Generally, the LAA is limited to the area in which Project activities are likely to have indirect effects on VCs; however, the size of the LAA can vary depending on the VC being considered, and the biological and physical variables present.” In section 5.1.5.1.1 Spatial Boundaries, the EARD states that “The LAA encompasses an area 15 km from the PA in all directions. [...] However, due to the location in which some proposed Project activities can be performed (the locations of the East and West Pits are fixed by geology) the extent to which the Project can be manipulated to avoid impacts to wetland habitat is constrained.” The proponent should clarify what is meant by the term “wherever practical” in this context. [...] Climate Change Effects of the Environment on the Project On page vii, the proponent writes that “due to the relatively short duration of the Project, and the contingencies added to mine water infrastructure design, climate change is not anticipated to affect the Project.” The proponent should provide detailed information about the anticipated or possible impacts and risks of climate change on the. [...] Given the size of the LAA and the distributions of these species within the province, it is likely other occurrences of these observed species exist elsewhere in the LAA.” This is assumption is incorrect. [...] The plan states: “At this time, the number of monitoring stations and the level of effort at each station has not been determined.” Before the final version of the plan is approved by DNRR (which should be done before construction of the project begins), the proponent should commit to the number of monitoring stations, their location, and the level of monitoring effort that will be carried out.
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- 19
- Published in
- Canada
