Re: Teck Frontier Oil Sands Mine Project: Responses to Supplemental Information Requests (SIRs)
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1 Teck Resources Limited February 11, 2014 Métis Nation of Alberta Association Fort McMurray Local Council 1935 Attention: Kyle Harrietha (General Manager) Re: Teck Frontier Oil Sands Mine Project: Responses to Supplemental Information Requests (SIRs) Dear Mr. Harrietha: Teck is in receipt of your December 16, 2013 letter to the Canadian Environmental Assessment Agency (CEAA) regarding the Teck s responses to Round 2 SIRs. While the comments contained within the letter are directed to the regulator, Teck responds to your comments directly. We have organized our response according to the specific SIR commented on in your December 16, 2013 letter. General Concerns with the Consultation Process Issue 1: Capacity to Undertake Effective Consultation: Teck remains committed to continuing consultations with the Métis Local 1935 regarding the Frontier Project. In addition to contributing to Métis Local 1935 s Mark of the Métis study, Teck has agreed to provide capacity funding for a Métis Local 1935 Project specific traditional land use study. Upon receipt, Teck will consider the additional information in Project planning and future stages of engineering. Teck has also recently developed a consultation work plan with Métis Local 1935 this consultation work plan was developed and agreed upon by parties, meeting the needs of Métis Local 1935 and addressing concerns regarding sustained engagement with Local 1935 membership.
2 Issue 2: Lack of Engagement by Teck, the Government of Alberta and the Federal Government: as above. Comments on Teck s Response to Round 2 SIRs Cover Letter: concerns regarding capacity funding have been responded to above. ERCB Response 2a: concerns regarding capacity funding have been responded to above. Furthermore, as stated above, Teck has committed to provide capacity funding to Métis Local 1935 to undertake a Frontier Project specific traditional land use study. ERCB Response 29b: Generally speaking, Teck considers Aboriginal communities in the oil sands region as potentially affected and has engaged these communities with respect to the Frontier Project, including Métis Local Teck will consult with any Aboriginal community in the oil sands region regarding the development of a wildlife mitigation plan that expresses an interest. Capacity funding to participate in the development of mitigation and monitoring plans for any aspect of the Project and/or research programs will be discussed with individual communities, upon request. With respect to regional monitoring initiatives, Teck is helping fund the Federal / Provincial Joint Oil Sands Monitoring Program, which is comprised of new monitoring stations in addition to stations previously operated by the Regional Aquatics Monitoring Program and the Wood Buffalo Environmental Association. Teck will monitor the status of CEMA in 2014 and make a final decision regarding our involvement once clarity as to its ongoing status exists. ERCB Response 32a: Teck will provide employment and procurement monitoring results to MNA R1 and any other Aboriginal community upon request. Teck has not yet developed specific mechanisms for dissemination of this information and will be seeking input from Aboriginal communities regarding the dissemination of this information. ESRD/CEAA Response 1: concerns regarding capacity funding provided to Métis Local 1935 have been responded to above. Teck remains open to consulting with any Métis community in the oil sands region regarding reclamation, barriers to education, employment and training, business development, monitoring or any other aspect of the Project that communities express an interest in. ESRD/CEAA Response 30: As stated above, Teck will monitor the status of CEMA in 2014 and make a final decision regarding our involvement once clarity as to its ongoing status exists. ESRD/CEAA Response 43g: Teck will consult with any Aboriginal community regarding fish compensation, upon request. ESRD/CEAA Response 43i: Project-specific traditional land use baseline studies for all Aboriginal communities are not required to understand fish species with traditional use value in the oil sands region. As stated above, Teck will consult with any Aboriginal community regarding fish compensation, upon request. ESRD/CEAA Response 60a: as stated above, Teck will consult with any Aboriginal community Project such as the river water intake. Additionally, Teck will engage Métis Local 1935 regarding wildlife and riparian habitat fragmentation to better understand these concerns.
3 ESRD/CEAA Response 61a: as stated above, Teck will consult with any Aboriginal community Project such as the location of infrastructure and access management. ESRD/CEAA Table 62 b-1: During consultations for the Frontier Project, Aboriginal communities expressed concern regarding increases in traffic as a result of ongoing development and the development and operation of the Frontier Project. Additionally, concern has been expressed regarding increases in traffic in the region. Teck did not undertake interviews with Métis peoples regarding the pros and cons of camp construction. Teck remains committed to continuing consultation with Aboriginal communities regarding the Frontier Project and is open to discussing accommodations with Métis Local The positive and negative factors listed in Table 62b-1 were identified based on professional judgment and experience gained by Teck during initial phases of engineering and development of the Integrated Application. ESRD/CEAA Response 65a and c: Teck commits to consulting with the RFMA holder in question. ESRD/CEAA Response 68: as stated above a Métis Local 125 Elder intimately familiar with the Project area participated in a helicopter fly-over in June 2010 to assist Teck in evaluating potential river water intake locations. Teck s choice of location for the proposed river water intake took into consideration traditional land use information available to Teck. Teck will continue consulting with potentially affected Aboriginal communities regarding infrastructure such as the river water intake. ESRD/CEAA Response 87: as stated above, Teck has committed to providing funding for Upon completion of the study, Teck will consider the additional information, including how it may inform Teck s understanding of potential effects to Key Wildlife Biodiversity Zones as a result of the Frontier Project. ESRD/CEAA Response 90: as stated above, Teck has committed to providing funding for ESRD/CEAA Response 91: as stated above, Teck will consult with any Aboriginal community Project such as potential effects to wildlife (including caribou). ESRD/CEAA Response 137: as stated above, Teck has committed to providing funding for ESRD/CEAA Response 138 (General): concerns expressed here have been responded to throughout this letter. ESRD/CEAA Response 138a: concerns expressed here have been responded to throughout this letter. ESRD/CEAA Response 138c: Teck will consult with any Aboriginal community regarding fish compensation, upon request. As stated above, Teck has committed to a Métis Local 1935 Project-specific traditional land use study and has recently jointly developed a consultation work
4 plan with Métis Local 1935, meeting the consultation needs and interests of this community. To be clear, Teck does not consider trapper compensation as compensation for impacts to Aboriginal Rights. ESRD/CEAA Response 142a: concerns regarding capacity funding for Métis Project-specific traditional land use studies have been responded to (above). Teck remains committed to initiating discussions on access management with potentially affected Aboriginal communities starting in ESRD/CEAA Response 143b: as above. Teck is aware of one burial site along the Athabasca River. This burial site will not be impacted by the Frontier Project. To-date, additional burial sites in the vicinity of the Project have not been identified. ESRD/CEAA Response 147: concerns regarding capacity funding for Métis Project-specific traditional land use studies and technical reviews have been responded to (above). Concerns relating to the ability to experience remoteness and solitude, and feelings of safety and security have been expressed by the Athabasca Chipewyan First Nation and Mikisew Cree First Nation in Statements of Concern provided to Teck and regulators. ESRD/CEAA Response 148: concerns regarding capacity funding have been responded to (above). ESRD/CEAA Response 155: Teck believes it has met the Terms of Reference for the Frontier Project. As discussed above, Teck will consider additional information provided by Aboriginal communities (e.g., technical reviews, traditional land use studies) in Project planning and additional stages of engineering. ESRD/CEAA Response 176c: as stated above, Teck has committed to providing funding for ESRD/CEAA Response 181c: as stated above, Teck has committed to providing funding for ESRD/CEAA Response 184c: as stated above, Teck has committed to providing funding for Membership in CEMA has been responded to above. ESRD/CEAA Response 187c: as stated above, Teck has committed to providing funding for ESRD/CEAA Response 188: as stated above, Teck has committed to providing funding for Teck is open to discussing concerns related to the Ronald Lake Bison Herd with Métis Local 1935.
5 In closing, please do not hesitate to contact me if you d like any additional information or would like to meet to discuss Project-specific concerns or any of the concerns raised in your December 2013 letter. Sincerely, Ian Mackenzie Director, External Affairs, Teck Energy Teck Resources Limited Cc. James R. Dragon (President, Métis Local 1935) William Landstrom (President, MNA R1) Debbie Bishop (K2B Law Group) Stacy MacDonald (AER) Amanda Black (AER) Carolyn Dunn (CEAA) Marek Janowicz (DFO) Janais Turuk (Teck) Sheila Risbud (Teck) Neil Sandstrom (Teck)
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