After reviewing this…

ERO number

019-4807

Comment ID

59325

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Individual

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Comment

After reviewing this proposal, I thought it would be in the best interest of ensuring the safety of the Caribou and the habitat in question by examining the precedent set by similar projects while looking at measures taken to restore and replenish habitats after the impact of such projects.

Canadian Environmental Assessments provide us with this 2015 report taken from the Whabouchi Mining Project Environmental Assessment.

In particular, this statement taken from "8.4.5 Potential Cumulative Effects on Species at Risk" of the same report should be taken into consideration with regard to any strategies looking to have a positive effect upon the Caribou habitats of the proposed Kirkland Lake Gold Ltd project:

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According to the recovery strategy for the woodland caribou (Boreal population), many of the threats to this species and its habitat are related and may interact, in which case they can have cumulative effects that may look less significant when threats are examined individually.

Additionally, cumulative effects related more specifically to the size and distribution of local caribou populations may have a lag effect, which can take years to manifest. Environment Canada is therefore of the view that it is important to remain vigilant and to look at the effects as a whole over a vast area. ***

This would certainly imply that although the proposed projects are considerably small in the overall space they will impact (between 0.18 square km and 0.33 square km of Caribou habitat as per your proposal, with 0.18 square km being the total area you've selected as optimal), that these effects stretch far beyond the projected space they occupy and in turn are affected in complex ways that could grow over time if neglected.

Also, drawing on experience from our similarly concerned neighbours to the south, I cite this paragraph taken from a project to monitor and restore habitats affected by mining operations of The Crown Jewel Mine Okanogan County in Washington in the United States by the Okanogan Highlands Alliance.

The paragraph states:

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Shortly after mining operations began in 2008, water quality monitoring data began to show problems at the Buckhorn Mine. The issues began when the mine used contaminated development rock to construct the mine facilities, instead of putting it on liners as required. Early on, the treatment facility was inadequate and discharges from the underground mine, the mine surface, and from the treatment facility began degrading the water. Water quality violations have been almost continuous since then.
***

This preceding paragraph was quoted from:
https://okanoganhighlands.org/mine-monitoring/water-quality/

As we can learn much from these assessments and observations from both the Impact Assessment Agency Of Canada (https://www.canada.ca/en/impact-assessment-agency.html) and the Environmental Protection Agency of the United States (https://www.epa.gov), managing these projects and ensuring their mandate to protect the environment in which they are being operated requires oversight through every step of the project, from proposal to planning to design to engineering, construction and operation. All while being responsible to the habitat, the environment and future generations.

At every step, there has to be a group responsible to ensure that all these measures are being considered and followed including the environmental sciences and engineering relevant. In the event of any problems, that the priority is given to the environment and the effort to protect the habitat occupied by the project until a solution is arrived at by the evaluation of experts and the Ministry Of The Environment.

Thank you for taking the time to read this comment and consider the points illustrated here, and many thanks to those who produced the accompanying reports and made the information available so that we may learn from the efforts of others.

Thank you for being environmentally responsible to present this proposal in a manner that opts for productive public input.