My name is Simon Jutras, I am submitting my comment on

The Upper Beaver Gold ProjectIAAC Reference Number: 82960

Upper Beaver Gold Project–1

In addressing the proponent’s proposal, the Upper Beaver Gold Project, it would be difficult not to speak from the heart as my family has been on

the Beaverhouse Lake-Misema River for 71 years.

This picture is an early morning sunrise on the Misema. I had stopped the boat and sat in silence watching the morning sky unfold. These are moments of wonder that cannot be quantified within profit and loss. These are moments measured in the deep personal enrichment of our being in its connection to nature. Beaverhouse Lake-Misema River

Misema River

My name is Simon Jutras, I am submitting my comment on behalf of myself and my brother Richard Jutras. Today it is my privilege to be one of the voices to speak in support of the Misema River and for those who have come before us, and the generations that will follow to protect this eternal source of life.

As a child I drank directly from the waters of the Misema. As a child I was taught to build a fire by an aboriginal man that was born on the Misema in the 1800’s. He was a man that held the hand of history, as do the pictographs on the walls of the Misema. A testament and reminder of those who came before us as guardians of this river.

It would be my view, that to upset the balance of this river system that has flowed for tens of thousands of years, will require our vigilance, dedication and understanding. We are the witnesses to a harmony of life and growth that has sustained itself through time.

It is incumbent on everyone within this process, at every stage to seek and meet the highest standards of Environmental and Engineering science, new technologies, promoting compliance to international standards regarding climate change, project management and community engagement in every aspect of the project, ensuring the Misema River and the surrounding habitat are not casualties of the Upper Beaver Gold Project.

Please support our call for a full Federal Impact Assessment.


IDP Document Reference

Concerns Comments


Have the towns, townships, organizations that are encompassed by the flow of the Misema River and the Blanche River been notified of the Upper Beaver Gold Project?

It is incumbent on the proponent to see everyone within the territory of the Misema and Blanche Rivers as stakeholders.

The Upper Beaver Gold Project will discharge effluent into the Misema River that flows into the Blanche River, flowing into the Ottawa River and eventually the St. Lawrence River for a period of 13 plus years.

Why were the stakeholders downstream not advised of the Upper Beaver Gold Project?

These stakeholders have now been denied the opportunity to comment directly to the IAAC.

While having a conversation with a member of another stakeholder group, it became clear that we were each receiving selective information, that left each of us unaware of issues particular to each stakeholder group. The old adage “Divide and conquer” seems appropriate.

The proponents IPD indicates:

“It is possible that the list of stakeholders will expand as the project progresses.”

General InformationPages 1–9

Summary of Engagement with StakeholdersA.3 Page 3

The following is a list of stakeholders that were consulted prior to and during preparation of this Initial Project Description.

• Beaverhouse Lake cottagers and surface rights owners • Township of Gauthier • Town of Kirkland Lake • Township of Larder Lake • Citizens from the Kirkland Lake area • Kirkland Lake District Chamber of Commerce • Kirkland District Game and Fish Protection Association; • Timiskaming Abitibi Trail Association; • Kirkland and District Community Development Corporation; • Stella-Jones and Eacom Timber Company; • Ministry of Northern Development, Mines, Natural Resources and Forestry • Ministry of the Environment, Conservation and Parks • Impact Assessment Agency.

Beaverhouse Lake

IPD Document Reference

Concerns Comments



“Agnico Eagle is also conducting other explora-tion programs in the region that are unrelated to the Upper Beaver Gold project, which may or may not continue in parallel with the project.”

Will the proponent elaborate on this statement, clarifying how other exploration programs may run in parallel with the Upper Beaver Gold project?

Given the scope of this project if additional exploration programs do run in “parallel” with this project, there are a vast range of questions and implications that need to be clarified by the proponent before approval of the IPD can move forward.

“Agnico Eagle currently has environmental applications in progress with provincial ministries for an advanced exploration program that could be started in 2022 to collect a bulk sample of approximately 60,000 t from at least three underground areas at the Upper Beaver Gold site.”

Will the proponent provide the following information:

• The number and locations of bulk sample sites. • The depth for each sample zone.

• Identify which sample area will be reached by exploration shaft and exploration portal.

The questions posed here is important to deter-mine the potential of an “advanced exploration” stage actually becoming a production phase under an Advanced Exploration permit.

Project InformationPages 12–24

Ongoing Exploration–related Facilitiesand InfrastructureB.3.3 Page 14



Beaverhouse Lake



Concerns Comments


“The existing historic underground working will be accessed to extract the bulk sample by means of an exploration shaft and new portal.”

• What is the required depth needed for the “exploratory” shaft and ramp to reach the bulk sample zones? • Has the proponent established that the historic underground workings are safe to extract the bulk sample?

• What type of rehabilitation is required to the historic workings to obtain the samples required?

• What is the projected time frame to drive the exploration ramp and shaft?

• What is the expected tonage of waste rock generated with the exploration ramp and shaft? • Where will the waste rock for the bulk sample be stored?

• What heavy equipment for surface and underground ramp construction will be required to drive the shaft and ramp, during “Advanced Exploration?”

Given the facilities and infrastructure stated as required for advanced exploration in the IPD, can this phase really be called advanced exploration? Does the potential exsist of a construction and production phase starting once the permits for the advanced exploration stage are issued?

The required integration of infrastructure for the “exploration” ramp and shaft, the mitigation required for historic workings and construction of the pit in conjunction with diversion of the Misema River cannot be described as an advanced exploration stage. This is false and misleading.




Ongoing Exploration–related Facilitiesand InfrastructureB.3.3 Page 14–16

“Facilities required to support the advanced exploration program include:”

York Lake—This is the site of the historic underground workings 1960’s—early 1970’s, The site consisted of a headframe and one building. An exceptionally small footprint.

The Wildlife and Habitat have no voice.


Concerns Comments




Proposed Mine Facilitiesand InfrastructureUnderground MineB.3.4 Page 17

“Mineral waste associated with the mine devel-opment will be re-used to backfill the mine as practical.”

Tailings Storage page 19

“A paste backfill plant will allow a portion of the tailings to be mixed with a binder (such as cement) that will increase the strength of the materials, so that they can be returned to the underground workings to provide additional underground stability without negatively affecting environmental aspects.”

The proponent has not offered enough information with regards to Paste Backfill Plant.

There is only one mention of a Paste Back-fill Plant in the proponents IPD. In the Tailing Storage section page 19, and no mention of a Paste Backfill Plant in the Plain Language Summary.

The Paste Backfill Plant is an integral part of any underground mine operation and infrastructure.

• Paste Backfill Plant Is the volume of water required been accounted for in the permits issued as of October 4, 2021?

• The sand requirement for the Paste Backfill Plant. Is the proponent exploring for sand pits as they are for aggregate pits?

• If the proponent is exploring for sand pits will the local stakeholder be informed. As of October 2, 2021 local stakeholders have no information.

• If sand is being transported daily to site, what are the estimates of loads per day and impact of the carbon footprint for the proponents project and surrounding area?

Habitat—Has no Voice

Beaverhouse Lake



Concerns Comments



Proposed Mine Facilitiesand Infrastructure

The Open Pit and Diversion section in the proponents IPD covers less than a page in this document and does not adequately address the broad impacts, complexities and interrela-tionships of multiple aspects of this project and omits information that is required to understand the full impact of the open pit, the de-watering of York Lake and the Misema River diversion.

As a local stakeholder, the casual presentation of this aspect of the project and the omissions and lack of transparency by the proponent continue to foster mistrust on the part of local stakeholders.

Open Pit and DiversionB.3.4 Page 17–18



Open Pit and DiversionB.3.4 Page 17

“Rock stability investigations during 2019/2020 identified that there was insufficient competent rock in place between the surface the first old mine workings. Approximately 20 metres (m) of unconsolidated materials and 20 m of bedrock are present above the proposed mine workings.

Agnico Eagle and their technical consultants are concerned that mining under this material could cause an instability, and potentially catastrophic failure and collapse of these materials into the underground workings, causing the Misema River to flow into the underground mine.”

Given the issue of rock stability stated by the proponent, does this impact extracting a bulk sample from the historic workings?

Is the bulk samples requested from the historic workings under the proponents proposed pit?

It is understood in the mining industry that an open pit allows a mine to generate immedi-ate revenue to support start up costs, without the high infrastructure costs related to under-ground mining.

It appears the advanced exploration stage has been planned to ensure that a great deal of the infrastructure, preliminary construction and production can be achieved before even entering the construction and production stage under Advanced Exploration Permits.

Having worked underground I am in no way attempting to diminish safety issues. A full IA would allow the proponent to establish the strength of their position and equally allow a full and rigorous assessment of this projects claim that the pit is required for safety reasons.

Beaverhouse Lake


Concerns Comments






“The benches in rock will be developed by blast-ing using an ANFO (ammonium - nitrate / fuel oil) explosive and/or an emulsion explosive.”

• Will the proponent discuss and offer information regarding the relationship between the different types of explosives and the rates of dissolution within water?

For example, an emulsion explosive that has a longer dissolution rate where unac- ceptable levels of effluent might not be detected immediately by source discharge monitoring, but potentially would be caught if monitored further downstream from the projects footprint?

• How many monitoring points are planned along the Misema and Blanche Rivers? • Will the proponent provide an in-depth monitoring plan?• Given the proponents public statements of their leadership in environmental aware- ness, and process application would they commit to levels of monitoring above the minimum requirements set by provincial and federal agencies?

Given the potential life of this mine and an onsite mill that potentially will be processing ore from other mines. The long term impact on the Misema and Blanche rivers, local habitat, wildlife has to be considered. It is imperative this project under go a Federal Impact Assess-ment review.

Ava Lake waterfall into York Lake

Wildlife—Has no Voice

Beaverhouse Lake



Concerns Comments




Open Pit and DiversionB.3.4 Page 17 Ava Lake & York Lake De-watering

Misema River Diversion

“In order for the open pit to be developed, chan-nels will be created and dykes placed, so that the Misema River can be safely diverted just around York Lake maintaining the integrity of the river system once channel is stabilized.”

• There is no information regarding the construction of the channels?

• Are the channels artificial or will they be blasted with the resulting forest habitat lost?

• What materials will the dikes be constructed with?

• What heavy equipment will be required?

• Access to the Channel and Dike sites, will this result in habitat and forest destruction?

• Will barges be required and if so what are the potential impacts on Ava Lake?

• Can the proponent explain channel stabilization and what are the potential impacts to the aquatic life and habitat are before stabilization?

The information offered in the section Open Pit and diversion is inadequate.




“The channels will be designed to handle the necessary water flows, as well as passage of fish, at least equivalent to the current conditions.”

• Can the proponent elaborate on the data they are going to use to design the the channels that will “handle the necessary waterflows?”

• Can the proponent elaborate on the data they are using to establish current conditions?

Ava Lake

Ava Lake Rapids

Beaverhouse Lake


Concerns Comments






“There is the potential that on closure of the mine, the open pit could be reflooded to create a larger lake at the current York Lake location.”

Can the proponent provide examples and evidence that the reintegration of the pit into the Misema River will offer a viable aquatic environment that will equal the natural environ-ment of the Misema River?




“Ongoing exploration has also identified small ore deposits close to the surface on the plateau area south of the tailings storage facility. This mineral-ized zone could potentially be extracted without loss of potential resources, while providing addi-tional opportunities for site water management.”

• Will the proponent elaborate the specifics of this statement?

• I s there a 2nd Pit being planned?

• Will the proponent elaborate on “Opportunities for site water management.”

Once again the issue of transparency is at the fore here.

Is the proponent suggesting a second pit will be developed, and what is meant by additional opportunities for site water management?

The proponent’s IPD does not offer enough information.



Concerns Comments




Aggregate OperationsB.3.4 Page 21

“Agnico Eagle is planning a field investigation during Fall 2021 to assess a potential aggregate source in a fluvio-glacial system identified by a geomorphology study southeast of the site (see Figure B.1).”

The proponent gave the local stakeholders no notice that there would be an ongoing exploration for an aggregate pit.

It was one of the local stakeholders who dis-covered the exploration work.

When the proponent was asked at a September 22, 2021 meeting directly why the local stake-holders were not advised in our August 2021 meeting about the aggregate pit, the proponent responded it was a last minute decision.

It was then pointed out to the proponent that Aggregate operations are listed in the IPD.



Water Management Facilities and Drainage Works–Ava LakeB.3.4 Page 20“Additional fresh water will be required for ore processing and a fire water supply, and is expected to be pumped from Ava Lake. A potable water treatment plant could be constructed to treat water for use on site.”

Is the additional fresh water that will be required from Ava Lake for ore processing and fire water supply, covered under permits issued by provincial or federal agencies as of October 4, 2021?

Ava Lake

Ava Lake Rapids

Beaverhouse Lake




Concerns Comments



AccessB.3.4 Page 20

“There is an existing site access connected to Beaverhouse Road. It is expected that a portion of the access road on site will require re-routing to avoid the open pit. An access road for local cottagers and other land users is expected to be developed so that local traffic can avoid the secure area of the mine development.”

Road Access

Local stakeholders were told in the late summer of 2020 that there would be an open pit and we would lose road access to the Beaverhouse boat landing, but assured that there would be an alternative found.

When the topic has been brought up by stake-holders in the last year we have been told there will be specific meeting to find a solution.

As of Oct 4, 2021 that meeting has still not taken place and it is over a year since it was promised.

The Road access to Beaverhouse Lake has been a public access and a Historic right of way for at least 100 years.

The proponent has acknowledged they do not own the road. The road is used by local stake-holders, local recreation for the town of Dobie and the surrounding municipalities.

It is only in the last couple of weeks since the release of the IPD that local stakeholders have understood why we have not been offered a meeting regarding road access. The reason is tied in with the rapids between Beaverhouse and Ava lakes and the aggregate pit.

Beaverhouse Lake Landing

Rapids at Landing Ava Lake side



Concerns Comments



The Rapids Beaverhouse Lake—Ava LakeThe proponent’s IPD does not include any reference to the rapids between Beaverhouse Lake and Ava Lake.

The only reference with regards to this obvious and important environment and geogologic con-nection between the two lakes is in the following under Buildings and Yard Areas:

“Three new water crossings are currently proposed for the Upper Beaver Gold project, likely as culverts, but potentially as bridges.”

The Beaverhouse & Ava Lake rapids are identified on the preliminary site map as a marker for a possible “culvert”.

(Figure B.1). & P. 20

Beaverhouse & Ava Lake Rapids

Ava Lake

Ducks at the Beaverhouse—Ava Lake Rapids

The Beaverhouse—Ava Lake Rapids have been only identified as a pin mark on the priliminary sitemap in the proponents IPD as a potential culvert. The above picture speaks for the reality of the environment. Why would the proponent exclude the rapids from the IPD, very simply the aggregate exploration if successful will need to be transported to the mine site.

Will the proponent transport the aggregate out Fork Lake road, to highway 66, back to Dobie then up to the mine site, no the proponent will build a culvert across the rapids. Consideration of this option was verbally acknowledged by the proponent to the two stakeholders at a Zoom meeting on September 22, 2021.

The proponent did not disclose to local stakeholders in the early or late summer meetings that they would be exploring for aggregate. The proponent has over the last year continued to say there will be a meeting regarding options for the closure of our historic access to the lake. No doubt there will be a meeting offered when the proponent has reached a decision regarding aggregate.

The proponent continues to insist in the Summary of Engagement with Stakeholders (A.3 page 2)“Build a trusting relationship through dialogue and transparency”. Sadly the local stakeholders have found no evidence of this statement in words or action over the last three years.

In my opinion this one ommision and intent is enough to bring to the fore the need for a Full Impact Assessment of this project. I am truly dissapointed in the casual arrogance the proponent has shown the local stakeholders, and the quality of the IPD submitted.

The proponent’s IPD does not include any reference to the Beaverhouse—Ava Lake Rapids.

Summary



There are moments of stillness where one experiences the awakening of all our physical senses. It is in these moments that one is embraced with the understanding that the Misema is a source of life for the complete environment through which it flows.

It represents all that is sacred with in an union of one. It is a heartbeat, as relentless as time, flowing to all of us. There are aspects of the Misema that are deeply sacred to tradition.

It is imperative that the IAAC demand a Full Federal Impact Assessment. To seek alternatives to the diversion of the Misema, and the de-watering of York Lake for an open pit. This Misema is a monument to time, it deserves our wisdom and collective will to ensure it is sustained for those that will follow us.

In this brief summary I try to find words to describe what the gift of knowing the Mesima has bequeathed my 67 years. It cuts very deeply, to read the casual quantification of this flow of life as only a resource.

This is not a process to ensure shareholder satisfaction.

“The Upper Beaver Gold project is intended to help meet this corporate need and provide a return on investment to Agnico Eagle shareholders.”

Page S-9 Plain Language Summary

For three years the local stakeholders have attended meetings and listened to the proponent state:

“Build a trusting relationship through dialogue and transparency”

Over the last three years this statement holds no merit in action or intent.

I ask you to consider the submission of the The Ontario River Alliance and all who have stepped forward with heartfelt conviction regarding the proponents Initial Project Description. Again I ask for a Full Federal Impact assessment. I thank you for your time and consideration.

Simon Jutras1 Beaverhouse Rd.Dobie, ON P0K 1B0

[email protected]

Documents

My name is Simon Jutras, I am submitting my comment on