi-poph-surv-

cancer-overview-fort-chip-2014-03-24.pdf. Accessed February 2016.

SOC 87

Fort McKay requests that Teck provides a rationale to explain the excess cholangiocarcinoma in

the region, and in particular if environmental causes are to be dismissed, provides an acceptable

rationale and an acceptable alternative hypothesis.

Teck Response:

This SOC requests that Teck provide an explanation of the “excess cholangiocarcinoma in the region”.

According to Alberta Health Services (AHS 2014), the reason that the number of reported cases exceeded

the statistical number of expected cases may be because of the small population of Fort Chipewyan.

The initial Alberta Cancer Board (ACB 2009) investigation and AHS (2014) follow-up report list cancers

that have occurred in the Fort Chipewyan region by type (including biliary tract cancer, or

chlolangiocarcinoma) and identify their various risk factors. Neither study was designed to determine the

cause of the cancers. According to AHS (2014), the known risk factors for biliary tract cancer are

complicated but may include “family history, bile duct stones, cysts and abnormalities, liver cirrhosis,

inflammatory bowel disease, aging, obesity, alcohol, diabetes and viral hepatitis.” Other risk factors for

biliary tract cancer include “smoking, pancreatitis, infection with HIV, and exposure to asbestos, radon,

dioxin, nitrosamines or some polychlorinated biphenyls” (AHS 2014). None of these contaminants are



associated with the Project and therefore, were not identified as chemicals of potential concern in the

updated HHRA.

References

ACB (Alberta Cancer Board). 2009. Cancer Incidence in Fort Chipewyan, Alberta 1995–2006. Alberta

Cancer Board, Division of Population Health and Information Surveillance.

AHS (Alberta Health Services). 2014. Cancer Incidence in Fort Chipewyan Follow Up Report. March 24,

2014. Available at: http://www.albertahealthservices.ca/assets/healthinfo/poph/hi-poph-surv-

cancer-overview-fort-chip-2014-03-24.pdf. Accessed February 2016. SOC 88

Fort McKay requests that Teck provides support to investigate further the potential causes of

cholangiocarcinoma in the region, with a specific focus on risks to the Community of Fort McKay.

Teck Response:

Teck acknowledges that despite government responses to the cholangiocarcinoma incidence rate in Fort

Chipewyan, communities remain concerned about the potential linkage between environmental factors

and direct health effects. If a collaborative regional forum is created to address direct or indirect health

concerns, Teck is open to discussing how support could be provided to the community of Fort McKay.



Regional Multi-stakeholder for Human Health

SOC 89

Fort McKay requests that Teck constructively supports initiation or progression of a regional

multi-stakeholder initiative to explore recognizing and managing indirect health impacts of

industrial development on human health.

Teck Response:


FRONTIER OIL SANDS MINE PROJECT 3 SOC RESPONSES TAILINGS MANAGEMENT


Tailings Management

Fines Treatment

SOC 90

Fort McKay requests that Teck attends a technical meeting to discuss the revised tailings

management program.

Teck Response:

Teck and Fort McKay met on November 3, 2015, to discuss the Project’s proposed tailings management

plan. Teck is willing to continue to meet with Fort McKay to discuss Teck’s approach to tailings

management.



Tailings Management Program

SOC 91

Fort McKay requests that Teck attends a technical meeting to explain the revised tailings

management program and why Teck considers it an improvement.

Teck Response:




Cyclones

SOC 92

Fort McKay requests that Teck attends a technical meeting to explain how successful using

cyclones has been during all seasons.

Teck Response:




Water Use

SOC 93

Fort McKay requests that Teck provides evidence that water withdrawal requirements are similar

to the 2011 Integrated Application plan.

Teck Response:

The Project Update identifies how the Project’s river water requirements are similar to or less than those

defined in the Integrated Application (see Volume 1, Section 7.11 of the Project Update). This conclusion

is based on three measures: water usage, water use intensity and the Project’s water license request.

WATER USAGE

The updated Project requires less river water than is described in the Integrated Application because of

(i) an improved understanding of the area hydrogeology and (ii) a change in tailings technology.

An updated interpretation of the distribution of the basal water sands and a refined three-dimensional

geologic block model of the Quaternary sequence was developed for the Project Update. Additionally,

slug test data for the Quaternary facies were re-analyzed, which resulted in higher values of hydraulic

conductivity being assigned to the permeable Quaternary materials. As a result, the groundwater

component increased from the Integrated Application, resulting in a corresponding decrease in river water

requirements.

In the Integrated Application, fines were purposely stripped by thickening and stored as thickened tailings

in dedicated disposal areas. This left empty space (voids) between sand grains in the coarse tailings

beaches, and these spaces were filled with water. The updated Project uses centrifuges instead of

thickening technology, so approximately 300 million more tonnes of fines are able to be stored in these

voids, substantially reducing the amount of residual water permanently stored on site.

Estimates of water usage on site are provided in Volume 1, Section 7.11.2.1 of the Project Update. Based

on data presented in Section 7.11.2.1 for average operating and hydrogeologic conditions, the total

Athabasca River water withdrawal has been reduced from 1,127 Mm³ in the Integrated Application to

895 Mm³ in the Project Update.



WATER USE INTENSITY

Another measure of water use is the amount required per barrel of bitumen produced. The updated Project

will recover 200 million more barrels of bitumen than the Integrated Application. The recovery increase

combined with the lower overall water requirement described above has the effect of reducing unit water

requirements (i.e., water use intensity) from 2.5 barrels of river water per barrel of bitumen in the

Integrated Application to 1.9 barrels of river water per barrel of bitumen in the Project Update. As noted

in Volume 1, Section 7.11.2.1 of the Project Update, this is less than the oil sands industry-average water

use intensity of 2.3.

WATER LICENSE REQUEST

The river water license defines the maximum river water withdrawal allowed per year, which is set by the

Alberta Energy Regulator. Teck determined its license request based on the results of life-of-mine site-

wide water balance modelling that takes into account all anticipated water flows in the PDA. These

include, but are not limited to, water required for extraction processing, minimum water depths for

pumping and barges, potable water, precipitation, evaporation, and groundwater seepage reporting to the

recycle water system. Teck then factored in conservative climatological information and used

probabilistic modelling to estimate ranges of water availability. These two parts of the equation – water

requirements and water availability – were used to determine the maximum amount of water expected to

be required for withdrawal in any given year.

For the Integrated Application, Teck based its water license request on the maximum annual water

requirement over the mine’s operating life (71.5 Mm³). In the Project Update, the license request was

modified to reflect a two-phase approach. The updated request consisted of an initial requirement

(98 Mm³ per year for the first eight years) and a subsequent decrease (to 60 Mm³ per year thereafter). The

higher peak rate was due to the faster production ramp-up outlined in the Project Update (i.e., two

production trains in the first two years versus three-year intervals in the Integrated Application). The

faster ramp-up requires additional water storage sooner in the mine life. However, comparing the areas

under the licence curves (see Figure 93-1) reveals that if the maximum allowable water license amount is

actually withdrawn each year over the life of the mine, the Project Update would use less water than the

Integrated Application. Based on this measure, the Project Update would use less water than the

Integrated Application.

SUMMARY

Based on these three measures, Teck is confident that river water requirements defined in the Project

Update are similar to, or less than, the Integrated Application. Teck will continue to identify opportunities

to further reduce water use during future stages of engineering.



Figure 93-1 Annual River Water Requirements



Rehandling Tailings

SOC 94

Fort McKay requests that Teck attends a technical meeting to explain how it plans to avoid

rehandling tailings from the ET Areas to the centrifuge.

Teck Response:




Thin Lift Drying Area

SOC 95

Fort McKay requests that Teck clarifies its statement in relation to the possibility that there will be

similar challenges with centrifuge discharge material.

Teck Response:

Teck considers the operational complexity of centrifuge operations to be substantially less than that of

thin lift drying, as summarized below.

By their nature, thin lift drying operations are spread over a large area, much larger than that required for

an equivalent deep-deposit centrifuge operation. The network of piping systems required to deliver fluid

fine tailings for thin lift drying operations is widespread and must be moved and expanded continuously

as tailings pour points are opened, closed, and advanced throughout the field. Berms that provide the base

for the piping systems require large volumes of mine waste and must also continually be expanded and

raised as the field rises. These berms serve to contain the tailings, which are soft and potentially

liquefiable. Finally, the thin lift drying operation is prone to more variable feed conditions, with a greater

chance to produce off-spec treated tailings that do not perform as planned.

By contrast, centrifuge operations are less complex and will be confined to a smaller area. Centrifuging is

a mechanical process that can be manipulated, making it is less prone to variable feed conditions. Also,

the centrifuge plant is in a fixed location and delivers product to a single load-out point, which is

inherently simpler. Shovel and truck operations haul the product to its final disposal area, which is

simpler and more flexible than the constant movement of pipelines required in thin lift drying. The in-pit

disposal area is also naturally segmented with ‘ribs’ for the trucks to drive on, making it easier to move

immediately to a different location should conditions warrant. See the response to AER Round 5 SIR 36

for a discussion of how the updated tailings management plan aligns with the policy intent of the Tailings

Management Framework for Mineable Athabasca Oil Sands (GOA 2015).

References

GOA (Government of Alberta). 2015. Tailings Management Framework for Mineable Athabasca Oil

Sands (TMF). Lower Athabasca Region, March 2015.



ETA Surface Reclamation

SOC 96

Fort McKay requests that Teck attends a technical meeting to explain the overall reclamation pace.

Teck Response:




In-pit CFT Placement

SOC 97

Fort McKay requests that Teck attends a technical meeting to explain how the revised plan could

accomplish reducing or eliminating external tailings facilities.

Teck Response:


FRONTIER OIL SANDS MINE PROJECT 3 SOC RESPONSES CONSERVATION AND RECLAMATION PLAN


Conservation and Reclamation Plan

Reclamation Schedule Pace

SOC 98


i. examines its mining and reclamation plans to identify all opportunities for progressive

(accelerated) reclamation and direct soil placement; and

ii. consults with Fort McKay regarding any potential shifts in surface disturbances within the

project footprint from the planned locations and that the appropriate regulatory bodies request

assessment of direct and cumulative effects due to shifts in the planned locations and associated

disturbances.

Teck Response:

i. The Project’s closure, conservation and reclamation plan (see Volume 1, Section 13 of the Project

Update) will be examined and updated annually over the life of the mine. One of the primary

objectives of these routine reviews will be to identify opportunities for increasing the rate of

progressive reclamation and direct soil placement. Teck will discuss with Fort McKay opportunities

for accelerated progressive reclamation and direct soil placement for the Project. The most

appropriate venue for such discussions will be Reclamation Working Group meetings (see Volume 1,

Section 13.9 of the Project Update).

ii. Teck understands that any shift in surface disturbance beyond the approved PDA will be subject to

amendment of relevant approvals for the Frontier Project. This is not necessarily the case for shifts in

surface disturbance within the PDA. In spite of this, Teck will summarize proposed shifts in surface

disturbances and provide this information to Fort McKay at Reclamation Working Group meetings.

However, it is neither practical nor appropriate for Teck to consult with Fort McKay regarding any

potential shifts in surface disturbances within the PDA.



Adaptive Management Framework

SOC 99

Fort McKay requests that Teck participates in regional and local initiatives to develop key

performance indicators to define and improve the adaptive management framework for the

evaluation of regional reclamation success and pace in the Athabasca oil sands.

Teck Response:


SOC 100

Fort McKay requests that an adaptive management framework for progressive reclamation and

closure plan integration for oil sands mines is developed on a priority basis.

Teck Response:


SOC 101

Fort McKay requests the opportunity to participate in development of an adaptive management

framework as part of a regional initiative and that Teck is a leader in initiating this process with

other mine operators in the region.

Teck Response:




Equivalent Land Capability

SOC 102

Fort McKay requests that Teck expressly considers its Cultural Keystone Species and their habitat

during reclamation planning and develop a more detailed reclamation plan in collaboration with

Fort McKay that will include explicit planning and methods that focus on reclamation for

traditional land uses, including targeting traditional plant species and wildlife habitat.

Teck Response:


SOC 103

Fort McKay requests that Teck supports Fort McKay in funding research focusing on the

development of criteria and indicators for determining reclamation certification and success for

traditional land use objectives. Very little research is available on this topic, and Teck is in a unique

position to partner with and support Fort McKay in moving forward this research for the region.

Teck Response:




Closure Landform Design

SOC 104

Fort McKay requests that Teck provides a detailed explanation of how the current landscape

design plan will shift if restoration of peat-forming wetlands becomes possible.

Teck Response:

Although peatlands are not specifically included in the closure, conservation and reclamation (CC&R)

plan for the Project, Teck anticipates that marshes and swamps will start to accumulate peat and move

towards peatlands as salinity decreases. Adaptive management is a key aspect of environmental

management for the Frontier Project and demonstrates that Teck is committed to change and adapt as the

Project evolves over time. This approach provides a mechanism for Teck to learn from experience and

modify management and mitigation plans for the Project to evolve in step with changing circumstances,

local and regional monitoring results, and advances in science. For additional discussion,

see Key Theme – Management, Mitigation and Monitoring (Section 2.2).

Teck recognizes that peatlands are an important traditional use area for Aboriginal communities. Teck

will seek to include peatlands in the CC&R plan should research results (e.g., the Nikanotee Fen

initiative; COSIA 2015) and recommendations confirm that restoration of peat-forming wetlands is

feasible and appropriate. Specifically, if research identifies restoration techniques that are feasible and

appropriate, Teck would likely initiate peatland reclamation activities in some of the areas that are

currently targeted for wetlands in the CC&R plan. As reclamation progresses, additional areas for

peatland reclamation may be identified. Because Teck will follow progressive reclamation, improvements

in peatland reclamation and techniques can be incorporated into the mine reclamation plan that is

expected as a condition of approval and will be updated throughout the life of the Project.

Teck will continue to work with potentially affected Aboriginal communities through the co-creation of

Reclamation Working Group(s); seek input on the Project’s reclamation plan, measures and targets to

determine its success; and facilitate participation in monitoring activities. As well, Teck will continue to

participate in regional committees and research organizations and will examine new research, guidance

documents and frameworks for potential application to the Project’s reclamation program.

References

COSIA (Canada’s Oil Sands Innovation Alliance). 2015. Nikanotee Fen, Evaluating the success of fen

creation. Available at: http://www.cosia.ca/initiatives/land/nikanotee-fen. Accessed February

2016.



Mine Reclamation Materials Balance

SOC 105

Fort McKay requests that Teck clarifies why it is reducing the amount of salvaged and stockpiled

reclamation material and whether this corresponds to an increase in the volume of direct-placed

(i.e., non-stored) reclamation material.

Teck Response:

The reduction in salvage and stockpiling is due to an increase in the amount of direct placement of

reclamation materials, as well as the update to the PDA resulting from the Teck–Shell asset exchange, the

revised mine plan, and a change in the area of water in the closure landscape.

SOC 106


i. reduces the time gap between disturbance and reclamation;

ii. makes every effort to maximize direct placement of soils during reclamation; and

iii. ensures that Fort McKay plays a meaningful role in closure and reclamation planning so as to

minimize the cumulative disturbance and loss of access in its Traditional Territory caused by

Frontier mining operations.

Teck Response:




Reclamation Monitoring, Certification and Security

SOC 107

Fort McKay requests involvement in the reclamation monitoring program throughout all phases of

continued development at the Frontier Project site. Specifically, Fort McKay requests that Teck

commits to:

i. developing a reclamation monitoring program that incorporates traditional knowledge to

identify and evaluate indicators representing key elements of traditional uses and cultural

practices; and

ii. developing an indigenous research monitoring program to evaluate the re-establishment of land

capability to support traditional land uses, and to assist the community in building capacity

(e.g., training, providing contracts, communication of results).

Teck Response:




Reclaimed Lands Certification

SOC 108

Fort McKay requests that Teck supports Fort McKay’s participation in reclamation certification

application reviews and site inspections, and obtains Fort McKay’s consent to any reclamation

certification within its Traditional Territory.

Teck Response:


SOC 109

Fort McKay requests that reclamation certification is not granted until such time as it can be

conclusively demonstrated that ecosystem recovery is on a trajectory acceptable to Fort McKay,

Teck and the regulators.

Teck Response:


FRONTIER OIL SANDS MINE PROJECT 3 SOC RESPONSES CULTURAL IMPACT ASSESSMENT


Cultural Impact Assessment

Cultural Impact Assessment

SOC 110

Fort McKay requests support from Teck for a community-led Cultural Impact Assessment.

Teck Response:




Economics and Workforce

SOC 111

Fort McKay requests that Teck works with Fort McKay to establish specific fiscal targets for

business opportunities and Community-specific processes to enhance workforce and training.

Teck Response:




Community-Specific Socio-economic Information

SOC 112

Fort McKay requests that Teck consults with Fort McKay on socio-economic issues, identifying key

information gaps, supporting a community-led collection of socio-economic information, as needed,

and jointly developing with Fort McKay appropriate socio-economic mitigation measures and

strategies.

Teck Response:




Fly in/Fly out

SOC 113

Fort McKay requests that Teck considers the Community of Fort McKay when developing its flight

patterns to avoid community overflight where feasible.

Teck Response:




Traffic Volumes and Road Maintenance

SOC 114

Fort McKay requests that Teck affirms its commitment to consult with Fort McKay regarding

traffic safety issues and concerns and the timing and specifics of Highway 63 maintenance and

upgrading.

Teck Response:




On-site Lodge

SOC 115

Fort McKay requests that Teck continues to consult with Fort McKay on social, cultural and

traditional land use issues related to the presence of worker camps.

Teck Response:




Population Change and Infrastructure Effects

SOC 116

Fort McKay requests that Teck works with Fort McKay to understand the specific community-

level stressors regarding infrastructure and services and to develop, with Fort McKay, appropriate

social investments and initiatives to mitigate these impacts.

Teck Response:




Community Sustainability

SOC 117

Fort McKay requests that Teck works with Fort McKay on developing mitigation measures and

initiatives that focus on Community sustainability including social, health and cultural aspects of

Community sustainability. A Cultural Impact Assessment is a key study needed to understand

project impacts and cumulative development on social resiliency and culture and to develop

appropriate mitigation to offset impacts (see Request [110]).

Teck Response:


FRONTIER OIL SANDS MINE PROJECT 4 CLOSING


4 Closing

Fort McKay input into Teck’s submissions for the Project has enabled Teck to better

understand Fort McKay concerns and perspectives regarding development of the Project

and industrial development in the Athabasca Oil Sands Region. Fort McKay technical

reviews, traditional use studies, community-led cultural impact assessments and

consultation efforts with Teck have positively contributed to Project planning and the

environmental impact assessment, including development of mitigation measures.

Teck is committed to continuing to work through concerns with Fort McKay to achieve a

full resolution. Teck looks forward to continuing to work with Fort McKay as the Project

continues to move through the regulatory review process and future stages of project

planning.

reference: fort mckay technical review of teck frontier

Documents