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Tailings
Disposal
1. Where
will the tailings be placed and how big an area will be covered by these
tailings?
2. What will be the chemical composition of the water that is stored
with the tailings in the impoundment?
3. Will the tailings generate acidic water?
4. How will acid generation be prevented?
5. We have heard that pyrite causes acid formation and that it is possible
to prevent acid generation by segregating the pyrite from other tailings.
Is this NDM’s plan? How will acid generation from the pyritic
tailings be prevented both during and after operation?
6. Are there other metals present in the deposit that are not economic
to recover, or that are present only in trace amounts, that are discarded
along with the tailings? What risk do these pose to the environment?
7. Will the water that flows through the tailings impoundment be allowed
to drain into surface waters during mine operation?
8. Will the water that flows through the tailings impoundment be allowed
to drain into surface waters after mine closure?
9. Will the water that flows through the tailings impoundment be allowed
to drain into groundwater aquifers?
10. How will flow to groundwater be prevented? Will a liner be used?
11. What would such a liner be made of, and what it the life expectancy
of the liner?
12. Are such liners susceptible to failure through physical and chemical
degradation?
13. Are such liners able to withstand catastrophic events such as strong
earthquakes?
14. Of what material is the tailings dam constructed?
15. Is the dam impermeable, and if so, how is it made this way?
16. We have heard that all dams leak to some degree. What engineering
controls are used to prevent these leaks or collect leakage?
17. How are the processing chemicals cleaned or rinsed from the tailings
before they are placed in the impoundment, or are the chemicals used
in processing disposed of along with the tailings? How is contamination
from these chemicals prevented?
18. Is it possible to cement the tailings? Would that be an effective
method of preventing water flow through the tailings pile?
19. Is it possible to place the tailings back in the pit after the orebody
is mined out?
20. How will the tailings be prevented from blowing away?
21. We understand that tailings are often vegetated in order to stabilize
the pile and prevent wind erosion and dispersal. The Pebble area is
a harsh climate with strong winds. Can suitable vegetation be established
in such a climactic environment?
22. Will the tailings be capped after processing is complete? What will
be used?
23. What will the tailings impoundment look like after reclamation.
24. What exactly is a Mixing Zone? Will Northern Dynasty use a Mixing
Zone?
25. Why was the south tributary of the Koktuli River chosen for tailings
disposal?
26. We understand that one method of preventing acid generation and
controlling dust is to keep the tailings under water. Given the size
of the “tailings lake” that would be created, how will NDM
protect the tailings dam from damage due to ice movement during severe
windstorms that occur regularly in this area?
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Mine
Water
27. We
know that water draining through a mine pit, processing facilities,
and the general mine environment can become contaminated with explosive
residue, fuels, lubricants, and that it can be acidic, and bear toxic
levels of metals. Can you provide a complete list of potential contaminant
sources? Please provide it.
28. What will be the chemical composition of water draining from the
mine environment after the operation closes?
29. How will contamination emanating from the mine environment be prevented
from polluting surface and groundwater both during and after operation?
30. What will become of the pit after mining is complete? We have heard
that pits can be turned into lakes. Will NDM turn the Pebble Pit into
a lake?
31. Will the pit walls generate acidic water?
32. What contaminants will be present in the pit lake water?
33. If the pit lake water is contaminated or acidic, how will this water
be prevented from entering the downstream environment?
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Human
Health
A. Drinking water quality
34. What potential sources of pollution have the possibility of affecting
the quality of drinking water sources?
35. How high is the risk that drinking water sources could be contaminated
by the Pebble operation.
36. What is the relative toxicity of potential contamination sources?
37. What chemicals are used in the mineral processing, and at other
mine functions?
38. What chemicals could escape from the environment in the case of
improper operation, inadequate safeguard measures, or in the case of
an unforeseen natural disaster?
39. Have you documented all sources of drinking water in downstream
environment?
40. Will these sources be monitored throughout the life of the mine
and beyond?
41. What will NDM do to ensure that drinking water quality is not changed?
42. What will NDM do to assure every potentially affected human consumer
of water that his or her source will remain unchanged in perpetuity?
43. What will NDM do if its operation, despite the best of intention
and engineering excellence, contaminates water during mine operation
and through closure?
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B. Subsistence food quality
44. What are the potential sources of contamination to subsistence food
resources as a result of the Pebble operation?
45. How high is the risk that these resources could be contaminated
by the Pebble operation?
46. What is the relative toxicity of potential contamination sources?
47. What will NDM do to ensure that subsistence foods that local residents
consume do not become contaminated?
48. During the life of the operation and beyond, what will NDM do to
assure subsistence resource consumers that their resources have not
been contaminated?
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C. Air quality
49. What are the potential sources of contamination to air as a result
operations at Pebble?
50. How will power be generated?
51. Of the various alternatives for power that are being considered,
which is projected to have the lowest air quality impact?
52. How will dust be controlled in the mine environment?
53. How will dust be controlled along the transportation corridor?
54. What alternatives for transportation provide the lowest air quality
impact?
55. We are aware that Red Dog Mine had a problem with lead and zinc
concentrate dust being released along the road to the port, and that
this dust contaminated vegetation and soil, thereby affecting berries
as a subsistence resource. How will similar contamination be avoided
at the Pebble operation?
56. If subsistence resources are somehow accidentally contaminated through
some unforeseen circumstance, will we be compensated for the loss of
those subsistence resources?
57. If so, how do you propose to put a price tag not only on the loss
of the resource, but the loss of a lifestyle?
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Environmental
Health
A. Water quality
58. What Pebble project potential sources of pollution have the possibility
of affecting the quality of water?
59. How high is the risk that water could be contaminated by the Pebble
operation.
60. How high is the risk that water quality could be slowly degraded
over time through minor leaks and releases?
61. What is the relative toxicity of potential contamination sources?
62. What is the chemical composition of water that is impounded in the
tailings pile during operation?
63. What will be the chemical composition of water draining from the
mine environment after the operation closes?
64. What is the acid generating capability of the tailings, the pit
walls, and the waste rock piles?
65. What chemicals could escape from the environment in the case of
improper operation, inadequate safeguard measures, or in the case of
an unforeseen natural disaster?
66. What will NDM do to ensure that water quality is not changed in
the downstream environment?
67. What will NDM do to assure all stakeholders that water quality will
remain unchanged in perpetuity?
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B. Water flow
68. How much water will the Pebble operation consume?
69. How much will this consumption affect the level of water in the
downstream environment?
70. How much will this affect water temperatures in the downstream environment?
71. How will NDM ensure that fish passage, fish habitat, fish spawning
and fish rearing are not impacted by reduced water flow?
72. Will effluent be allowed to pass from the tailings pile or from
the mine into the groundwater table, or will there be linings that prevent
effluent movement?
73. We have heard that very small changes in water chemistry can be
detrimental to salmon reproduction and juveniles. How will Northern
Dynasty prevent these small changes?
74. We have heard that a small amount of copper is particularly harmful
to fish eggs and fry. Is this true? We understand that the goal is to
recover the copper, but some will escape to tailings. How will you prevent
harm to eggs and juvenile fish from copper contamination?
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C. Plants
75. What are the potential sources of contamination that could affect
the health of plants in the mine area and along the transportation corridor?
76. How will this contamination be avoided?
77. We are aware that Red Dog Mine had a problem with lead and zinc
concentrate dust being released along the road to the port, and that
this dust contaminated vegetation. How will similar contamination be
avoided?
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D. Soil
78. What are the potential sources of contamination that could affect
the health of plants in the mine area and along the transportation corridor?
79. How will this contamination be avoided?
80. We are aware that Red Dog Mine had a problem with lead and zinc
concentrate dust being released along the road to the port, and that
this dust contaminated soil. How will similar contamination be avoided?
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E. Air
81. What are the potential sources of contamination that could affect
air quality in the mine area, along the transportation corridor, at
the power generation facility, or at any other mine-related infrastructure?
82. Is dust a significant environmental concern? If so, how will dust
be controlled during construction and operation?
83. How is air quality factored into alternative analysis of power generation,
transportation, and mine equipment? How much weight is air quality impact
given in these analyses?
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F. Fish, habitat and spawning/rearing areas
84. We understand that the current preferred alternative is to sacrifice
Frying Pan Lake and part of the south tributary Koktuli River drainage
for tailings disposal. We understand that this site was chosen, in part,
because the waters have lower levels of resident fish and fish spawning
and rearing habitat. Nevertheless, these waters do provide habitat for
some fish, and that the waters to be sacrificed do contain resident
fish, fish rearing habitat in the form of beaver ponds, and spawning
areas. We further understand that when such sacrifices are made, it
is typical that compensation or mitigation of some sort is made. What
is the form of this compensation? What specifically is being proposed?
85. We understand that all the anadromous rivers of the Bristol Bay
region are precluded from mining through Mineral Closing Orders (MCO).
The Koktuli River is a catalogued anadromous river, but we are unsure
of the MCO boundaries. The closures were put in place to preserve the
salmon spawning and rearing areas specifically from mining activity.
We are wondering whether or not the tailings disposal area overlaps
with the Mineral Closing Order area that is on the Koktuli River. Please
provide maps or drawings that clearly show the closed areas in relation
to the tailings disposal area and other mine infrastructure. Does NDM
plan to disturb, in any way, lands or waters that are overlain by the
Koktuli River MCO?
86. We understand that the National Marine Fisheries Service has special
rules of Essential Fish Habitat (EFH). Congress defined EFH as "those
waters and substrate necessary to fish for spawning, breeding, feeding,
or growth to maturity" (16 U.S.C. 1802(10)). It would appear that
the Koktuli River would meet this definition. Does NDM consider any
portion of the Koktuli River to be EFH? Does NMFS consider any portion
of the Koktuli River to be EFH? What are the implications for development
if indeed the areas of the upper part of the Koktuli south tributary
are classified as EFH?
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G. Terrestrial animals
87. We know the proposed mine area is productive for terrestrial animals.
Caribou migrate through the area and are known to calve nearby. Moose
inhabit the area. Bears den near the deposit and travel through the
area enroute to feeding grounds on the salmon spawning grounds. Fox,
wolves, porcupine and a variety of other animals live here. What is
being done to document the existing habitat, animal populations and
movements? What effect will the mine and attendant infrastructure have
on terrestrial wildlife?
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H. Ecosystem integrity and interconnectivity
88. There is great deal of interconnectivity in the ecosystem of the
project area. Bears rely on spawning salmon. Trout rely on salmon eggs.
Caribou, wolves and bears migrate through the area. What is being done
to evaluate the overall ecosystem?
89. What is being done to evaluate potential impacts when one of the
ecosystem components is changed or damaged?
90. What is being done to evaluate potential impacts due to habitat
fragmentation and obstacles resulting from infrastructure developments?
91. Are migratory routes being documented?
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I. Visual effects and noise
92. What are the potential sources of visual disturbance and noise?
Will you provide a complete list?
93. How far away will the sound from blasting travel? Will we hear a
blast in Nondalton? Newhalen? Iliamna? Igiugig? Pedro Bay? Port Alsworth?
94. What affect will blasting noise have on terrestrial animals, spawning
fish, and other wildlife?
95. How often will blasts occur?
96. Will lights be visible in Nondalton? Newhalen? Iliamna? Igiugig?
Pedro Bay? Port Alsworth?
97. Will the sound of mining equipment or processing facilities be heard
in Nondalton? Newhalen? Pedro Bay? Port Alsworth?
98. If trucks will be used to transport the product, how many trucks
will pass by Pedro Bay every day?
99. If a train was used to transport the product, how many trains would
pass by Pedro Bay each day?
100. If a slurry pipeline was used to transport the product out, how
many trucks per day would be bringing supplies to the mine?
101. What will be done to diminish or avoid light and noise emanating
from trucks or trains?
102. How visible will the mine infrastructure be from aircraft flying
at normal altitude (~1,500 feet ASL) between: Port Alsworth and Nondalton?
Nondalton and Iliamna? Nondalton and Igiugig? Nondalton and Pedro Bay?
Port Alsworth and Katmai Park? Iliamna and sports fishing areas on Upper
Talarik Creek and Lower Talarik Creek?
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J. Reclamation and post-closure environment
103. Can you give an overview of what the mine footprint will look like
after the mine has been closed and reclamation of the land has been
completed?
104. Will the land be reestablished as wildlife habitat with the same
soil and vegetative cover that is present now?
105. How will water be prevented from being contaminated by mine rock,
tailings and infrastructure?
106. Who will be liable for risk management once the mine is closed
and NDM moves on?
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K. Adequacy of baseline studies
107. We understand that NDM plans to apply for its permits in the summer
of 2005. We also understand that NDM has collected baseline environmental
and socioeconomic data in 2004, and that Cominco also did some baseline
work previously. We further understand that baseline studies will continue
through the permitting process. Under the development schedule, as we
understand it, this will mean three years of NDM-generated baseline
data will be in hand when the permits are expected to be issued. Given
the enormous area potentially affected, and the variability of the ecosystem,
we are concerned that the length of study for baseline development may
be inadequate. We think this especially possible for environmental components
such as caribou migration and surface water hydrology as it relates
to salmon spawning and rearing. Can you demonstrate that three years
of baseline data is adequate for all ecosystem components?
108. Can the permitting process proceed properly, and can scientifically
defensible decisions be made with only one or two years of baseline
data in hand.
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L. Catastrophic failure
109. The Pebble project is located in a seismically active area. There
is potential for severe earthquakes and volcanic eruptions. The region
is also prone to strong winds and occasional rainstorms and flood events.
All of these natural disasters have the potential to cause environmental
damage on a large scale. This damage may be irreversible. (eg a tailings
dam failure that spills tailings and acidic metal-laden waters into
the Koktuli River and the remainder of the Nushagak-Mulchatna watershed).
Can NDM provide a complete list of the risks associated with such natural
disastrous events?
110. How will NDM protect against these natural disasters?
111. Will there be secondary structures built as safeguards? (eg, a
secondary, emergency tailings dam?)
112. How will NDM manage water flow in the event of a large rainstorm?
113. What are the design criteria for water management? 50 year flood?
100 year flood? 500 year flood?
114. Will there be any risks associated with floods and seismic events
after mine closure? For example, could there be a release of contaminated
water from the tailings pile 1000 years from now in the event of major
earthquake? Please supply a complete list of risks associated with natural
disasters in the post-mining period.
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Socioeconomic:
A.
Subsistence
115. Of primary concern to area residents is the potential for loss
of subsistence resources. These resources could be lost due to contamination,
environmental degradation, ecosystem disruption, or through additional
competition and use resulting from a dramatic human local population
increase. If the impacts analysis from an Environmental Impact Statement
(EIS) indicates that there will be a loss of subsistence resources,
how will NDM deal with the issue?
116. How can NDM protect subsistence users from loss due to additional
competition due to population increase as a result of the Pebble project?
117. If NDM cannot protect from the loss, can it, or will it, compensate
for the loss? If so, how do you propose that this would occur?
118. The Nushagak – Mulchatna River produces a substantial run
of Chinook (King) Salmon. This fishery is of exceptional subsistence
value. NDM has stated that its project will result in no net loss of
fish. Will NDM commit to say that its project will result in no net
loss of fish on a species basis? ie: Will NDM stipulate that there will
be no net loss of King Salmon? Replacement of King Salmon with sockeye
or other species may be interpreted as “no net loss”, but
this would not be an acceptable substitution to us.
119. We understand that studies will be carried out to assess the baseline
use of subsistence resources. In the wrong hands, such as unethical
hunting guides, this information could be used to the detriment of subsistence
users. How is this information kept confidential through a public process
and in perpetuity?
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B. Commercial Fisheries
120. Commercial fishing has been virtually the sole economic driver
of the Bristol Bay region for decades. Though drastically reduced in
value due to price depression that came with the advent of farmed fish,
the industry is still extremely important to every Bristol Bay resident,
regardless of whether they are employed directly in the industry or
not. Contamination and environmental degradation has the potential to
reduce or eliminate salmon runs in the case of improper engineering
or operation. We see potential effects for both gradual degradation,
and from catastrophic events. While we understand that NDM intends to
use the best possible engineering and operational procedures, it is
possible that mistakes will be made, and that catastrophic damage to
the fisheries could result. Is NDM doing studies to evaluate the relative
risk to commercial fishery damage?
121. How high is the risk that commercial fisheries could be partly
or completely damaged?
122. Will there be financial compensation in the event that commercial
fisheries are damaged?
123. Bristol Bay commercial fishers have made advances in market recapture
by advertising their product as natural wild Alaska salmon, free from
antibiotics and other contaminants. Part of the marketing theme is that
the Bristol Bay fish come from untouched, pristine waters. A large-scale
mining operation, even if it is run to the highest possible environmental,
engineering and operational standards, will still cast a shadow of doubt.
In marketing, perceptions are reality. The presence of the mine may
detrimentally affect the ability of Bristol Bay fish marketers to successfully
regain market share. Does NDM have any suggestions on how to deal with
this issue?
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C. Sports fisheries and Tourism
124. Some of the regions employment and revenue is derived from these
industries presently. In the immediate project area an industry catering
to elite fly fishers has evolved. Though we understand that it is NDM’s
goal to build a mine without affecting the quality or quantity of the
fish resource, the fact is that the patrons of these lodges are paying
for time in a remote, pristine, non-industrialized setting. The presence
of a mine, and a much expanded population would change the experience,
probably to the detriment of lodge owners. Tourists visiting nearby
parks similarly expect an experience in a pristine environment. How
does NDM respond to this issue? What can it do to avoid the problem?
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D. Population
125. We understand that the mine may employ 1000 people. Since many
of the jobs require skills not readily available in the region, out
of necessity, many people will move to the area. We have already inquired
about potential effects this increased population could have on subsistence,
environment, and wildlife. However, a large population increase would
also put out demands for schooling, medical facilities, police force,
fire departments and other services. Who is going to pay for services
that will have to be developed or expanded?
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E. Lifestyle change
126. Related to population increase, we envision that lifestyles of
area residents would be radically altered. While some of the changes
may be beneficial, some will not be. How does NDM respond to this issue?
127. Many residents lead a “subsistence lifestyle”. Such
a lifestyle may no longer be possible once the mine is developed. How
does NDM respond to this issue? Some sort of compensation might be proposed,
but how does one place a dollar value on a lifestyle?
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F. Employment and training and business opportunity
128. NDM has indicated that it will endeavor to hire locally, facilitate
training, pass on business opportunities to local residents, and provide
business development guidance. Some local residents have secured employment
at the project, and some have availed themselves of the training opportunities
provided by NDM. What is NDM’s long-term plan for workforce development?
What will NDM do to ensure that local residents get the training they
need so that they can secure meaningful employment in advanced positions
at the mine?
129. When will the longer-term training begin?
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G. Infrastructure development and accessibility
130. We understand that some sort of transportation system will be built,
and that it is most likely to be a road leading to Cook Inlet.
131. Who will have access to the road?
132. To what standard will the road be built?
133. Who will pay for the road?
134. Who will pay for maintaining the road?
135. Who is performing the transportation system alternatives analysis?
136. How rigorous is this analysis?
137. Is the alternatives analysis complete?
138. Is a railway being considered? If not, why not?
139. We have heard that a slurry pipeline may be used. If so, will there
still be a road? Who will have access to the road? To what standard
will the road be built?
140. What sort of port facility will be constructed?
141. Who will have access to the port?
142. Is it reasonable to expect that the port will accommodate cruise
ships? Barge traffic carrying tourists in recreational vehicles?
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H. Change of ownership
We are concerned that NDM will sell its interest in this project to
another mining company. NDM has made some verbal commitments to the
people of Bristol Bay, but none of these commitments are in writing
in some enforceable form. We are concerned that if NDM’s interest
is old, the new owner will not honor the commitments your company has
made.
143. Will NDM be willing to make written commitments that will be binding
upon subsequent owners of the project?
144. We have heard of Impacts and Benefits Agreements in Canada. As
a Canadian based company, you must be aware of these agreements. Do
you believe these agreements to be of value to both the mining company
and the local people?
145. Are you willing to negotiate an Impact and Benefit Agreement with
local entities?
146. Will Northern Dynasty be the mine operator?
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I. Shutdowns, Bankruptcy
147. What will happen if NDM finds that it cannot operate the mine profitably
due to low metal prices?
148. Will there be adequate contingency funding to ensure environmental
protection in the event of a prolonged shutdown? Please provide details
and examples.
149. What will happen if NDM becomes insolvent?
150. Will there be adequate funding, set aside from the hands of creditors,
available to ensure environmental protection, even in the event of bankruptcy?
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J. Bonding
We understand that bonds are put in place to ensure that adequate funding
is available for reclamation. We also understand that often, a fund
is developed for this purpose and that it is built up over time in the
mine life. We are concerned that there will not always be adequate funding
available for reclamation at all stages of the project. For example,
if, ten years from now, a mine has been built and is operating, but
metal prices decline dramatically due to some unforeseen economic event,
for a prolonged period.
151. Will there be adequate bonding and reclamation fund monies available
to perform full reclamation at all life stages of the project?
152. Who determines the amount of bonding that must be in place?
153. How rigorous is the financial analysis that results in the calculation
of the bonding amount?
154. Who supplies such bonds?
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K. Cumulative impacts
155. Is it a reasonable possibility that NDM will develop some of the
other deposits it has discovered on its Pebble claim block?
156. Will NDM supply a list of secondary, cumulative impacts that it
reasonably anticipates will become reality?
157. Will the EIS consider these secondary, cumulative impacts?
158. What weight is given to cumulative impacts by regulators when they
assess impacts in their determination of permit issuance.
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L. Participation in public process
We understand that NDM will be finalizing its alternatives analysis
and economic feasibility over the next eight months. It follows then
that the preferred alternative and mine design will be formulated in
the next few months. We have been told that we will have input to the
project. Though NDM has informally listened to feedback from local residents
there appears that there will be no regimented input into the initial
engineering proposal that NDM plans to submit to the Department of Natural
Resources. We think it important that local residents have formal, structured,
regimented and meaningful input into the initial design.
159. Will NDM provide an opportunity to provide formal, structured,
regimented and meaningful input into the initial design?
160. We are unsure of how local residents are meant to participate in
the public process. The timelines are not clear, and it is not clear
how meaningful our comments and concerns will be. Can NDM provide clarification
of the public process?
In particular, we would like to know how we could have meaningful input
into project design parameters such as the placement of tailings disposal
site and the method of product transport.
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Access to road.
Accommodation of mine staff – community versus company camp /
town.
161. Will the road (or railroad or pipeline), and the power generation
system, be permitted in a joint EIS process with the mine, or will the
three be separate public processes?
162. What are the merits of separate versus mutual permitting of the
facilities?
163. Who makes the decision as to whether the permitting process is
separate or mutual?
164. Will NDM allow us to provide input to these project design parameters
prior to submission of a draft proposal and permit application?
165. When do we get to say whether we find the project acceptable, and
how much weight is given to our opinion if we do not find the project
acceptable?
166. Can we stop this project if we do not think that it can be safely
built and operated?
167. We are aware that in its agreement with Cominco, NANA Corporation
has the power to stop operations if there is a valid environmental reason
to do so. Recognizing that NANA is the mineral right owner in the case
of Red Dog, and therefore in a stronger position, would NDM nevertheless
be willing to sign an agreement that would allow a local oversight agency
the power to stop operations under certain conditions detrimental to
the environment?
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M. Preservation of cultural resources, heritage
We understand that there is little in the way of cultural resources
in the immediate mine site. However, with a much-increased population,
there is a strong chance that there will be interest in archaeological
sites elsewhere in the region. It will cost Native groups money to protect
these resources. Further, with a much-increased population, it is likely
that Native heritage will be lost or diluted.
168. Will damage to cultural sites be considered a potential impact
in the EIS?
169. Will impact to Native heritage be considered in an EIS?
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N. Communications
To date, NDM has been forthcoming with information about its project,
and the alternatives that it is considering. We recognize that the level
of effort and expense NDM has put into communication is above and beyond
what is often put forth by resource developers in these situations,
and more than is required by public process.
170. Will this level of communication continue commensurate with the
permitting process, and subsequently through development, operation
and closure?
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O. Native Liaison
We have heard that NDM will hire community coordinators in villages.
171. In what villages will these coordinators be hired?
172. When will the coordinators be hired?
173. What will be the duties of the coordinators?
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P. Schedule
The current schedule that NDM has shown us has permitting being completed
two years after permit applications are filed. Construction is to take
place in the following two years after that, with production to immediately
follow.
174. Is it possible to construct the road and the mine in just two years?
175. The schedule seems to us to be on a fast track. Having only two
years to consider the project, have input to the project design, and
consider all the ramifications seems too short, in light of everything
we see at stake. While we understand some of the reasons NDM might have
for moving forward as rapidly as possible, we want to make sure there
is adequate time to truly consider and debate the merits of the project,
weighing the risks against the rewards. Would NDM consider relaxing
the permitting schedule to allow for more in-depth consideration?
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Other
Miscellaneous Questions
176.
Is there any circumstances upon which NDM would elect not to develop
a mine at this site? If so, what are they?
177. Other than unfavorable financial feasibility analysis, what could
stop this project from proceeding?
178. What is the overall mine footprint?
179. Does NDM have investments or partnerships with other companies
that are planning or operating projects in and around the Pebble Project?
180. What, if any, ties does NDM have with Bristol Bay Native Corporation
and its subsidiary companies?